Privacy statement
Schroders Personal Wealth is a joint venture between Lloyds Banking Group plc and Schroders plc.
This Privacy Policy is designed to help you understand what information we gather and process about you ("personal data"), why and how we use it, and with whom we share it. It also sets out the rights you have in relation to your information and how you may contact us for your queries.
DEFINITIONS USED IN THIS PRIVACY NOTICE CAN BE FOUND HERE
“Client” means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Schroders Personal Wealth. “Schroders Personal Wealth”, “we” or “us” means Scottish Widows Schroder Personal Wealth Limited and Scottish Widows Schroder Personal Wealth (ACD) Limited with its registered office at 25 Gresham Street, London, EC2V 7HN United Kingdom. ICO registration under ZA514039 and ZA544184
“Schroders Personal Wealth Websites” means the websites operated by Schroders Personal Wealth.
“Schroders Personal Wealth Products and Services” means the products and services that we offer to our Clients, including through our related support, mobile or cloud-based services.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Schroders Personal Wealth (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.
“You” means each individual to whom this notice is addressed, who may be:
(a) a Client or prospective Client of ours;
(b) a visitor to the Schroders Personal Wealth website; or
(c) an employee, director, officer or representative of another organisation with which we have a business relationship.
1. BACKGROUND
(1.1) Schroders Personal Wealth collects and uses certain Personal Data. Schroders Personal Wealth is responsible for ensuring that it uses that Personal Data in compliance with data protection laws
(1.2) At Schroders Personal Wealth, we respect Your privacy and we are committed to keeping your Personal Data secure.
(1.3) This Privacy Notice is directed to individuals whose Personal Data we handle in the course of carrying on our commercial activities. Those individuals could be Clients or prospective Clients or their representatives, agents or appointees, or an employee, director, officer or representative of another organisation with which we have a business relationship. This Privacy Notice is also directed to visitors to our websites.
(1.4) Please note that in addition to this Privacy Policy, the Personal Data we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your Personal Data will be used by us and these fraud prevention agencies, and your data protection rights, can be found at the following link Fair Processing Notices for Cifas (‘National Fraud Database’).
2. OUR PRIVACY PROMISE
(2.1) To keep your Personal Data safe and private.
(2.2) Not to sell your Personal Data.
(2.3) To give you ways to manage and review your marketing choices at any time.
3. OVERVIEW OF CIRCUMSTANCES IN WHICH WE HANDLE YOUR PERSONAL DATA
(3.1) Schroders Personal Wealth gathers information about you in the following ways:
(a) Information we receive in the course of providing products or services to you. This may be provided directly from you or from third parties, such as providers of ‘know your Client’ and anti-money laundering services which we use to help us meet our legal obligations.
(b) Information we receive as part of your interest in our products or services. This is only provided by you and includes enquiries and other activities you perform while visiting our premises, participating in informative events and using Schroders Personal Wealth Websites. Details of how we handle the information we receive through our Websites are set out in paragraph 11 of this Privacy Notice.
We may combine the personal and other data we collect directly from you with information collected from or about you in other contexts, such as from our Web Sites or obtained from third parties.
4. THE TYPES OF PERSONAL DATA WE COLLECT
(4.1) The nature of our relationship with you will determine the kind of Personal Data we may process. These types of Personal Data we process may include:
Identification data: first name; family name; age; gender; nationality; citizenship; place of birth; national insurance number; ID or passport number, occupation and job title; ID documentation (including your photograph); date of birth; civil status; life events and family information; signature.
Contact data: email address; phone; address.
Technical data: Personal Data related to your use of the Schroders Websites through our use of cookies. This includes information that may identify you, particularly when you interact with our website in ways that involve providing your details (see further section 11 below).
Financial data: account number; client reference number; fees quotation and proposal; bills and invoices; billing amount; taxpayer identifying/identification number(s); country(ies) of tax residency; tax status and tax certificates.
Contractual data: files that we may produce as a record of our relationship with our clients and prospective Clients, including contact history; information concerning the fulfilment of contractual obligations and pre-contractual measures (including for investors any invested amount and any information regarding the dealing in shares (subscription, conversion, redemption and transfer as well as balance or value at year-end and total gross amount paid or credited in relation to the shares, including redemption proceeds)).
AML/KYC data: source of wealth and funds, fraud related search results, power of attorney, information on related parties.
Sensitive data: health related information; disability status; personal data revealing racial or ethnic origin or religious or philosophical beliefs; details of political opinions or affiliations; or records of criminal offences and court proceedings.
Communication data: any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, manage or improve our service and in order to comply with our legal and regulatory requirements.
You may, at your discretion, refuse to communicate the Personal Data to Schroders Personal Wealth. In this case, however, Schroders Personal Wealth may not be able to enter into a contractual or other business relationship with you, if such Personal Data is necessary for the relevant purposes.
Moreover, you should refrain from providing us with Personal Data which are not requested by Schroders Personal Wealth. Unless provided otherwise by applicable law, Schroders Personal Wealth shall not be liable for any damage caused by the processing of such Personal Data provided by you without being requested by Schroders Personal wealth. Information provided to us by professional advisers, product providers, events organisers, other agents and/or representatives, industry databases and other business intelligence tools Schroders Personal Wealth subscribes to.
(4.2) The Personal Data listed above is collected from the following sources:
Information that you or third parties representing you provide to Schroders Personal Wealth. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of Personal Data we might ask for. Such information may include identification data, contact data, financial data, and sensitive data.
We also process personal data about any person on whose behalf you are acting, for example investment beneficiaries, that you may have provided to us in connection with our provision of services to you. By providing us with their personal data, you agree to provide them with the information set out in this Privacy Policy.
Information that we collect or generate about you. This may include contractual data, communication data and technical data.
Information we obtain from other sources. Some of this Personal Data may be sensitive and may include:
Information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies (including CIFAS (Fair Processing Notices for Cifas); law enforcement agencies/authorities; public databases, registers and records such as the UK’s Companies House and the FCA Register and other publicly accessible sources
5. HOW WE USE YOUR INFORMATION
(5.1) The Data Protection Laws allow or require us to use your Personal Data for a variety of reasons. These include the following instances where the processing of Personal Data is necessary for:
performing our contractual obligations;
discharging legal and regulatory obligations;
establishing, exercising or defending our legal rights;
purposes for which we have obtained your consent; and/or
our legitimate business interests which are not overridden by the interests or fundamental rights and freedoms of data subjects, including you.
Where the Schroders Personal Wealth act as controller and the purposes change over time or where we want to use Personal Data for new purposes, we will inform you of such new processing in accordance with the Data Protection Laws.
For the avoidance of doubt, where consent is given by you, this consent is separate from any consent given in the context of confidentiality and/or professional secrecy compliance obligations.
(5.2) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
1. to execute the contract between you and Schroders Personal Wealth
2. the legitimate interest of Schroders Personal Wealth acting as controller
3. to comply with the legal obligations imposed on the Schroders entity acting as controller
(5.3) We may use systems to make profiling and automated decisions about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. Profiling and automated decisions can affect the products, services or features we may offer you now or in the future. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from outside organisations we work with. We study this to form a view on what we think you may do, want, or need. We use this information to place you in groups with similar Clients. These are called Client segments. We use these to study and learn about our Client’s needs, and to make decisions based on what we learn. This is called profiling. It helps us to design products, services and offers for different Client segments, and to manage our relationships with you.
(5.4) We may use Artificial Intelligence to process your personal information, we will do this on the basis of legitimate interest using trusted providers.
(5.5) Within Schroders Personal Wealth, your Personal Data is accessed only by employees of Schroders Personal Wealth that have a need to access it for the purposes described in this Privacy Policy
6. WHO WE SHARE YOUR PERSONAL DATA WITH
(6.1) Your Personal Data may be shared with Lloyds Banking Group plc and Schroders plc, and entities within their respective corporate groups.
(6.2) We may also share your Personal Data outside of the Schroders Personal Wealth as further described below:
with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
with representatives, agents, custodians, intermediaries and/or other third-party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);
with law enforcement and fraud prevention agencies as well as other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
with third party agents and contractors for the purposes of them providing services both to us (for example, Schroders’ Personal Wealth accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) and to Clients or prospective Clients. These third parties will be subject to appropriate data protection obligations and due diligence;
with any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;
to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with court order, tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights; and
if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.
The above recipients of Personal Data (“Recipients”) may disclose the Personal Data to their agents and/or delegates (the “Sub-Recipients”), which shall process the Personal Data for the purposes of assisting the Recipients in providing their services to the Schroders Personal Wealth acting as controller and/or assisting the Recipients in fulfilling their own legal obligations. The Recipients and Sub-Recipients may process the Personal Data as processors (when processing the Personal Data upon instructions of the controller and/or the Recipients), or as distinct controllers (when processing the Personal Data for their own purposes, namely fulfilling their own legal obligations).
7. INTERNATIONAL TRANSFERS OF PERSONAL DATA
(7.1) Where we transfer your Personal Data to another country, we ensure that it will be protected and transferred in a manner consistent with legal requirements. In relation to data transferred outside of the UK and European Economic Area (the “EEA”), Switzerland, the UK, and your jurisdiction, we may do so in one of the following ways:
the country to which we send your Personal Data is approved by the European Commission, the UK as offering an adequate level of protection for Personal Data, including if the recipient is established in the United States and participates in the EU-US Data Privacy Framework and its UK extension, or other multilateral or bilateral arrangement where your country is a party to such arrangement (as relevant); or
the recipient signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your Personal Data;
in some limited circumstances the law may permit us to otherwise transfer your Personal Data outside of the UK and the EEA.
(7.2) You can obtain more details of the protection given to your Personal Data when it is transferred outside UK and the EEA and the UK, by contacting us as described in paragraph 13 below.
8. HOW WE SAFEGUARD YOUR PESONAL DATA
(8.1) Personal Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value.
We ensure safe processing operations by operating and maintaining physical, electronic and procedural safeguards to guard your non-public Personal data and we restrict access only to authorised personnel. The effectiveness of these safeguards is periodically tested.
We have extensive controls and mechanisms in place designed to detect, respond and recover in case of adverse events that may arise.
9. HOW LONG WE KEEP YOUR PERSONAL DATA
(9.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:
the purpose for which we are using it (as further described in this Privacy Notice at paragraph 5.1) – we will need to keep the data for as long as is necessary for that purpose; and
our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data. For example, we will retain Personal Data for required statutory retention periods where these apply, or we will retain Personal Data for the duration of the contract we have with you (if applicable) and thereafter for a period relating to the duration within which contractual claims are able to be raised (e.g. 7 years within the UK).
(9.2) If you would like to know in detail how long we hold specific Personal Data for, please contact us in accordance with paragraph 13 below.
(9.3) Once we no longer require your Personal Data for the purposes for which it was collected, we will securely destroy the Personal Data in accordance with applicable laws and regulations.
10. YOUR RIGHTS
(10.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights. You can exercise your rights free of charge in most cases. These rights include:
the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;
in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Schroders Personal Wealth;
the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data, but we are required or entitled to retain it;
the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
(10.2) You can exercise your rights by contacting using the details provided at paragraph 13 below.
11. SCHRODERS PERSONAL WEALTH WEBSITE
(11.1) If you use a Schroders Personal Wealth Website, we may collect technical information through the use of cookies. The type of information collected varies by category of cookies as explained in our Cookie Notice. As detailed in our Cookie Notice, we provide you with the opportunity to selectively accept certain categories of cookies in your Web browser through our Cookie Manager Application. If you accept cookies of the tracking category and you make your identity known during a secure (logged-on) browsing session on one of our Web Sites, we will be able to combine the information we collect about your usage of our Web Sites during that session with other information we know about you, such as any searches you conduct on our Web Sites or information you request during your web session. We will use this combined information to assess the appeal and usefulness of the information and tools offered on our Web Sites as well as to identify Schroders Personal Wealth products and services that may be of interest to you. We also gather anonymous information related to browsing habits of users through other categories of cookies with the purpose of managing and improving our Website.
(11.2) If you use a Schroders Personal Wealth Website and follow a link from it to another website, different privacy policies may apply. Prior to submitting any Personal Data to a website, you should read the privacy policy applicable to that website
12. CHANGES TO THIS PRIVACY NOTICE
(12.1) Any changes we make to our Privacy Notice in the future will be posted on this website and where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Notice.
13. QUESTIONS AND CONCERNS
(13.1) If you have any questions or concerns about Schroders’ Personal Wealth handling of your Personal Data, or about this Privacy Notice, or to exercise any of your rights, please contact us at DataPrivacy@spw.com or by post at:
Schroders Personal Wealth Privacy Team
1 City Square
LEEDS
LS1 2ES
To exercise your right to withdraw consent to receive electronic marketing communications at any time, please follow “unsubscribe” instructions found in such marketing materials.
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns directly to your local courts or Data Protection Supervisory Authority competent for your jurisdiction.
If you raise a concern, we may:
request additional details from you regarding your concerns and personal data limited to what is necessary for the purpose of authenticating you;
engage or consult with other parties in order to investigate and resolve your issue (and these parties will receive and process information about you); and/or
keep records of your request and any resolution of your issue,
in each case in accordance with our data protection and other legal obligations.
Reviewed: December 2024