Fair Processing Notice

Shareholders Privacy Notice

This Shareholding Fair Processing Notice ("Notice") sets out how Jardine Lloyd Thompson Group plc collects and processes information about you as our shareholders ("you" and "your"). Do read this Notice with care. It provides important information about how we use personal data and explains your legal rights. This Notice is not intended to override our other privacy policies or fair processing notices or contracts you have with us or any rights you might have available under applicable data protection laws. We may amend this Notice from time to time for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business. Please regularly check the Notice for updates.

 


 

1. Who is responsible for looking after your personal data?

Jardine Lloyd Thompson Group plc ("we", "us" or "our") is the Controller and responsible for looking after your personal data.

 


 

2. What personal data are we collecting?

We may collect, use, store and transfer the following personal data from you:

  • Contact Details which includes your name, addresses, email addresses and telephone numbers
  • Financial Details which includes your bank account details
  • Identification numbers such as shareholder reference number or national insurance number
  • Location data which is any data processed in an electronic communications network or by an electronic communications service indicating the geographical position of the terminal equipment of a user of a public electronic communications service, including data relating the latitude, longitude or altitude of the terminal equipment; the direction of travel of the user; or the time the location information was recorded.
  • Online identifier Natural persons may be associated with online identifiers provided by their devices, applications, tools and protocols, such as internet protocol addresses, cookie identifiers or other identifiers such as radio frequency identification tags. This may leave traces which, in particular when combined with unique identifiers and other information received by the servers, may be used to create profiles of the natural persons and identify them.

Please note that we do not collect any Special Categories of Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We also do not collect any information about criminal convictions and offences.


 

3. How do we use your personal data?

We will only use your information when the law allows us to. We usually use your information for the following purposes:

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • where we are required to comply with a legal or regulatory obligation or requirement.
  • where we are performing our contractual obligation to you.

We have set out below a description of the ways in which we may use your personal data and which of the legal bases we rely on to do so. 

 Activity Type of information collected The basis on which we may collect the information
 To administer and maintain our register of shareholders and to enable trading on the London Stock Exchange

Contact Details

Identification numbers

Location data

Online identifier

Legitimate interests (for the provision of administration services)

To comply with a legal or regulatory requirement

To perform our contractual obligation

 To undertake and perform activities relating to shareholders such as to inform shareholders about upcoming AGMs, payment of dividends and to communicate with shareholders

Contact Details 

Financial Details

Identification numbers

Location data

Online identifier

Legitimate interests (for the provision of administration services)

To comply with a legal or regulatory requirement

To perform our contractual obligation

 Understanding our shareholder/investor base

 Identification numbers

Location data

Online identifier

Legitimate interests (for the provision of administration services)
 Assessment and collection of taxes

Contact Details 

Financial Details

Identification numbers

Location data

Online identifier

To comply with legal or regulatory requirement
 Prevention of financial crime, money laundering and fraud risk.

Contact Details 

Financial Details

Identification numbers

Location data

Online identifier

Legitimate interests (for the provision of administration services)

To comply with legal or regulatory requirement

 Improving products or services

Contact Details 

Financial Details

Identification numbers

Location data

Online identifier

Legitimate interests (for the provision of administration services)

To comply with legal or regulatory requirement

 


 

4. How is your personal data collected?

We may collect data from and about you directly from you or from information we receive from third parties such as your broker, Trustee or Investment Company, credit reference agencies, fraud detection agencies and registration or stock broking industry exchanges.

 


 

5. Who do we share your personal data with?

We work with many third parties to help administer, maintain and provide the website. These third parties may from time to time need to have access to personal data and may include:

  • Banks and other payment service providers to process your entitlements and payments
  • Printers in order to supply you with documentation and certificates
  • Insurance companies where we need to provide details of your account when we make a claim
  • Stockbrokers and market makers who execute transactions on your behalf
  • Service suppliers to facilitate email, IT and administration services
  • Professional advisers, for example lawyers and technology consultants when they need to provide advice to us
  • Your employer or agent(s), in accordance with any specific instructions you provide us
  • Third party providers, for example, your solicitor, when you have requested their services
  • Credit reference agencies and fraud detection agencies as part of our identification procedures
  • 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.
  • Market Research Agencies to measure or understand the effectiveness of advertising we serve to you and others.
  • Your Official Receiver or appointed insolvency practitioner if we receive notice of your insolvency, bankruptcy or insolvency proceedings/arrangement.

 


 

6. International transfers

From time to time we may need to share your personal data with other affiliate companies of the Jardine Lloyd Thompson Group plc who may be based outside of the European Economic Area ("EEA"). We may also transfer your personal data to our service providers, who may be located outside the EEA. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:

  • we will only transfer your personal data to countries which are recognised as providing an adequate level of legal protection,
  • transfers within the affiliate companies of Jardine Lloyd Thompson Group plc who will be covered by the Standard Contractual Clauses which gives specific contractual protections designed to ensure that your personal data receives an adequate and consistent level of protection wherever it is transferred within affiliate companies of Jardine Lloyd Thompson Group plc,
  • transfers to service providers and other third parties will always be protected by contractual commitments and where appropriate further assurances, such as certification schemes - for example, the EU - U.S. Privacy Shield for the protection of personal data transferred to the US.

 


 

8. How long do we keep your personal data?

We will retain your personal data for as long as is reasonably necessary for the purposes set out in this Notice. In some circumstances we may retain your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

Where your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by the business.

 


 

9. What are your rights?

You have a number of rights in relation to your personal data.

You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any Automated Decision Making and Profiling or the basis for international transfers. You may also exercise a right to complain to your Supervisory Authority. These are set out in more detail as follows:

 

Your right

What this means

Access

You can ask us to:

  • confirm whether we are processing your personal data;
  • give you a copy of that data;
  • provide you with other information about your personal data to the extent that information has not been provided to you in this Notice, such as what data we hold about you, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling.

Rectification

You can ask us to rectify inaccurate personal data. We may seek to verify the data before rectifying it.

 

Erasure

You can ask us to erase your personal data, but only where:

  • it is no longer needed for the purposes for which it was collected; or
  • you have withdrawn your consent (where the data processing was based on consent); or
  • following a successful right to object (see 'Objection' below); or
  • it has been processed unlawfully; or
  • to comply with a legal obligation to which we are subject.

We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances where we would deny that request.

Restriction

You can ask us to restrict (i.e. keep but not use) your personal data, but only where:

  • you contest the accuracy of your personal data (see Rectification), to allow us to verify its accuracy; or
  • the processing is unlawful, but you do not want it erased; or
  • it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
  • you have exercised the right to object, and verification of overriding grounds is pending.

    We can continue to use your personal data following a request for restriction, where:

  • we have your consent (for example to process a claim); or
  • to establish, exercise or defend legal claims; or
  • to meet legislative or regulatory requirements or
  • to protect the rights of another natural or legal person.

Portability

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Controller, but in each case only where the processing is based on your consent or the performance of a contract with you; and the processing is carried out by automated means.

Objection

You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

International Transfers

You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.

Supervisory Authority

You have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, the supervisory authority for data protection is the ICO. We do ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.

 


10. Contacts and complaints

The primary point of contact for all issues arising from this Notice, including requests to exercise data subject rights, is our Group Data Protection Officer. The Data Protection Officer can be contacted in the following ways:

Email: JLTGroup_DataProtectionOfficer@JLTGroup.com

Write to: Group Data Protection Officer
Jardine Lloyd Thompson Group plc
The St Botolph Building
138 Houndsditch
London EC3A 7AW

If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.