Privacy Policy
Privacy Policy
Privacy Notice
As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide.
This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.
“We”, “Us” “Our” refers to the Partner named on this website.
Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St. James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy
Table of Contents About us
1. Our processing of your personal information Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons. 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). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you. We also use details of any unspent criminal convictions 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 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 refer to the section that best describes your relationship with us.
2. Prospective clients
This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system.
What personal information may we collect?
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid reason as set out above and we will only disclose it to the following parties:
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to:
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 7.
10. Your rights
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 7 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:
As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide.
This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.
“We”, “Us” “Our” refers to the Partner named on this website.
Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St. James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy
Table of Contents About us
- Our processing of your personal information
- Prospective Client
- Existing Clients
- Clients’ Family Members, Business Associates or Beneficiaries
- Other Business Partners
- Users of our Website
- What marketing activities do we carry out?
- How long do we keep your personal information for?
- What is our approach to sending information overseas?
- Your rights
- Cookies
- Contacting us
- Updates to this Notice
1. Our processing of your personal information Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons. 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). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you. We also use details of any unspent criminal convictions 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 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 refer to the section that best describes your relationship with us.
2. Prospective clients
This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system.
What personal information may we collect?
- 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.
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- Employment information such as job title, employment history and professional accreditations.
- Financial information:
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- 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 we provide such as:
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- 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 such as IP address and browsing history obtained through our use of cookies.
- Information obtained during telephone recordings.
- Information we may have gather from publicly available sources such as the electoral roll, internet search engines and social media sites such as LinkedIn where you have been flagged as a PEP and we need to carry out enhanced due diligence.
- 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 or income protection need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client) or where you have disclosed such information to us because it explains your risk appetite for investments.
- In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.
- you enquire about or apply to receive our wealth management services; and
- you contact us by email, telephone and through other written and verbal communications.
- We will also collect your personal information from:
- Publically available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
- St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found at www.sjp.co.uk/site-services/privacy
- We need to use your personal information to enter into the client agreement, for example, we need to use your personal information to assess whether we can provide services to you and to set you up as a client on the St. James’s Place client relationship management system.
- 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 and we are required to report to St. James’s Place on our relationship 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 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.
- 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.
- There is a substantial public interest such as prevention and detection of fraud.
- 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.
- 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 |
To verify your information. |
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To comply with our legal or regulatory obligations. |
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To set you up as a client on client relationship management systems and to communicate with you in respect of your application and service preferences. |
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For business purposes and activities including maintaining business records, file keeping and strategic business planning. |
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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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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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- Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.
- St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found at www.sjp.co.uk/site-services/privacy.
- Third parties who provide sanctions checking services including Experian.
- Compliance consultants including the Consulting Consortium.
- Financial crime and fraud detection agencies.
- Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
- Selected third parties in connection with any sale, transfer or disposal of our business.
- Our insurers.
- The police, HMRC and other crime prevention and detection agencies.
- Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
- 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.
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- Employment information such as job title, employment history and professional accreditations.
- Financial information:
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- 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 relevant to the services we provide, such as:
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- 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
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- Information contained in client review meeting records and file notes
- Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
- Information about your family including information about your dependants.
- Information obtained during telephone recordings where applicable.
- 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 7 below.
- Your marketing preferences and details of your customer experience with us.
- Information which we have gathered from publicly available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and we need to carry out enhanced due diligence.
- 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 or where we are applying for income protection insurance we will need to ask you about any medical conditions and information about lifestyle choices such as whether you drink alcohol or smoke so that appropriate insurance can be obtained) or where you have disclosed such information to us because it explains your risk appetite for investments.
- In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.
- you register to receive our services and complete and return to us all applicable application forms; and
- you contact us by email, telephone and through other written and verbal communications.
- Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
- Any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
- 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.
- We need to use your personal information to enter into or perform the client agreement that we hold with you. For example, we need to use your personal information to provide our services, to arrange and implement recommendations, review your ongoing suitability of current arrangements and handle claims.
- 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 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.
- 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 relevant health information.
- There is a substantial public interest such as prevention and detection of fraud.
- 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.
Purpose for processing | Lawful Basis for using your personal information | Lawful Basis for using your special categories of personal information |
To carry out identification checks and checks against sanction lists and politically exposed persons (PEP) screening |
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To verify your information throughout the course of our services. |
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To set you up as a client on the St. James’s Place client relationship management system and to communicate with you in respect of your service preferences. |
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To provide services in accordance with your client agreement. |
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To arrange and implement any of our recommendations e.g. investing into certain funds or arranging a product or insurance policy for you. |
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To carry out annual reviews and reviews of ongoing suitability of your current arrangements |
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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 and strategic business planning. |
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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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- Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.
- Third parties who provide a service in relation to the management of your investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where you are buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.
- St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy
- Third parties who provide sanctions checking services including Experian.
- Compliance consultants.
- Financial crime and fraud detection agencies.
- Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
- Selected third parties in connection with any sale, transfer or disposal of our business.
- Our insurers.
- The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
- General information such as your name, address, phone numbers and email addresses, date of birth and gender.
- Your relationship to our client.
- Financial information relating to your financial liabilities, such as a property portfolio which is owned jointly between you and our client.
- Any information which is relevant to the services we provide for our client.
- We may collect details about your physical and mental health which are relevant to your the services we provide for our client (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).
- Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom your family member or business associate was previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
- 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 wills or trust documents where you are listed as a dependant or employment related documents and you are listed as a business partner of our client.
- From any records held by previous independent financial advisers (otherwise known as IFAs) with whom your family member or business associate was previously a client and from any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
- St. James’s Place group companies.
- 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 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.
- 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, partner or business associate who is our client.
- There is a substantial public interest such as prevention and detection of fraud.
- 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.
Purpose for processing | Lawful Basis for using your personal information | Lawful Basis for using your special categories of personal information |
To provide services 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 and strategic business planning. |
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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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- Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.
- Third parties who provide a service in relation to the management of our client’s investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where our client is buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.
- St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy
- Compliance consultants including the Consulting Consortium
- Financial crime and fraud detection agencies.
- Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
- Selected third parties in connection with any sale, transfer or disposal of our business.
- Our insurers.
- The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax adviser.
- 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, your employees 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 St. James’s Place group companies.
- Directly from you
- St. James’s Place group companies.
- Publicly available sources such as internet search engines.
- From service providers who carry out sanctions checks.
- 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 including reviewing the performance of our business partners.
Purpose for processing | Lawful Basis for using your personal information | Lawful Basis for using your special categories of personal information |
To carry out fraud, credit and anti-money laundering checks on you |
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Not applicable |
To carry out due diligence on you. |
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Not applicable |
To comply with our legal or regulatory obligations. |
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Not applicable |
For business purposes and activities including maintaining business records, file keeping and strategic business planning. |
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Not applicable |
For compliance and monitoring purposes. |
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Not applicable |
- St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found https://www.sjp.co.uk/site-services/privacy.
- Your agents or employees as appropriate.
- Third parties who provide sanctions checking services including Experian.
- Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
- Selected third parties in connection with any sale, transfer or disposal of our business.
- Our insurers.
- Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
- General information submitted via the website, for example where you provide your details in the contact section such as your name, contact details and company name.
- 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 7 below.
- We have a valid business reason to use your personal information, necessary for our everyday business operations and activities, for example to maintain business records and to monitor usage of the website.
Purpose for processing | Lawful Basis for using your personal information | Lawful Basis for using your special categories of personal information |
To respond to any enquiries you have submitted. |
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Not applicable |
- St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy
- Third parties who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as IT suppliers and website providers.
- What marketing activities do we carry out?
- 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;
- transferring personal information only to companies in the United States who are certified under the “Privacy Shield”. The Privacy Shield is a scheme whereby companies certify that they provide an adequate level of data protection. You can find out more about the Privacy Shield https://www.privacyshield.gov/welcome or
- 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://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en
Country of transfer | Reason for the transfer | Method we use to protect your information |
Hong Kong, Singapore, Shanghai | Provision of data to international offices to support clients living overseas. | We have standard contractual clauses in place |
- 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.