The St. James's Place Wealth Management Group offers a comprehensive range of wealth management services to individuals and businesses.
At the heart of our business is the St. James's Place Partnership; the exclusive advisory arm of the St. James’s Place Wealth Management Group.
This Notice sets out important information about how St. James's Place collects and uses personal data (referred to as "personal information" in this Notice) during the process of joining the partnership. You should read this Notice carefully and raise any questions you may have with your Sponsor / Mentor, Development Manager or Data Protection Officer.
The data controllers will be the following;
1) St. James’s Place Wealth Management plc company number: 4113955 (“St. James’s Place”) whose registered office is at St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP; and
(2) St. James’s Place Management Services Limited company number: 2661044 (“SJPMS”) whose registered office is at St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP; and
(3) St. James’s Place Partnership Services Limited company number: 8201211 (“SJPPS”) whose registered office is at St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP; and
(4) Other entities within St. James’s Place plc’s group of companies as applicable.
Appropriate contractual, technical and organisational measures are in place between the entities within St. James’s Place plc’s group of companies to safeguard your data.
Personal data means information which identifies you and relates to you as an individual. St. James's Place will collect, use and store your personal information for a wide variety of reasons in connection with your development towards either becoming a Wealth Manager within St. James Place Partnership, an Adviser linked with an existing St. James’s Place practice or a Paraplanner working with an existing St. James’ place practice (collectively referred to as the "Purposes" in this Notice).
In accordance with its obligations St. James's Place will ensure your personal information is:
- processed fairly and lawfully
- obtained and processed only for specified and lawful purposes
- adequate, relevant and not excessive
- accurate and kept up to date
- held securely and for no longer than is necessary
- not transferred to a country outside of the EEA unless there is an adequate level of protection in place
St. James's Place will review the nature of information being collected and held from time to time to ensure that these principles are being followed. Where you provide personal information to us about other individuals (for example, members of your family or other dependents) St. James's Place we will also act as the data controller of their personal information and will be responsible for protecting their personal information and using it appropriately. This Notice will therefore apply to those individuals and you should refer them to the content of this Notice.
We have set out below the main categories of personal information which we process on a day to day basis in connection with the Purposes:
- name, gender, home address and telephone number, date of birth and marital status
- business contact information (including e-mail address and telephone number)
- photograph
- identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters or bank statement and evidence of benefit entitlement
- your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process.
- employment information such as job title, employment history, professional qualifications and accreditations
- notes of discussions between trainees and St. James’s Place employees
- records of work absences, holidays/paid time off, entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies)
- training and development records
- information relating to performance of tasks and activities to be achieved via the programme
- notes of discussions with St. James’s Place employees
- payment information
- emergency contact information
- voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment.
- date of termination, reason for termination
- fitness and propriety information necessary for regulatory approval
- personal information which you otherwise voluntarily provide, for example when using your St. James’ Place e-mail account
The majority of the personal information provided by you is mandatory in order for us to administer our relationship and/or to comply with statutory requirements relating to immigration or taxation. Failure to provide mandatory personal information may affect our ability to accomplish the purposes stated in this Notice and potentially affect your training and development.
The list set out above is not exhaustive, and there may be other personal information which St. James's Place collects, stores and uses in the context of the relationship. We will update this Notice from time to time to reflect any notable changes in the categories of personal information which we process.
Most of the personal information which we process will be collected directly from you. In limited circumstances your personal information may be provided by third parties, such as former employers, official bodies (such as regulators or criminal record bureaus) or medical professionals.
For the purposes of our background checking carried out as part of our selection process we will also gather data from publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites and/or engage a third party to conduct electronic ID checks, sanctions and politically exposed persons checks.
St. James's Place uses your personal information for a variety of purposes in connection with your training and development as summarised above. Most of this processing takes place in order for St. James's Place to perform its obligations under your contract and/or to comply with its legal obligations and we have set out below the main purposes for which personal information is processed:
- processing your application to join one of the St. James Place Academy Programmes
- processing your application for examination registration
- processing, recording and storing your academic achievements including notification of results
- administration of your contract (new advisers) with St. James’s Place, including remuneration agreements
- for giving references about you if requested to do so by any third party;
- to establish your training and development needs;
- for the setting up and arrangement of any pension, private health care or similar arrangements which may be arranged by St. James’s Place on your behalf;
- for regulatory and compliance purposes (which may lead to disclosure to regulatory bodies);
- to establish contact in the case of an emergency (e.g. next of kin);
- for the contact of credit reference agency services in connection with your application and whilst any loans provided to you by St. James’s Place remain outstanding
- the day to day management of tasks and responsibilities
- to manage performance, including the conduct of regular reviews
- to consider eligibility for graduation and acceptance into the Partnership
- to comply with legal requirements, such as reporting to HMRC or to a regulator
- obtain FCA approval where necessary.
- corporate travel and other reimbursable expenses (if applicable)
- conflict of interest reporting
- to address disciplinary and grievance issues
- to protect our confidential and proprietary information, and intellectual property
- to monitor the proper use of our IT systems
- to prevent fraud against the company and its clients
- for succession planning or potential placement into a St. James’s Place Practice.
In addition, St. James's Place will process your personal information in pursuit of its legitimate interests provided this does not unduly impact your privacy rights; in these cases, we have specified below the processing and the nature of the legitimate interest in question:
- In connection with the prospective transfer or sale of a business or group company, we may share personal information as part of the due diligence process and/or to facilitate a smooth transfer. In these cases, the information which we share will be anonymised wherever possible, and it will be a condition that the recipient holds the information securely, uses it only for the prescribed purposes and deletes/returns the information if the transfer or sale does not go ahead.
- In specific cases St. James's Place will carry out psychometric or job related evaluations in order to facilitate development discussions and/or to evaluate you for potential alternative roles. Additional information about how your personal information is processed in the context of these evaluations will be available at the time of completion any such evaluation.
The details set out above are not exhaustive and St. James's Place may undertake additional processing of personal information in connection with the relationship. St. James's Place will update this Notice from time to time to reflect any notable changes in the purposes for which its processes your personal information.
Certain categories of data are considered "special categories of personal information" and are subject to additional safeguards. St. James's Place limits the special categories of personal information which it processes as follows:
Health Information
St. James's Place will process information about your physical or mental health in compliance with its legal and contractual obligations, in particular (i) to administer company and/or state sick pay; (ii) to facilitate the provision of benefits, such as private medical insurance; (iii) to comply with obligations owed to disabled candidates; (iv) to comply with health and safety obligations; and (v) to maintain a sickness absence record.
We will always treat information about health as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical, and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration, or disclosure.
Health information will typically be retained during an individual's relationship with St. James’s Place. Following the termination of an individual's relationship with St. James’s Place, we will typically retain health information for 12 months subject to any exceptional circumstances and/or to comply with particular laws or regulations.
St. James's Place's policy is to retain personal information only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations. Under some circumstances we may anonymise your personal information so that it can no longer be associated with you. We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice to you.
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
In addition, we use Google's remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on our sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie.
We will only collect personal information about you if you send us an e-mail enquiry via the 'contact us' facility or you register to receive your Unit Trust Manager's Reports by email. In order for this to happen, you will need to fill out the on line 'contact us' form or complete the registration details. The type of information being collected for an enquiry will be apparent from the layout of the 'contact us' form, which also tells you how this information will be used. The type of information collected to register to receive the Unit Trust Manager's Reports by email will be apparent from the details requested when you register. The information collected when you register will only be used to email your Unit Trust Manager's Reports and for no other reason.
We take all reasonable precautions to protect our visitors' information, both on and off line. If your personal information changes, please let us know and we will correct, update or remove any information that we hold about you on our active databases. We may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which St. James's Place handles data collected from you on this website, please visit the contact us page.
By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above four paragraphs.
Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that St. James's Place employees comply with legal obligations and St. James's Place policies and procedures (including our customer relations practices).
We may provide hyperlinks from this web site ('the Site') to web sites of other organisations including websites of associated companies. Please note that this Privacy Policy applies only to this Site and that St. James's Place will not liable for the contents of linked web sites or any transactions carried out with organisations operating those web sites.
As you may be aware, no data transmission over the internet can be entirely secure. As a result, while we will always use reasonable endeavours to protect your Personal Information, we cannot guarantee the security of your Personal Information and the use of our Site (including the e-mail facilities) is at your own risk.
St. James's Place will always seek to process your personal information in accordance with its obligations and your rights.
You will not be subject to decisions based solely on automated data processing without your prior consent.
In certain circumstances, you have the right to seek the erasure or correction of your personal information, to object to particular aspects of how your data is processed, and otherwise to seek the restriction of the processing of your personal information. If you have any questions about these rights, please contact the Data Protection Officer using the details provided.
You have a separate right of access to your personal information processed by St. James's Place. You may be asked for information to confirm your identity and/or to assist St. James's Place to locate the data you are seeking as part of St. James's Place's response to your request. If you wish to exercise your right of access you should set out your request in writing to the Data Protection Officer using the details provided.
Finally, you have the right to raise any concerns about how your personal information is being processed with the Information Commissioner's Office (ICO) by going to the ICO's website: https://ico.org.uk/concerns/ or contacting the ICO on 0303 123 1113 or [email protected].
If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our Data Protection Officer by emailing us at [email protected] or by writing to Data Protection Officer, St. James's Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom.
From time to time we may need to make changes to this Notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up-to-date Notice and you can check our website periodically to view it.
This Notice was last updated on 22/5/2018