SJP Privacy policy
St. James's Place plc is committed to protecting the privacy of all individuals it interacts, this includes, but not limited to, clients, prospects and employees. We therefore ask that you please read this fair processing notice carefully, employees and Partners should refer to the privacy policy on the St. James's Place intranet.
This fair processing notice covers St. James's Place Plc, and all of its subsidiaries (together, "SJP" or the "Group") on how they collect, processes and use your personal information whether that is face to face, online or via a St. James's Place or Partner Practice Website(s). In all instances where your personal data is processed including where you visit our websites or use our mobile and/or tablet apps (collectively referred to as "our sites") you acknowledge that the practices described in this notice apply.
Please click below for more information about the services we provide through the St. James's Place Partnership. This section will be relevant to you where you interact with a St. James's Place Partner.
St. James’s Place Wealth Management
St. James’s Place Wealth Management specialises in delivering face-to-face wealth management advice, products and services to individuals, trustees and businesses.
St. James’s Place Partnership
Our wealth management services are provided through personal, face to face advisors, delivered by our St. James’s Place Partners. St. James’s Place Wealth Management acts as principal in its relationship with the St. James’s Place Partners, which means that we provide the products, services and regulatory and compliance framework in which our Partners operate.
Where you have a St. James’s Place Partner, your Partner will provide your services and will process your personal information in accordance with its own Privacy Policy which is available on their Website
St. James’s Place Wealth Management will collect personal information about you as part of its role as principal, in order to ensure that the St. James’s Place Partners are compliant with applicable financial regulations. We do this by providing shared services product and servicing activity, conducting audits and dealing with any complaints that you may have. As principal, St. James's Place Wealth Management also has access to all personal information that St. James's Place Partners collect and use; this means that St. James's Place Wealth Management is the joint controller of your personal information along with your Partner.
For the purposes of this section and section 2, "we" and "our" shall refer to St. James's Place Wealth Management and "Partner" shall refer to your St. James's Place Partner.
We will collect and use different personal information about you for different reasons, depending on our relationship with you.
Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership) in order to provide comprehensive advice and deliver health related products to you.
In our role as principal and on behalf of Partners, we may also use details of any unspent criminal convictions for fraud prevention purposes to help Partners during the process of investing money.
Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and we are responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.
In order to make this notice as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us and the service you receive from us.
This section will apply if you receive wealth management services, or you are looking to receive wealth management services from a Partner.
- Information collected from any communications with you; and
- Information obtained through audits or processed in the process of ensuring our Partners comply with their regulatory obligations.
- Information stored on our client relationship management systems which Partners have access to and store information onto.
- Information collected when dealing with any complaints you may have
This will include the following personal information:
- General information such as your name, address, phone numbers and email addresses, date of birth and gender.
- 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, bank statements and evidence of benefit entitlement.
- Employment information such as job title, employment history and professional accreditations.
- Financial information:
- Bank details
- Financial reviews (fact finds)
- Information relating to your personal finances such as your financial liabilities and assets, income and outgoings
- Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders.
- Information relevant to the services that your Partner provides to you, including:
- previous and current investments
- information about your lifestyle
- attitude to investment risk
- existing plan details
- objectives
- copies of your will
- information about any trusts you have.
- Information about your family including information about your dependants.
- Information obtained during telephone recordings.
- Information which we have gathered from publically available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and our Partners are required to carry out enhanced due diligence.
- Details about any criminal convictions and any related information which have been obtained from our Partners' sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
- Details about your health which are relevant to the service you are receiving, for example where you have disclosed such information to our Partners or to us because it explains your risk appetite for investments.
- In limited circumstances and where relevant to the advice being provided by our Partner, we may also collect information which relates to your trade union membership, ethnicity or political opinions where you have disclosed it to our Partner.
We will collect information directly from you when:
- you contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
- Your Partner directly
- The St. James's Place Wealth Management client relationship management system and hosted platforms;
- Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
- Other St. James’s Place group companies where appropriate, including any of the following independent financial advisers (IFAs) (where you were previously a client) that have been acquired by the St. James’s Place Group:
- BFS Financial Services Ltd
- Hale Financial Solutions Ltd
- Linden House Financial Services Ltd
- PFP Time Ltd
- SJP Client Solutions Ltd
- LP Holdco Ltd
- Where an IFA has been acquired by the St. James’s Place Group, your financial advice will be provided by your Partner and your personal information that is held by those IFAs will be governed by their individual privacy notices which will have been made available to you.
There are a number of reasons we use your personal information and for each use we need to have a "lawful basis" to do so.
We will rely on the following “lawful basis” when we process your "personal information":
- We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
- We have a valid business reason to use your personal information and which is necessary for our everyday business operations and activities, for example to respond to any queries relating to our Partner services that we receive.
- In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information", we must have an additional “lawful basis" and we will rely on the following lawful basis in these circumstances:
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
- You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to review a complaint in respect of the Partner service you have received unless we have all the information we need, which could include your health information for example.
- We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION |
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| To comply with our legal or regulatory obligations, including ensuring that our Partners are compliant with the appropriate regulatory requirements. |
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| For communications purposes including handling complaints and dealing with any other communications. |
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| For business purposes and activities including managing the St. James's Place CRM system and hosting platform, and ensuring the continued improvement of the St. James's Place Partnership service. |
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| To assist in the transition of your services from your Partner to another Partner if your Partner leaves the St. James's Place Partnership. |
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This section will apply where a client receiving partner services provides information about their family member(s) or business associates to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse, partner or dependant mentioned in a will or trust document, another beneficiary or a business partner). This section will set out how we use your information.
- Information collected from the client;
- Information collected when dealing with any complaints you may have;
- Information collected from any communications with you; and
- Information obtained through audits or in the process of ensuring our Partners comply with their regulatory obligations.
This will include:
- General information such as your name, address, phone numbers and email addresses, date of birth and gender.
- Your relationship to our client who is receiving St. James's Place Partner services.
- Financial information relating to your financial liabilities, for example details of you and your partner's property portfolio to enable us to establish that a client has provided with appropriate financial advice.
- We may collect details about your health which are relevant to the services our client receives from the relevant Partner (for example where you are the client's partner and you have a medical condition which means that you are unable to work and therefore our client has a higher need for investment return and a lower risk appetite).
- In limited circumstances where relevant to the advice being provided by our Partner, we may also collect information which relates to your trade union membership, ethnicity or political opinions where it has been disclosed to the Partner by the client.
We will collect information directly from you when:
- you contact us by email, telephone and through other written and verbal communications, for example in relation to a data subject access request.
We may also collect your personal information from:
- our client who is receiving Partner services.
- our client's Partner;
- the St. James's Place Wealth Management client relationship management system and hosted platforms.
There are a number of reasons we use your personal information and for each use we need to have a "lawful basis" to do so.
We will rely on the following “lawful basis” when we process your "personal information":
- We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
- We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain our business records.
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information", we must have an additional “lawful basis" and we will rely on the following lawful basis in these circumstances:
- You have given your explicit consent to our use of your special categories of personal information which may have been provided to us by your family member, spouse or business associate who is our client.
- We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION |
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| To comply with our legal or regulatory obligations, including ensuring that our Partners are compliant with the appropriate regulatory requirements. |
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| For communications purposes including handling complaints and dealing with any other communications. |
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| For business purposes and activities including managing the St. James's Place CRM system and hosting platform, and ensuring the continued improvement of the St. James's Place Partnership service. |
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| To assist in the transition of our client's services from our client's Partner to another Partner if our client's Partner leaves the St. James's Place Partnership. |
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St. James's Place is committed to protecting the privacy of its job applicants.
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" as part of its recruitment processes. You should read this Notice carefully and raise any questions you may have with the Data Protection Officer.
This Notice is issued on behalf of St. James's Place Plc and its associated companies. In connection with your potential employment, the relevant data controller will be your prospective employer within the St. James's Place group of companies. A full list of these companies appears at annex 1 to this Notice. St. James's Place has appointed a dedicated Data Protection Officer to deal with any queries in relation to data processing and the relevant contact details are provided below.
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.
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 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 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
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 months of their rejection.
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.
Please see below for more information about the products we offer which include pensions and annuities.
St. James’s Place Products
St. James’s Place Wealth Management specialises in delivering face-to-face wealth management advice to individuals, trustees and businesses. As well as addressing simple and straightforward issues such as mortgages, we can help to resolve more complex problems for clients, whether it be investment for growth, Inheritance Tax or retirement planning. We also offer St. James’s Place Wealth Management products, which include pensions, annuities.
The data controller will depend on the product you take out with us and will be an entity within the St. James’s Place plc’s group of companies. If you are unsure about who the data controller of your personal information is, you can contact us at any time using the contact details in section 10 below.
For the purposes of this section and section 4, "we" and "our" shall refer to the relevant data controller as above according to the product that you have and "product" shall refer to the relevant product you hold.
Your home may be repossessed if you do not keep up repayments on your mortgage.
The value of an investment with St. James’s Place will be directly linked to the performance of the funds you select and the value can therefore go down as well as up. You may get back less than you invested.
We will collect and use different personal information about you for different reasons, depending on our relationship with you and the product held.
Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership).
We also use details of any unspent criminal convictions provided for fraud prevention purposes.
Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and we are responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.
In order to make this notice as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us and the service you receive from us.
This section will apply if you are an existing client of ours and you have purchased a St. James’s Place pension or an annuity product from us.
- General information such as your name, address, phone numbers and email addresses, date of birth and gender.
- 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.
- Employment information such as job title, employment history and professional accreditations.
- Financial information relevant to the products we provide, including:
- Bank details
- Financial reviews (fact finds)
- Information relating to your personal finances such as your financial liabilities and assets, income and outgoings.
- Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders or where you have been flagged as a PEP.
- Information about your family including information about your dependants.
- Information obtained during telephone recordings where recorded.
- Your marketing preferences and details of your customer experience with us.
- Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 11 below.
As part of our regulatory requirements, details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to. We may collect details about your health which are relevant to your application (e.g. as part of a pension need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client). In limited circumstances, we may also collect information which relates to your trade union membership (for example when gathering your employment details), genetic or biometric data or data concerning your sex life or sexual orientation where you instruct us on joint products.
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We will collect information directly from you when:
- you apply to purchase, vary or renew a St. James's Place product; and
- you contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
- Your St. James's Place Partner where applicable.
- The St. James's Place Wealth Management client relationship management system and hosted platforms.
- Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
- Other St. James's Place group companies.
- Third parties such as Experian who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services.
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There are a number of reasons we use your personal information and for each use we need to have a "lawful basis" to do so.
We will rely on the following “lawful basis” when we process your "personal information":
- We need to use your personal information to enter into or perform the client agreement that we hold with you for the product in question. For example, we need to use your personal information to provide the products that you have purchased from us.
- We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
- We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain business records, to review our business models, to undertake strategic and operational business analysis of the products we offer, to maintain management information, and for internal audit purposes.
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information", we must have an additional “lawful basis" and we will rely on the following lawful basis in these circumstances:
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
- We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
- You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you certain advice or financial products unless we have your health information.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION |
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| To carry out identification checks. |
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| To provide services in accordance with your product agreement |
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| To carry out annual reviews and reviews of ongoing suitability of your current arrangements as required. |
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| To prevent and investigate fraud. |
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| To comply with our legal or regulatory obligations. |
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| To communicate with you and resolve any complaints that you might have. |
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| To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys). |
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| For business purposes and activities including maintaining business records, file keeping, strategic business planning and internal audit, and management information. |
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To apply for and claim on our own insurance. |
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| To provide marketing information where you have provided your consent |
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| To provide marketing information by post, by telephone and in other circumstances where we don't require your consent. |
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General information such as your name, address, phone numbers and email addresses, date of birth and gender.
- 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.
- Employment information such as job title, employment history and professional accreditations.
- Financial information relevant to the products we provide, including:
- Bank details
- Financial reviews (fact finds)
- Information relating to your personal finances such as your financial liabilities and assets, income and outgoings.
- Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders or where you have been flagged as a PEP.
- Information about your family including information about your dependants.
- Information obtained during telephone recordings.
- Your marketing preferences and details of your customer experience with us.
- Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 11 below.
We may collect details about your health which are relevant to your application (e.g. as part of a pension need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client). In limited circumstances, we may also collect information which relates to your trade union membership (for example when gathering your employment details), genetic or biometric data (or data concerning your sex life or sexual orientation where you instruct us on joint products.)
We will collect information directly from you when:
- you enquire about a St. James's Place product or apply to purchase a St. James's Place product; and
- you contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
- your St. James’s Place Partner
- other St. James's Place group companies.
- third parties such as Experian who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services.
There are a number of reasons we use your personal information and for each use we need to have a "lawful basis" to do so.
We will rely on the following “lawful basis” when we process your "personal information":
- We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain business records, to review our business models, to undertake strategic and operational business analysis of the products we offer, to maintain management information, and for internal audit purposes.
- We need to use your personal information to enter into the product agreement with you for the product in question. For example, we need to use your personal information to set up the products that you are looking to purchase from us.
- We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information", we must have an additional “lawful basis" and we will rely on the following lawful basis in these circumstances:
- There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
- It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks
- We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
- You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you a quote for one of our products unless we have your health information.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION |
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| To carry out identification checks |
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| To answer any queries you may have and to provide you with a quote for the product in question. |
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| To arrange a product for you. |
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| To prevent and investigate fraud. |
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| To comply with our legal or regulatory obligations. |
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| To communicate with you and resolve any complaints that you might have. |
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| To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys). |
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| For business purposes and activities including maintaining business records, file keeping, strategic business planning and internal audit, and management information. |
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| To apply for and claim on our own insurance. |
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| To provide marketing information where you have provided your consent |
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| To provide marketing information by post, by telephone and in other circumstances where we don't require your consent |
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This section will apply if your personal information has been provided to us as part of a quote or an application for a St. James's Place Wealth Management product, for example if you are listed as a beneficiary in an application for an annuity product. This section will set out how we use your information.
If you are a business partner such as products providers, portfolio or fund managers and contractors who carry out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.
If you use our website, this section will be relevant to you and sets out our uses of your personal information.
Where you are an existing client
We may use your personal information to provide you with information about our products or services which may be of interest including e-briefings and newsletters, where you have provided your consent for us to do so.
If you wish to opt out of marketing, you may do so by clicking on the "unsubscribe" link that appears in all emails which are sent by your Partner or telling us when we call you. Otherwise you can always contact us using the details set out in section 10 to update your contact preferences.
Please note that, even if you opt out of receiving marketing messages, you may still receive communications from your Partner in connection with the products we offer you.
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 retain personal information collected during the recruitment process for a period of 12 months from the point at which you last logged onto the website 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 12 months then anonymised.
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 European data protection authorities otherwise known as the "standard contractual clauses" You can find out more about standard contractual clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en;
- we will only transfer personal information to companies in non-EEA countries who have been deemed by European data protection authorities to have adequate levels of data protection for the protection of personal information. You can find out more about this https://ico.org.uk
We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you.
Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. An example of our regular data transfers outside the EEA is set out below:
| Country of transfer | Reason for the transfer | Method we use to protect your information |
|---|---|---|
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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 do not currently use automated decision making as all decisions are reviewed by an individual.
What is profiling?
Profiling is any form of automated processing of personal information which evaluates certain personal aspects and we use profiling tools to assist in risk assessment and marketing activities.
We will use profiling in a number of circumstances including the following:
- where you are a prospective client we will use your postcode to determine which Partner is closest to you;
- for existing clients – where there are any investment fund switches, we will use systems to monitor irregular activity; and
- using a financial strategy segment profiling tool which uses information such as date of birth, occupation and financial information to determine appropriate investment wealth bands.
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:
We will of course inform you if any of the above situations arise and if we are unable to comply with your request.
- 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 and would have to cancel your client agreement, for example we could not enter into investments on your behalf if we had deleted your personal information.
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 878453.
You can also contact your Partner at the contact details set out in their Privacy Policy (as provided to you on their headed paper) if you would like any further information about how they collect, store or use your personal information.
At St. James’s Place, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of 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 the rights and freedoms of our clients, Partners or employees, we will inform them 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
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.
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 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, other developments or new products and services being offered.
We will provide you with the most up-to-date notice and you can check our website periodically to view it or you can request a copy from your St. James’s Place Partner.
This notice was last updated on 19/05/2022.
