What personal data do we use?
When we say personal data, we mean any information that is about you or which can help identify you.
We may collect your personal data in a number of ways. You may provide personal data to us directly, or we may collect your personal data from third parties.
Information you provide to us
You may provide personal data to us when you contact us. This could be by email, letter, phone, or when you submit personal data online. The types of information you provide to us will differ depending on the services we provide to you, but we will always only collect and process personal data required for the provision of services.
Other information we collect
Depending on the services we provide to you, we may also receive your personal data from other companies.
You may also provide personal data to us about other individuals, such as joint account holders or family relations. If you do this, you must confirm the other person agrees you may share their personal data with us and that we may use it in accordance with our privacy policies.
How do we use your personal data?
We use your personal data in the following ways:
- To deal with requests you send us.
- To respond to your queries.
- To provide you services and to enable us to provide services to our clients.
- To provide you updates on changes to our policies or terms and conditions.
- To help us improve our services.
- To analyse how people use our websites.
- For trend analysis to help us develop and improve our products and services.
- For profiling purposes to help us ensure that we provide you with the right information and offer you relevant services.
- If you agree, to contact you about other services and products we think may interest you.
- To comply with our legal and regulatory obligations, for example, rules imposed by the Jersey or Guernsey Financial Services Commission.
- To monitor the security and use of IT systems.
- To deal with any complaints or legal claims.
- To manage our business in an efficient and proper manner, including the management of our financial position, our resources, the risks to which we are exposed and the way in which we arrange our internal operations.
Depending on the services we provide, we will use your personal data for other purposes detailed in further privacy policies with examples of such purposes being:
- To maintain your account.
- To validate your identity and authenticate you.
- To prevent fraud and financial crime.
- To carry out your instructions in relation to the service we provide you.
- To keep records of your holdings and any transactions that we facilitate on your behalf.
- To inform you of your rights.
What are our legal reasons for processing your personal data?
Where we process your personal data, we need to have a valid legal basis for doing so. More detail is provided within privacy policies specific to services we provide, with legal bases being one or more of the following:
- It is necessary for us to process your personal data for us to perform our obligations under either a contract you have with us, or to take steps at your request before entering a contract with you or a contract we have with a client you have a relationship with (e.g. your employer).
- It is necessary for us to comply with a legal obligation to which we are subject.
- You have given consent to processing for one or more specific purposes.
- It is necessary for the purposes of legitimate interests pursued by us or by a third party, and those interests are not overridden by your interests or your fundamental rights and freedoms.
- It is necessary for the performance of a task carried out in the public interest, for example some financial crime screening.
Who do we share your personal data with?
Depending on the service we provide you, we may share your personal data with third parties where adequate safeguards are in place to protect your personal data.
We may share your personal data:
- To another entity in the Computershare Group.
- To other companies to provide services to you or to help improve our services and products
- Where requested to comply with our legal or regulatory obligations (which may include sharing information with regulators, auditors or other public bodies).
- To help improve our services and products.
For clarity, we will never sell your information to anybody for unsolicited marketing.
How long do we keep your personal data for?
We keep your personal data for as long as we need to for the purposes for which it was collected or (if longer) for any period for which we are required to keep personal data to comply with our legal and regulatory requirements.
Do we transfer your personal data outside the Channel Islands and the European Economic Area?
We may provide you with some services through another member of the Computershare group, or another company which is based in a country where data protection laws and standards differ from those in your home jurisdiction, including India, Australia, and the United States. If you are in Europe this means we may send your personal data to countries outside the European Economic Area.
Where we send your personal data to another country, we will always ensure adequate measures are in place to safeguard it and to ensure you can exercise your rights effectively.
Accessing your information
You may ask for a copy of the personal data we hold about you by writing to us at your nearest office.
Correcting your information
We try to ensure all of your personal data is accurate. If you find any inaccuracies or if your details change, please notify us promptly and we will correct them.
Erasing or restricting use of your information
You may ask us to erase or restrict use of your personal data. If you do, we will comply with your request unless there is a legal reason for us not to (for example, if a law says we must retain records for a fixed period and to do so we must retain your personal data).
Where the legal basis for us processing your personal data is that you have given your consent to that processing, you may withdraw your consent at any time. If you do so we will stop processing your personal data promptly.
Where you have provided consent for us to provide you with marketing information, you can change your preferences in relation to marketing at any time by contacting us at email@example.com.
If you have any complaints about the way we use your personal data please contact our Data Protection Officer who will try to resolve the issue.
You also have the right to complain to the data protection supervisory authority in your country. If you need more information about how to contact your local data protection authority please let us know by contacting our Data Protection Officer.
Service specific privacy policies
We have produced privacy policies which are specific to services we provide where we are the controller of personal data. Links to these privacy policies and description of services are included below.