St. James’s Place Privacy policy

Personal data means information which identifies you and relates to you as an individual. As your prospective employer, St. James's Place will collect, use and store your personal information for a number of purposes in connection with its consideration of you as a candidate for employment.

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 EU 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.

We have set out below the main categories of candidate personal information which we process in connection with our recruiting activities on a day to day basis:

• personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address)
• work history and other relevant experience including information contained in CV, cover letter or job application form
• education information including degrees awarded, transcripts and other information provided in support of the job application
• remuneration history
• information collected during phone screenings and interviews
• details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits
• reference information and information received from background checks (where applicable) including information provided by third parties
• information related to previous applications to us or previous employment history with us
• documents evidencing your right to work (including information about your immigration status where relevant)
• date of birth
• gender
• information gathered through our monitoring of our IT systems, building access records and CCTV recording in relation to your communications with us and attendance at our premises
• personal information which you otherwise voluntarily provide during the course of the recruitment process

The majority of the personal information to be provided by you is mandatory in connection with our recruiting activities. Failure to provide mandatory personal information may affect our ability to accomplish the purposes stated in this Notice, including considering your suitability for employment and/or entering into an employment contract with you.

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 application and recruitment process. St. James's Place will update this Notice from time to time to reflect any notable changes in the categories of personal information which it processes.

The majority of the personal information which we process will be collected directly from you. However, your personal information may also be provided to us by third parties, such as recruitment agencies, former employers, official bodies (such as regulators or the Disclosure and Barring Service) and/or medical professionals.

St. James's Place uses your personal information for a variety of purposes to take steps necessary to enter into an employment contract with you, to comply with legal obligations or otherwise in pursuit of its legitimate business interests. We have set out below the main purposes for which candidate personal information is processed:

• to identify and evaluate job applicants, including assessing skills, qualifications and experience
• verifying candidate information and carrying out employment, background and reference checks, where applicable, and in order to prevent fraud
• communicating with you about the recruitment process and your application
• to comply with our legal, regulatory, or other corporate governance requirements

In addition to using your personal information to consider you for the role you applied for, we will retain and process your personal information to inform you about, and to consider you for other roles that may be appropriate for you. If you do not want us to consider you for other roles which we consider may be appropriate for you, please inform your recruitment contact.

Again, this list is not exhaustive and St. James's Place may undertake additional processing of personal information in line with the purposes set out above. 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 types 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

We may process information about a candidate's physical or mental health in the course of the recruitment process. In particular:

• we will process information about an individual candidate's physical or mental health to comply with our obligations to make reasonable adjustments for disabled employees as part of the recruitment process;
• as part of our pre-employment screening, successful candidates are asked to complete a medical questionnaire administered by Health Assured Ltd in order that we can take account of any medical issues relating to a new employee, including our obligation to make reasonable adjustments in the workplace. Health Assured Ltd will only share information from this questionnaire with us with your express consent.

We will always treat information about health as confidential and it will only be shared internally where there is a specific and valid 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.

If a candidate is successful, any health information processed as part of the recruitment process that is relevant to St. James's Place's compliance with its obligations in connection with employment will be retained and processed in accordance with the Employee Privacy Notice. If a candidate is unsuccessful, any health information obtained as part of recruitment process will be deleted with the rest of the candidate's personal information within 6 months of their rejection.

As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:

• former employers, in order to verify your previous employment history
• universities and/or other establishments for higher education that you attended, in order to verify your education history
• for specific roles we will undertake electronic ID checks, sanctions and politically exposed persons checks via a third-party agency

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.

We will only conduct background checking in relation to successful candidates that have accepted a conditional offer of employment with us, and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.

St. James's Place will share candidate personal information with other parties only in limited circumstances where this is necessary for the purposes of entering into an employment contract, to comply with a legal obligation, or otherwise in pursuit of its legitimate business interests as follows:

• recruitment agencies
• background vetting specialists
• occupational health providers and other medical professionals
• HMRC and/or any other applicable government body
• accountants, lawyers and other professional advisers
• the Financial Conduct Authority and/or the Prudential Regulatory Authority and/or any other applicable regulatory body
• specialists undertaking psychometric & personality tests

Wherever possible the personal information is shared under the terms of a written agreement between St. James's Place and the third party which includes appropriate security measures to protect the personal information in line with this Notice and our obligations. The third parties are permitted to use the personal information only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.

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.

For unsuccessful candidates:

• We will typically retain personal information collected during the recruitment process for a maximum period of 6 months from the end of the process subject to any exceptional circumstances and/or to comply with particular laws or regulations.

If you are offered and accept employment with us, some of the personal information we collected during the application and recruitment process will become part of your employment record and we may use it in connection with your employment in accordance with the Employee Privacy Notice. The remaining data will be stored for a period of 6 months then deleted.

There are a small number of instances where your personal information may be transferred to countries outside of the European Economic Area ("EEA") such as when we transfer information to our other companies in the St. James’s Place group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:

• entering into data transfer contracts and using specific contractual provisions that have been approved by the UK government or the UK data protection authority
• we will only transfer personal information to companies in non-EEA countries who have been deemed by the UK government or the UK data protection authority to have adequate levels of data protection for the protection of personal information. You can find out more about this https://ico.org.uk

What is automated decision making?

Automated decision making refers to a situation where a decision is taken using personal information that is processed solely by automatic means (i.e. using an algorithm or other computer software) rather than a decision that is made with some form of human involvement. We may decide to use or procure the use of automated decision making in our business processes, for example only, where to do so creates efficiencies or provides better outcomes.

What is profiling?

Profiling is any form of automated processing of personal information which evaluates certain personal aspects.

We will use profiling in circumstances including the following:

Using your skills and experience to suggest other roles that may be appropriate for you.

We may use and/or procure the use of artificial intelligence (AI) tools in to support our business processes, for example only, to create efficiencies or assist in improving our services so that we may deliver better outcomes. Without limiting the scope of use, we may use AI tools to analyse data, generate insights, suggestions, recommendations and/or actions to enhance user experience. To the extent that any AI is used by us, inputs into any decision-making process and/or decision, we shall always ensure that a human being can oversee it and/or be involved.

Use of Artificial Intelligence (AI) by Third Parties

We may engage third-party service providers who use artificial intelligence (AI) technologies to support the delivery and improvement of our services. These AI tools may assist with, for example only: data analysis, content recommendations, customer support, and operational efficiency. Such third-party AI systems shall strictly only be used where and to the extent approved by us in writing. We shall always ensure that a human being shall be able to have oversight of and/or be involved in any such use of an AI tool by any third party when processing your data, including but not limited to, for the purposes of checking any decisions made by the third party AI tool.

We continuously seek to ensure that any processing by any autonomous or semi-autonomous system or AI does not prevent the fulfilment of individual subject access rights, for example only, to erase or rectify personal data.

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 10 if you wish to exercise these rights; we will not usually charge you.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:

• in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
• in doing so we could not provide services to you, for example we could continue with your application for employment

We will of course inform you if any of the above situations arise and if we are unable to comply with your request.

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it.

We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information.

We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.

It would be helpful if you could please complete the Data Subject Request Form to request a copy of the information we hold so that we can ensure we have all the relevant information we need to appropriately respond to your request.

The right to rectification

Please help us to keep your personal information accurate and up to date so if you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.

The right to restriction of processing

In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.

The right to withdraw your consent

Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.

The right to erasure / deletion

You are entitled to request your personal information to be deleted in certain circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.

The right to object to direct marketing

You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time. You can do this either by clicking on the "unsubscribe" button in any email that we send to you or by contacting us using the details set out in section 10.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you.

The right to object to processing

In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data.

The right to data portability

In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.

When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request

Rights relating to automated decision-making

Whilst we use software to carry out automated decision making (as set out in section 9 above), we will always have some form of human involvement to check any decisions made that arise out of such automated decisions. This complies with your data protection rights to have a decision taken by automated means reviewed.

The right to make a complaint

If you are unhappy with any aspect of the handling of your data, you can complain to the St. James’s Place Data Protection Officer. If your concern remains unresolved you can also raise your concerns to the UK Information Commissioner at ico.org.uk or to the Data Protection Authority in the country where you live or work.

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 St. James's Place Data Protection Officer at St. James's Place plc, St. James's Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom, [email protected] and 01285 878 453.

The St. James's Place website uses cookies - small text files that are stored on your computer or in your browser - to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. Our sites do not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example the number of visits the website receives. In order to respect our visitors' rights of privacy, this information is anonymous and no individual visitor can be identified from it.

You can disable and delete cookies by changing the appropriate setting within your browser's 'Help', 'Tools' or 'Settings' menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org.

Please view our full Cookie policy here.

At St. James’s Place, we take our responsibility to look after your personal information and privacy seriously and we have security measures in place to help prevent fraud and cybercrime.

If we become aware that a personal data breach has occurred and is likely to result in a high risk to your rights and freedoms, we will inform you without undue delay.

Our sites use 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 our sites, 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.

When communicating with us electronically, including by email, telephone or video call, this communication may be monitored and/or recorded. This is for the purposes of maintaining service quality standards, detection of and/or prevention of crime and to ensure that we comply with legal obligations and our own policies and procedures.

We may provide hyperlinks from our sites ('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.

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, and other developments. 

You can check our website periodically to view the most up to date notice.

This notice was last updated on 16 June 2026.