SJP SJPI Privacy policy
St. James’s Place International plc (“SJPI”) is an Irish registered life insurance company authorised by the Central Bank of Ireland. SJPI manufactures gross roll-up investment products including the International Investment Bond and Fund Administration Bond. SJPI is contracted with the St. James’s Place ("SJP") Partnership to distribute its products through SJP controlled distributor companies currently established in the UK, Singapore and China.
Depending on the product you take out with us, your data controller will either be SJPI or another entity within the St. James’s Place 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 7 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.
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 receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership).
We may also collect criminal convictions data for fraud prevention purposes.
We also use details of any unspent criminal convictions provided for fraud prevention purposes. However, we will only do so where we have your explicit consent or where such processing is necessary for us to enter into and perform our contract with you.
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 International product from us (e.g. International Investment Bond).
- General information such as your name, address, phone numbers and email addresses, date of birth, gender and marital status.
- Identification information including passport, driving licence, government issued ID verification and address verification documents such as local property tax letters or bank statement and evidence of social welfare payments.
- 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.
- Information obtained during the course of emails, queries and complaints.
- 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.
- Personal data of those individuals who have rights under or in connection with our products such as lives assured, dependents, nominated beneficiaries, trustees, authorised representatives, independent financial advisors, and lawyers.
- Information on Individuals/Controlling Persons of an entity under FATCA/CRS.
As part of our regulatory requirements, details about any relevant criminal convictions / offences 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. 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 apply to purchase, vary or renew a St James's Place International 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 register, court judgments, insolvency registers, internet search engines and social media sites.
- Other St James's Place group companies.
- Third parties such as Experian and Capita 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 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, service and administer 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:
- 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 to your SJP Partner at advice stage.
- We need to use your health information for purposes relating to a policy of insurance or life assurance, or a policy of health insurance or health-related insurance.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION OR INFORMATION RELATING TO CRIMINAL CONVICTIONS AND OFFENCES |
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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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General information such as your name, address, phone numbers and email addresses, date of birth, gender and marital status.
- Identification information including passport, driving licence, government issued ID verification and address verification documents such as local property tax letters or bank statement and evidence of social welfare payments.
- 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.
- Information obtained during the course of emails, queries and complaints.
- Your marketing preferences and details of your customer experience with us.
- Personal data of those individuals who have rights under or in connection with our products such as lives assured, dependents, nominated beneficiaries, authorized representatives ,trustees, independent financial advisors, and lawyers.
- Information on Individuals/Controlling Persons of an entity under FATCA/CRS.
- 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 8 below.
We may collect details about your health which are relevant to your application (e.g. 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 (f or 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), or relevant criminal convictions and offences information.
We will collect information directly from you when:
- you enquire about a St James's Place International product or apply to purchase a St James's Place International 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 and Capita 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 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 for example;
- Where necessary for our everyday business operations and activities, to maintain our business records, to evaluate and enhance our systems and processes.
- Where necessary for the performance of a contract or other legally binding obligation to you, or to take steps at your request prior to entering into a contract or any other binding legal obligation.
- Where we have your consent to process your personal information.
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:
- 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.
- We need to use your health information for purposes relating to a policy of insurance or life assurance, or a policy of health insurance or health-related insurance.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION OR INFORMATION RELATING TO CRIMINAL CONVICTIONS AND OFFENCES |
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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 f or 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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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 International product, for example if you are listed as a beneficiary in an application for one of our products. This section will set out how we use your information.
- General information such as your name, address, phone numbers and email addresses, date of birth, gender and marital status.
- Your relationship to our client.
- Financial information relating to your financial liabilities ,for example details of you and your partner's property portfolio to enable us to establish that the product our client is looking to purchase is appropriate.
- Any information which is relevant to the product we provide for our client.
- We may collect details about your health which are relevant to the product we will be providing to our client.
- In limited circumstances, we may also collect information concerning your sex life or sexual orientation for example where you are in a civil partnership with our client.
Directly from our client.
From documents directly provided to us by our client, such as application forms for products where you are listed as a dependant or employment related documents and you are listed as a business partner of our client.
Our client's SJP Partner directly.
The SJPI and SJP 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 for example;
- Where necessary for our everyday business operations and activities, to maintain our business records, to evaluate and enhance our systems and processes.
- Where necessary for the performance of a contract or other legally binding obligation to you, or to take steps at your request prior to entering into a contract or any other binding legal obligation.
- Where we have your consent to process your personal information.
When we use your “special categories of personal information" or information relating to relevant criminal convictions and offences, 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 or business associate who is our client.
- We need to use your health information for purposes relating to a policy of insurance or life assurance, or a policy of health insurance or health-related insurance.
- We need to adhere to our regulatory requirement to detect and deter fraud and criminal activities.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION OR INFORMATION RELATING TO CRIMINAL CONVICTIONS AND OFFENCES |
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| To provide products to our clients |
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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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| For business purposes and activities including maintaining business records, file keeping, strategic business planning and internal audit, and management information. |
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If you are a business partner such as product provider, portfolio or fund manager and contractor who carries out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.
- General information such as your name, address, business phone numbers and email addresses.
- Employment information such as job title, business cards and professional accreditations.
- Information about your clients and the services and products you offer.
- Your bank details and information obtained from checking sanction lists and credit checks
- Information which we have gathered from publicly available sources such as internet search engines and generally obtained as part of the due diligence process conducted by SJPI and other St James's Place group companies.
Directly from you.
From other St James's Place group companies.
From publicly available sources such as internet search engines.
From service providers who carry out sanctions checks including Experian and Capita.
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 contract that we hold with you.
- We have a legal or regulatory obligation to use such personal information. For example, we may be required to carry out certain background checks.
- We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis. 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.
| PURPOSE FOR PROCESSING | LAWFUL BASIS FOR USING YOUR PERSONAL INFORMATION | LAWFUL BASIS FOR USING YOUR SPECIAL CATEGORIES OF PERSONAL INFORMATION OR INFORMATION RELATING TO CRIMINAL CONVICTIONS AND OFFENCES |
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| To carry out fraud, credit and anti-money laundering checks on you |
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| To carry out due diligence on you. |
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| To comply with our legal or regulatory obligations. |
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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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| For compliance and monitoring purposes such as recording and managing complaints made against you by our clients. |
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We will only keep your personal information f or as long as reasonably necessary to fulfil the purposes set out in sections 2 - 4 above, to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial services firm, we are regulated by the Financial Conduct Authority(the FCA)and the Central Bank of Ireland who imposes certain record-keeping rules which we must adhere to.
All financial institutions operating in Ireland, including SJPI, are required under legislation incorporating into Irish law the US Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standards to report the following information to the Irish Revenue Commissioners f or all non-resident clients. This information may be transferred by Revenue to the authorities of another jurisdiction under an inter-governmental agreement.
Reportable Individual Account Holders – name, address, country of tax residence, Tax Identification Number, date of birth, place of birth, client account number, account balance or value at year end and payments made with respect to the account during the calendar year.
Reportable Entity Account Holders – name, address, country of residence, Tax Identification Number, account number, account balance or value at year end and payments made with respect to the account during the calendar year.
Reportable Controlling Persons of passive Non-Financial Entities (PNFE's) - name, address, country of tax residence , Tax Identification Number and the name, address and country of residence, Tax Identification Number and date of birth of each controlling person, the account number, account balance or value at year end and payments made with respect to the account during the calendar year.
All transfers of personal information to any third party including Revenue will always be completed securely.
Further information on this reporting requirement may be found on Revenue’s website by clicking here.
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 SJP 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 f or the protection of personal information. You can find out more about this https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
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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| HongKong, Singapore, Shanghai | Provision of data to international offices to support clients living overseas. | We have standard contractual clauses in place |
If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 10.
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 client outcomes.
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 SJP 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.
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 client 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 f or certain periods of time; or
- in doing so we could not provide services to you and would have to cancel your client agreement, f or example we could not enter into investments on your behalf if we had deleted your personal information.
We will of course inform you if any of the above situations arise and if we are unable to comply with your request.
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.
Please complete the Data Subject Request Form to request a copy of the information we hold.
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.
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.
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.
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 f actors such as our own regulatory obligation, to assess whether we can comply with your request.
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.
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.
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.
Whilst we use software to carry out automated decision making (as set out in section 8 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.
If you believe that we have breached data protection laws when using your personal information, you have a right to complain to the United Kingdom Information Commissioner's Office (ICO)or the Irish Data Protection Commission (DPC).
You can visit the ICO's website at https://ico.org.uk/ and the DPC's website at https://www.dataprotection.ie for more information. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.
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 the SJP 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], telephone number 01285718453.
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.
We have a dedicated group, the ‘Information Security Oversight Committee’, that provides oversight and guidance to our information security and privacy programme.
The executive body responsible f or privacy and data security is the Information Security Oversight Committee (ISOC) -chaired by the Data Protection Officer. ISOC has a reporting line that enables effective escalation of issues up to the Board where appropriate.
We educate and train our employees, Partners and contractors on their information security, fraud prevention and privacy obligations annually.
Our employees, Partners and contractors take part in an annual Information Security training and awareness program and must agree to adhere to the Data Protection Act and our own Information Security Policy that are designed to keep your information safe. These are refreshed each year to reflect the current trends that are being observed across the information security landscape. Information Security awareness also forms part of our new employee induction program.
We also educate our employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to our Financial Crime Prevention team.
When you login, or send us information on the internet we protect the security of this information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
When you use your web browser to login, view or share information with us, all electronic information exchanged is encrypted using 2048 bit SSL (Secure Sockets Layer) certificate. You can identify this by looking for the HTTPS:// and the padlock in the address bar at the top of your browser:
We will always interact with you in a safe, secure and consistent manner
To keep your information secure and to protect our clients from fraud, St. James’s Place will only interact with you in the following ways. If in doubt, call your St. James’s Place Partner directly or alternatively email the St. James’s Place Data Protection Office at [email protected].
When interacting with you, we will:
Only send funds that you have requested to be withdrawn to a verified bank account in your name.
Verify who you are when speaking to you on the phone, by asking you security questions.
We will not:
Ask you for your password over the phone.
Send you an unsolicited email with a link to our login page asking you to enter your Online Wealth Account credentials.
Ask you for payment or credit card details by email or telephone.
Call you to notify you of a problem, and then request you call us back immediately to discuss the problem further.
We continually review our physical and logical security controls in place across the business.
Physical controls –As well as protecting your digital information, St. James’s Place also protects their premises and physical locations where personal data may be used and stored. These measures include security guards, security entrances, secure disposal of confidential waste and hardware, CCTV, personal card access and locks on doors and file storage cabinets, with a ‘clear desk’ policy to ensure all information is locked away and protected.
Logical controls –St. James’s Place uses technical security measures to make sure our systems where we store and use personal information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business.
All employee emails and devices are encrypted to enable secure transfer and storage of personal information.
We conduct security testing of our applications and services in a controlled testing environment before they are made available for our clients to use on an ongoing basis.
We perform security risk assessments for each of our sites to identify and control risks.
External technical assessments are conducted by an independent external 3rd party.
Security audits and vendor due diligence are conducted on a continual basis.
We have a business resiliency plan with disaster recovery and business continuity testing.
The purpose of Business Continuity Management and the St. James’s Place Business Continuity Plan, is to provide an effective, predefined and documented framework to respond to an incident affecting the Group’s activities. The key drivers in developing the business recovery plans are;
To mitigate the risks that could lead to the significant disruption of our products and services to our clients.
To provide a recovery plan that supports a timely and full restoration of our products and services for our clients.
However, whilst we take appropriate technical and organisational measures to safeguard your Personal Information, please note that we cannot guarantee the security of any data that you transfer over the internet to us.
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 f or 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 online 'contact us' form or complete the registration details. The type of information being collected f or an enquiry will be apparent f rom 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 f rom 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.
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 05/12/2025.