This Notice gives information on how the First Sentier Investors group of companies collect, use and protect the personal data held about investors, clients, intermediaries and other business contacts.
This Notice describes how we will fulfil our obligations under applicable data protection laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the General Data Protection Regulation or GDPR).
Information about us
References in this Notice to First Sentier Investors will include the following companies as well as the EU based group company investment funds that they manage (as applicable):
First Sentier Investors (UK) Funds Limited*
First Sentier Investors (UK) IM Limited*
First Sentier Investors (UK) Services Limited
First Sentier Investors Europe Holdings Limited
First Sentier Investors International IM Limited*
First Sentier Investors (Ireland) Limited**
(together “we”, “us” or “our”)
*Authorised and regulated by the Financial Conduct Authority of the United Kingdom
**Authorised by the Central Bank of Ireland
Information we may collect
First Sentier Investors collects from time to time, personal data on investors, clients, intermediaries and other business contacts from a number of sources, including from: investor application forms; other First Sentier Investors forms (including website forms); client investment management agreements; correspondence, conversations with clients, advisers, intermediaries; business cards; third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents); client advisers; other third parties; and from public sources. This information may be collected directly from investors, clients, intermediaries and business contacts, or indirectly from third parties, as follows:
We may collect from you and process the following personal data, depending on the nature of our business relationship with you:
- Your name; address (including proof of name and address); photo identification; contact details both personal and work (for example, your email and phone numbers); hobbies and interests; job title and company; nationality; citizenship; tax residency; date of birth; passport details; national insurance number and other tax details; adviser details; investment details; banking details; signed contracts with you; business cards, contact sheets and biographies; financial dealings; family connections; details of your company’s directors, secretaries, authorised signatories and identification documents; details of any complaints made; data received from due diligence activities (such as anti-money laundering, politically exposed persons and sanctions checks); responses to surveys and competitions; fraud enquiries (for example, information from police reports); images captured by CCTV cameras on our premises; recordings of telephone conversations and electronic communications with our staff.
From third parties
We may collect personal data about you from third parties, depending on the nature of our business relationship with you, in particular:
- Third party service providers to our funds (for example, transfer agents, registrars, administrators, distributors, custodians and paying agents) – information received includes personal details of investors obtained from fund application forms such as: name; address; contact details; nationality; national insurance number; date of birth; tax residency; adviser details; investment details; bank account details.
- Your advisers (including independent financial advisers) – information received may include your name, address, gender, date of birth; bank details.
- Our vendors such as Experian and World-Check – information received includes the results of “Know Your Client”, anti-money laundering, politically exposed persons and sanctions checks.
- Publically available sources such as MandateWire and LinkedIn – information available includes contact details of institutional investors (MandateWire) and details of job title, company, former employers and roles, and connections (LinkedIn).
How we will use the information we collect
The information we collect and use will depend on the nature of our business relationship with you, as follows:
- In relation to prospective investors and clients, we may process personal data for identification purposes (prior to becoming an investor in our funds or a client of ours under an investment management agreement), for the purposes of anti-money laundering, counter terrorist financing, suitability and appropriateness assessments, “Know Your Client” and credit-worthiness checks, and for any other applicable legal or regulatory reasons. Failure to provide relevant information will mean that we will not be able to on-board a potential investor or client.
- In relation to investors in our funds, we may process information collected for the purpose of account administration and other general business purposes (for example, for processing subscriptions and investments; maintaining the share register of investors, carrying out investor instructions; handling any complaints and enquiries; sending investor communications, including financial reports, valuations, corporate actions). In addition, in order to comply with regulatory obligations, we may collect and disclose certain information about our investors and certain related persons and their investments to HM Revenue & Customs and/or other relevant tax authorities overseas.
- In relation to our investment management clients, we may process personal data for the purpose of managing and administering clients’ accounts, including providing valuations and periodic reports and informing clients of relevant information as required by the investment management agreement.
- We may from time to time process personal data of investors and clients to comply with legal and regulatory requirements impacting our business. In particular, we may need in the context of our business: to obtain legal advice on legal and regulatory requirements; to report to relevant regulators; to comply with market opening and registration requirements in the conduct of our business.
- In relation to intermediaries who introduce investors into our funds (such as distributors, platforms and independent financial advisers), we may process personal data to conduct market research, gauge product sales or product performance or assess the creditworthiness of intermediaries. In addition, we may process the personal data of investors introduced to our funds, as outlined above.
- In relation to our general business contacts (including consultants and intermediaries who act for our mutual clients), we may process personal data for general business purposes such as: for public relations and corporate communications purposes; providing thought leadership articles; networking/relationship building; conducting market research and gathering industry statistics; evaluating products and services; and assisting with any queries.
- Monitoring purposes: we may process personal data to analyse the performance of IT systems, monitor usage of resources and systems and to improve products, services and usability of our technology platform, including telephone calls and electronic communications with our staff which may be recorded for the purposes of retaining a record of communications, in the interests of security, for training and compliance monitoring purposes and/or to comply with legal or regulatory obligations.
- Where you have provided your consent, we may process your personal data for the purposes of informing you (for example, by telephone, mail and email) about other products and services available from the First Sentier Investors group of companies and of marketing campaigns and event invitations.
We are entitled to use your personal data in these ways because:
- We have legal and regulatory obligations that we have to discharge;
- We may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- The use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates);
- The use of your personal data is necessary for the performance of a contract with you;
- You have provided your consent to us processing your personal data (other than for marketing purposes); or
- You have provided your consent to us processing your personal data for the purposes of informing you (for example, by telephone, mail or email) about other products and services available from the First Sentier Investors group of companies and of marketing campaigns and event invitations.
Disclosure of your information
- We may disclose your personal data to any member of the First Sentier Investors group, which means our affiliates, for internal business and administrative purposes (including to administer our products and services and for prudential and risk management purposes) and, where you have given your consent, to provide you with information on related products and services. We may also disclose personal data relating to our clients to members of our group to whom we sub-delegate our services (for example, trade order execution and portfolio management).
- We may disclose your personal data to third parties that are specifically engaged by us to provide services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified services to us. The following is a list of the types of third parties who process your personal data on our behalf:
- third party service providers to our funds (for example, transfer agents, administrators, distributors, custodians, paying agents and researchers). These third party service providers may also disclose and transfer your personal data to their affiliates or other third party contractors;
- credit reference agencies, debt collection agencies and other companies for use in credit decisions, for fraud prevention, to pursue debtors and for the verification of identity;
- document execution vendors in relation to the execution of contracts with our clients;
- insurance brokers;
- professional advisers (for example, accountants/tax advisors and legal advisors).
- If you use a financial adviser (as indicated on your investor application form), then details of your investments and valuations may also be provided to such financial adviser.
- We may disclose to relevant tax authorities, regulators, government departments or competent authorities of the UK or of other countries, any personal data (including tax status, identity or residency or other personal and payment information, documents or self-certifications) in order to comply with a court order or to meet legal and regulatory requirements arising in the conduct of our business. Such disclosure may be made directly to such regulators or competent authorities or made indirectly to our advisers or providers who will make such filings or disclosures on our behalf.
Transfers outside the EEA
We may transfer your personal data to our overseas affiliates (including outside the EEA) and/or allow the information to be accessed by our affiliates and their employees outside the EEA as well as within in. It may also be processed by personnel operating outside the EEA who work for us or for one of our third party service providers.
Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA or that the transfer is otherwise compliant with data protection laws. This can be done in a number of ways, for example:
- the country that we send the data to might be approved by the European Commission;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data;
- where data protection laws permit us to transfer your personal data outside the EEA.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a sample copy of the model contractual clauses) by contacting infoUK@firstsentier.com
How long will we store your data?
Personal data held by us will be kept confidential. How long we hold your personal data for will vary and will be determined by various criteria, including:
- the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.
Your rights in relation to your data
If you wish to contact us for any of the reasons below, please e-mail us at infoUK@firstsentier.com
- You have a right to access the information which we hold about you. If you wish to make an application to access or obtain this information, please contact us. In some circumstances, you have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit that data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us.
- We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date. Please contact us if any of the details you have provided change. Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.
- If you wish us to erase or restrict using your data, please contact us. We may need to discuss with you the basis of your request as there may be circumstances where we are legally entitled to continue processing your personal data/refuse your request.
- If you have previously provided your consent to our use of your data (other than for marketing purposes) and you wish to withdraw such consent, please contact us. We may need to discuss with you whether our use of your data needs to continue for lawful purposes (i.e. because we have another legitimate reason (other than your consent) for doing so).
- If you have previously consented to being sent information about other products and services available from the First Sentier Investors group of companies, you may withdraw such consent by contacting us.
- If you have any complaints in relation to the way we have used your information, please contact us in the first instance. You also have the right to lodge a complaint with the Information Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (Tel: 0303 123 1113) if you think that any of your rights have been infringed by us.
Other Products and Services
If you would like to receive further information from us about other products or services offered by First Sentier Investors group, please ensure you tick the relevant box on the appropriate application form or contact us by e-mailing us at infoUK@firstsentier.com
When you enter our website, you will be asked to accept some Terms and Conditions and a Cookie will remember if you have accepted them. This means that you don’t have to re-accept them on every visit. The Cookies we use here are ‘persistent’ as they remember your preferences. Every time we amend our Terms and Conditions, or on an annual basis, a new Cookie will be set and you will be asked to re-accept our Terms and Conditions.
We use analytics cookies to collect information on website activity (such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site). This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website. Visit Google’s site for an overview of privacy at Google and information on how to opt out of the Google Analytics cookie. These Cookies are ‘session’ cookies.
We use marketing automation cookies placed by Pardot and Salesforce. Pardot tracks visitor and prospect activities on our website and landing pages by setting cookies on your browsers. Cookies are set to remember preferences (like form field values) when you return to our site following a previous visit. Pardot also sets a cookie for logged-in users to maintain the session and remember table filters.
Pardot sets first-party cookies for tracking purposes, to allow us to improve our content, and sets third-party cookies for redundancy. Using first-party and third-party cookies together is standard in the marketing automation industry. Pardot cookies don’t store personally identifying information, only a unique identifier. Pardot sets first-party cookies on tracker subdomains and Pardot domains.
We use remarketing cookies to allow us to match external advertising messages with the pages that you have visited on our website, with the intention of providing you follow-up information. You can opt-out of this service by visiting the Network Advertising Initiative opt-out page.
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However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work. More information about cookies can be found on allaboutcookies.org
Links to other web sites
Our web site may contain links to non-First Sentier Investors web sites. While such links are provided for your convenience, you should be aware that the information handling practices of the linked web sites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
Recording of telephone conversations and electronic communications
Please note that we are required to record telephone conversations (we will do so without a warning) and to keep copies of electronic communications. We are required to keep copies of these recordings and electronic communications for a period of five years (or up to seven years at the request of a regulator). Copies may be provided to you upon request by contacting infoUK@firstsentier.com
Changes to our Privacy Notice
This Notice was updated in September 2020. We reserve the right to change this Notice at any time. We will ensure that any changes to this Notice are added to the Notice available on our website on their effective date.