Charles Stanley & Co. Limited is the data controller of your personal data for the purposes of data protection law including the General Data Protection Regulation and the Data Protection Act 2018.
This privacy notice applies to you if you are a past, prospective or current client or an intermediary or client of an intermediary of Charles Stanley & Co. Limited (“you”, “your”). It sets out how and why your personal data will be collected and used and how long it will be retained for.
How do we collect information about you?
We collect personal data from you in a number of ways:
From our website we collect information:
you provide by filling in one of our online enquiry forms; and
by using cookies for security purposes, marketing and ad-tracking and to monitor the services you use and how you use them.
From our clients we collect information:
you provide via our account application process and throughout our relationship with you whether face-to-face, by phone, email or otherwise;
by recording telephone conversations between you and us; and
about you from third parties, for example whilst carrying out routine checks during our client on-boarding process and from intermediaries when entering into or administering your agreement with us.
What information do we collect about you?
We collect the following types of personal data about you:
your name, and contact information such as address, email address and telephone number;
your date of birth, national insurance number (or other tax identification number) and due diligence information;
technical data including internet protocol (IP) address, your login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
financial information, employment history, nationality and dependents; and
your marketing preferences.
Why do we collect this information from you?
We collect and use your personal data to provide our services and to ensure we meet our regulatory requirements. Your data may also be used for marketing purposes, so that we can inform you about our products and services.
On what basis do we use your personal data?
We may process your personal data because:
it is necessary for the performance of our contract with you;
we have obtained your consent to do so;
of regulatory and legal requirements that we are subject to;
of the need to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
for our legitimate business interests such as:
• monitoring and efficiently managing the performance and operation of our business;
• outsourcing of parts of our back office functions to third parties;
• contacting you after you request information to see if we can provide further assistance and information about events, economic commentary and keep you informed of other services which might be of interest to you.
How long do we keep this information?
If you are not a client of ours, we will keep your information for a year after we last heard from you. If you ask us to remove you from our marketing list, we may keep your personal details on an “opted-out” list in order to ensure that we do not market to you again.
If you are or have been our client, we keep your information for 15 years after closure of your account. Where required by law or regulation, we keep documents relating to pension transfers indefinitely and recordings of telephone conversations with you for 5 years after they took place.
Who do we share your information with?
In addition to sharing your personal data with other members of the Charles Stanley group, we may also disclose your personal data:
to our IT providers and services providers in order to provide and maintain the provision of our services;
to our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information to provide advice;
to fraud prevention agencies and other organisations to allow us to undertake the relevant checks;
to providers of investments or services we work alongside with, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, discretionary management services, custodians, loans, insurance products or other such products or services. We may also be required to share information with the auditors appointed by the providers of such products or services;
to the Financial Conduct Authority, the Information Commissioner’s Office, or any relevant regulatory authority where they are entitled to require disclosure;
if required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
to relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
if tax regulations require us to collect information about tax residency, then in certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions; or
in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets.
We will not lend or sell your information to third parties.
Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside the European Economic Area (EEA). Where we do so, we will ensure that we do this in accordance with current data protection legislation by only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission or where the recipient is a certified member of the EU-Privacy Shield scheme.
If you agree, we may send you information about our products and services by email and those of other companies in our group which may be of interest to you. Where it is in our legitimate interests, we may send you information about our products and services by post. If you have consented to receive marketing, you may still opt out at a later date. We may also use your name and address to post to you invitations to events, or to introduce you to other Charles Stanley products or services which may reasonably be considered to be of interest to you.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please email us at [email protected] or write to us using the information at the end of this notice.
We may use automated decision making in order to comply with our regulatory requirements in relation to KYC/AML checks or to evidence we are providing a suitable and appropriate service to you.
What are your data protection rights?
You have certain rights in respect of the data we hold relating to you. Further details of these rights can also be found on the Information Commissioner’s website.
The right to access - you are entitled to a copy of the information we hold about you in a portable format or otherwise, this is known as a Subject Access Request.
The right to request rectification - you can request we correct any information you believe is inaccurate or incomplete.
The right to erasure – you can ask us to delete your data under certain circumstances but we may be legally entitled to retain
it so will not be able to erase or modify the data.
The right to object and the right to restrict processing – you can object or request we restrict the processing of the information we hold about you, again under certain circumstances but we may be legally entitled to continue processing and/or may refuse your request.
The right to data portability – you can request we transfer the data we have collected on you to another organisation or directly to you in a reasonable format specified by you.
In order to exercise these rights or if you have any concerns about our use of your personal information, please contact the Data Protection Officer using the information at the end of this notice. You can also contact the ICO in its capacity as our supervisory body.
We will endeavour to keep your information accurate, however, if at any time after giving us this information it becomes out of date, then we ask you to notify us directly and we shall remove or amend the information within a reasonable time frame and in accordance with legislative requirements.
Changes to our Privacy Notice
We keep our privacy notice under regular review. This privacy notice was last updated in October 2019. We reserve the right to update this privacy notice at any time and we will advise you when we make any substantial update to it.
How to contact us
If you have any questions about our privacy notice or the information we hold about you please contact us at
[email protected] or by post at the address below:
Data Protection Officer
Charles Stanley & Co. Ltd
55 Bishopsgate, London