Privacy Policy

• Information collected from any communications with you; and
• Information obtained through audits or processed in the process of ensuring our Partners comply with their regulatory obligations.
• Information stored on our client relationship management systems which Partners have access to and store information onto.
• Information collected when dealing with any complaints you may have.

This will include the following personal information:

• 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.
• Employment information such as job title, employment history and professional accreditations.
• Financial information:
  • 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 that your Partner provides to you, including:
  • 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 obtained during telephone recordings.

Information which we have gathered from publically available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and our Partners are required to carry out enhanced due diligence.

• Details about any criminal convictions and any related information which have been obtained from our Partners’ 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.
• Details about your health which are relevant to the service you are receiving, for example where you have disclosed such information to our Partners or to us because it explains your risk appetite for investments.
• In limited circumstances and where relevant to the advice being provided by our Partner, we may also collect information which relates to your trade union membership, ethnicity or political opinions where you have disclosed it to our Partner

We will collect information directly from you when:
• you contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
• Your Partner directly;
• The St. James’s Place Wealth Management client relationship management system and hosted platforms;
• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
• Other St. James’s Place group companies where appropriate, including any of the following independent financial advisers (IFAs) (where you were previously a client) that have been acquired by the St. James’s Place Group:

­ BFS Financial Services Ltd
­ Hale Financial Solutions Ltd
­ Linden House Financial Services Ltd
­ PFP Time Ltd
­ SJP Client Solutions Ltd
­ LP Holdco Ltd

Where an IFA has been acquired by the St. James’s Place Group, your financial advice will be provided by your Partner and your personal information that is held by those IFAs will be governed by their individual privacy notices which will have been made available to you.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• 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 and which is necessary for our everyday business operations and activities, for example to respond to any queries relating to our Partner services that we receive.
• In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• 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.
• You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to review a complaint in respect of the Partner service you have received unless we have all the information we need, which could include your health information for example.
• 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.
• There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.

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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:

• Your Partner
• Other Partners within theSt. James’s Place Partnership only where we have to transition services. (e.g. if your Partner leaves the St. James’s Place Partnership.)
• Other St. James’s Place group companies, including any independent financial advisers (IFAs) (where you were previously a client) that have been acquired by the St. James’s Place Group;
• 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.
• Data protection authorities.
• Financial crime and fraud detection agencies.
• The police, HMRC and other crime prevention and detection agencies.
• Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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.

• Information collected from the client;
• Information collected when dealing with any complaints you may have;
• Information collected from any communications with you; and
• Information obtained through audits or in the process of ensuring our Partners comply with their regulatory obligations.

This will include:

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.
• Your relationship to our client who is receiving James’s Place Partner services.

Financial information relating to your financial liabilities, for example details of you and your partner’s property portfolio to enable us to establish that a client has provided with appropriate financial advice

• We may collect details about your health which are relevant to the services our client receives from the relevant Partner (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).
• In limited circumstances where relevant to the advice being provided by our Partner, we may also collect information which relates to your trade union membership, ethnicity or political opinions where it has been disclosed to the Partner by the client.

We will collect information directly from you when:

• you contact us by email, telephone and through other written and verbal communications, for example in relation to a data subject access request.

We may also collect your personal information from:

• our client who is receiving Partner services.
• our client’s Partner;

the St. James’s Place Wealth Management client relationship management system and hosted platforms.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• 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 maintain our business records.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• 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 or business associate who is our client.
• 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.
• There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.

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.

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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:

• The client’s Partner
• Other Partners within the St. James’s Place Partnership only where we have to transition services for clients. (e.g. if your spouse is a client and his or her Partner leaves the St. James’s Place Partnership.)
• Other St. James’s Place group companies.
• 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.
• Data protection authorities.
• Financial crime and fraud detection agencies.
• The police, HMRC and other crime prevention and detection agencies.

Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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.
• 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.
• Employment information such as job title, employment history and professional accreditations.
• Financial information relevant to the products we provide, including:
  • 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 about your family including information about your dependants.
• Information obtained during telephone recordings where recorded.
• Your marketing preferences and details of your customer experience with us.
• 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 11 below.

• As part of our regulatory requirements, 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). In limited circumstances, we may also collect information which relates to your trade union membership (for example when gathering your employment details), genetic or biometric data or data concerning your sex life or sexual orientation where you instruct us on joint products.

We will collect information directly from you when:

• you apply to purchase, vary or renew a James’s Place product; and
• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Your St. James’s Place Partner where applicable.
• The St. James’s Place Wealth Management client relationship management system and hosted platforms.
• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
• Other 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.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• We need to use your personal information to enter into or perform the client agreement that we hold with you for the product in question. For example, we need to use your personal information to provide the products that you have purchased from us.
• 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 maintain business records, to review our business models, to undertake strategic and operational business analysis of the products we offer, to maintain management information, and for internal audit purposes.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
• 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.
• 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.

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.

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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:

• Third parties who facilitate the arrangement of products that you purchase from us such as product providers, and 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.
• Your Partner within the St. James’s Place Partnership so that the product you have purchased can be integrated into the wealth management service provided to you by your Partner.
• Other St. James’s Place group companies.
• Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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.
• 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.

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.
• Employment information such as job title, employment history and professional accreditations.
• Financial information relevant to the products we provide, including:
  • 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 about your family including information about your dependants.
• Information obtained during telephone recordings.
• Your marketing preferences and details of your customer experience with us.

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 11 below.

• 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). In limited circumstances, we may also collect information which relates to your trade union membership (for example when gathering your employment details), genetic or biometric data (or data concerning your sex life or sexual orientation where you instruct us on joint products.

We will collect information directly from you when:

• you enquire about a St. James’s Place product or apply to purchase a St. James’s Place product; and
• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Your St. James’s Place Partner
• Other 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.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to maintain business records, to review our business models, to undertake strategic and operational business analysis of the products we offer, to maintain management information, and for internal audit purposes.
• We need to use your personal information to enter into the product agreement with you for the product in question. For example, we need to use your personal information to set up the products that you are looking to purchase from us.
• 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.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.
• 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
• 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.

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 a quote for one of our products unless we have your health information.

[table id=4 /]

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:

• Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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.
• 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.
• Other St. James’s Place group companies.
• 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.

• 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, for example details of you and your partner’s property portfolio to enable us to establish that a pension product our client is looking to purchase is appropriate.

Any information which is relevant to the product we provide for our client.

• We may collect details about your health which are relevant to the product we will be providing to our client.

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.

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:

• Third parties who facilitate the arrangement of products we recommend such as product providers and 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.
• Our client’s Partner within the St. James’s Place Partnership (as appropriate) so that the product purchased by our client can be integrated into the wealth management service provided to our client by the relevant Partner.
• Other St. James’s Place group companies.
• 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 who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• 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 maintain business records, to review our business models, to undertake strategic and operational business analysis of the products we offer, to maintain management information, and for internal audit purposes.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• 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 or business associate who is our client
• There is a substantial public interest such as the prevention and detection of unlawful acts such as where we suspect fraud.
• 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.

[table id=5 /]

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:

• Third parties who facilitate the arrangement of products we recommend such as product providers and 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.
• Our client’s Partner within the St. James’s Place Partnership (as appropriate) so that the product purchased by our client can be integrated into the wealth management service provided to our client by the relevant Partner.
• Other St. James’s Place group companies.
• 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 who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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.

If you are a business partner such as products providers, portfolio or fund managers and contractors who carry out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.

• 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 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 publically 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.
• From other St. James’s Placegroup companies.
• From publically available sources such as internet search engines.
• From service providers who carry out sanctions checks.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• 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. In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

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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:

• Where you are providing a product or services to one of our clients on our behalf, the relevant St. James’s Place Partner where the client receives wealth management services from that Partner.
• Other St. James’s Place group companies.
• 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 who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, 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 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 which can be found in section 11 below.

We will collect your information directly from our website.

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

• 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.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

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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:

• Other St. James’s Place group companies;
• If you receive wealth management services from a St. James’s Place Partner, the relevant Partner if relevant to the services you receive; and

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.