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Privacy policy

This notice describes how we collect, store, use and share personal information.

It applies to personal information provided to us, both by you or by others on your behalf. It also explains the rights you may have in relation to the personal information that we hold about you.

Where 'we', 'us' or 'our' is referred to, it applies to one or more of the companies listed on our website here. We are a 'data controller' of the personal information we process. This means that we decide why and how personal information is used.

Within this privacy notice  'Royal London' refers to The Royal London Group.

We may collect and process the following:

  • information about you – for example name, age, gender, title, date of birth and nationality. We need this information to help us identify you, but also to allow us to contact you, for example, for regulatory or service reporting reasons.
  • government identifiers – for example identification document information (driving licence, passport) and National Insurance number.
  • contact information - for example email, address, postcode and phone number.
  • online information – for example cookies and IP address (your computer’s internet address), if you use our websites
  • financial information –bank account details for any payments you make to us or we make to you.
  • audio or video recordings – for example voice recording when you contact us, or CCTV footage if you visit our offices. Calls may be recorded for regulatory purposes, such as calls relating to the reception, transmission and execution of investment orders.
  • contractual information – for example details about your products and benefits.
  • third party information – where relevant we will have information such as the executor or power of attorney connected to your investment.

When we collect your information, we’ll let you know if any of it is optional. If it is, we’ll explain why it would be useful to us, and you can decide whether it’s something you’re happy for us to have.

We use any information we obtain directly from you or your adviser or intermediary for a number of reasons. Depending on which category you fit into, we have different processing activities which may be carried out by us directly or trusted third party companies that we use. We use information in the following ways for each category:

3.1. If you are an investor in one of our funds:

  • processing your investment application
  • verifying your identity and preventing fraud
  • fulfilling any legal or regulatory obligations
  • completing any requests you make
  • keeping you updated about your investment with regular reports
  • producing tax reports
  • maintaining a backup of the investment register for business continuity purposes

3.2. If you are an adviser, wealth manager, an employee of an existing or potential institutional client, or are exercising investment control for an institutional client:

  • verifying your identity and preventing fraud
  • fulfilling any legal or regulatory obligations
  • managing the relationship with our institutional or wholesale clients
  • keeping you updated with regular reports
  • monitoring the flow of investments, from the platforms we use to distribute our funds
  • researching our customers’ opinions and exploring new ways to meet their needs
  • assessing and developing our products, systems, prices and brand
  • sending you marketing emails and contacting you by phone about our products and services

3.3. If you are/were a tenant of one of our properties:

  • managing our properties
  • ensuring our properties are properly valued, benchmarked and our accountancy requirements are met
  • insuring our properties
  • in some of our promotional marketing material

3.4. Processing activities that apply to all the people whose personal information we process:

  • recording phone calls if you call one of our recorded lines
  • communicating with you if you are the contact of one of our existing or potential suppliers
  • monitoring the use of our websites.

Most of the information we receive comes directly from you or your financial adviser or intermediary if you have appointed one. We may also get personal information about you from other sources, such as:

  • Tracing companies – if we lose touch with you, we may source information such as contact details so we can get in touch and remind you about your investments.
  • Platforms – some of the Platforms selling our funds send us the breakdown of the flows including names of Independent Financial Advisers.
  • Web search – we may search for contact details over the web (e.g. when searching for Financial Advisers). In this case, we will tell you at first contact where we got your details from.
  • Events list – we also get names through lists of events that we sponsor. In this case, we ask the organiser to only share the contacts that agreed to be contacted.
  • Business intelligence portals – sometimes we get contact details of employees of institutions we’d like to work with from portals that we subscribe to. These portals provide information on industry trends where personal data could be provided (e.g. Financial Clarity).
  • Your employer – when an institution becomes our client, they may have provided your details as the person we contact.
  • Risk & compliance portals – we use information from third-party portals to conduct regulatory checks.
  • ‘Third party’ cookies - to collect information on how visitors use our website. Our cookie policy can give you more information on this.
  • Letting agent – we use letting agents to search for and vet potential tenants. Please refer to their privacy policy for more information.

Data protection gives organisations a number of different conditions to allow us to process your information lawfully.

We’ll only use your personal information when one or more of these conditions has been satisfied. Below you can see how we use your information and the legal grounds for processing this:

Uses of your personal data Legal grounds

Consent

Vulnerability Information

We process your personal data to be able to treat you as a vulnerable customer (if due to personal circumstances you are in a vulnerable position). You may, at your discretion provide us with this type of information on a voluntary basis and based on your consent. 

Cookies

On our website we use ‘third party’ cookies that collect information about how visitors use our website.  Please see our Cookie Policy or further information.

Your personal data may be processed when we receive your consent

The consent you provide must be freely given, informed, specific, unambiguous and given with a positive affirmative action.

Your consent can be withdrawn at any time.

Processing and administering your investment

This covers:

  • Processing your investment application.
  • Managing any changes of personal details such as changes of address or name..
  • Completing any requests you make.
  • Responding to queries or complaints.
  • Keeping you updated about your investment, such as sending you regular statements.

Managing relationships with our institutional clients

If you were appointed as a contact by an institutional client of our, this covers:

  • Contacting you for the effective. performance of our contract.
  • Relationship management.
  • Managing any queries or requests you make.

Manage our properties

If you are a tenant at one of our properties, this covers:

  • Approving and signing tenancy agreements.
  • Overseeing the activities of our Managing Agent who will collect rent and service charges and appoint maintenance to provide service to you.
  • Liaising with valuers and accountants.

Communicating with suppliers

If you work for any of our suppliers, this covers:

  • Contacting you for negotiation of a contract.
  • Contacting you for relationship management purposes.

If we lose touch

We may use a trusted 3rd party to find you and reunite you with your policy.

Necessary for the performance of a contract

The personal data you provide or that of a joint party to the contract may be processed when it is necessary in order to enter into or perform a contract. E.g. where we process your personal data to assess your application, calculate your premium or to provide your policy.

We use your personal data, where necessary, to comply with legal obligations including:

  • Establishing your identity, residence and tax status in order to comply with laws and regulations on taxation and the prevention of money laundering, fraud and terrorist financing.
  • Providing you with statutory and regulatory information and statements.
  • Preparing tax and other returns to regulators and the HM Revenue and Customs and overseas tax authorities.
  • Complying with the requirements of Legal and Regulatory bodies e.g. HM Revenue and Customs, The Financial Conduct Authority, Information Commissioner`s Office, and the Financial Ombudsman`s Service.
  • Keeping proper books and records and risk management governance to ensure the company stays financially sound.
  • Carrying out internal reporting, quality checking, compliance controls and audits to help meet these obligations.
  • Recording phone calls of our employees who work with the reception, transmission and execution of investment orders.
  • Reporting to and, where relevant, conducting searches on industry registers. This includes screening all customers against sanction lists and Politically Exposed Persons lists.
  • Complying with court orders.

Necessary for compliance with a legal obligation

Your Personal data may be processed where Royal London has a legal obligation to perform such processing.

We may disclose your information to the Police or other authorities if we have serious concerns about your wellbeing.

Necessary to protect vital interests

This will usually only apply in 'life‑or-death' scenarios.

In certain cases, and where necessary, the special category data provided may be processed for the following purposes:

  • To defend legal and prospective claims,
  • To pursue legal proceedings or prospective legal proceedings, or

For the purposes of establishing, exercising or defending legal rights.

Necessary to provide legal advice and legal proceedings

The 2018 Data Protection Act provides legal grounds for processing special category data for legal advice and legal proceedings.

 

Necessary for legitimate interests

We also use your personal data when we have a “legitimate interest” and that interest isn’t outweighed by your privacy rights. Each activity is assessed, and your rights and freedoms are taken into account to ensure that we’re not being intrusive or doing anything beyond your reasonable expectation.  We’ll assess the information we need, so we only use the minimum.

If you want further information about processing under legitimate interests, you can contact us using the details below.

You also have the right to object to any processing done under legitimate interests.  We’ll re-assess the balance between our interests and yours, considering your particular circumstances.  If we have a compelling reason, we may still continue to use your personal data.

We use legitimate interests for the following:

Use of your personal data Legitimate interest(s) 

In order to develop and tailor our proposition to specific customer outcomes, we may use information to identify customer groups who are likely to benefit from specific customer research.

We will also obtain feedback and customer research in a number of ways including for new fund launches. We will always take steps to check that you haven`t objected to such contact, e.g. by checking the Telephone Preference Service (TPS).   

Evolving our product and brand proposition

We need to be able to identify gaps in the market and groups of customers who may be interested in any new products or services that we are considering developing.

We need to develop those products and services, and make sure our product charges are fair.

We need to make sure our communications and reporting are easy to understand and or products are distributed to the correct audience.

We need to ensure the results from customer research projects are accurate and reflective of the target market. 

  • We collect and provide service information on your investment.
  • We financially assess the performance of our business, we conduct risk management exercises and we carry out long-term statistical modelling.
  • We manage our network and information security (for example: developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions.)
  • We also use CCTV at our premises.
  • We share your information with Royal London Group and our service providers.
  • Sharing tenant information with our suppliers.
  • Maintain backup of our investment register.
  • Monitor sales flow.

 

To manage our business:

  • To improve our service quality and for training purposes.
  • To help us understand our risks, provide management information and help us to manage our business.
  • To ensure that our systems are always secure and that your data is always protected.
  • To prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity).
  • To protect our staff and visitors for health and safety reasons and security purposes.
  • For internal administrative, audit, statistical, or research purposes. Where possible, we will make your data anonymous.  Your data will only be transmitted within the Group and to our service providers when appropriate safeguards, including contractual provisions, are in place.
  • To ensure our properties are  properly valued, benchmarked and all accountancy requirements are met, as well as ensuring adequate insurance cover is in place
  • For business continuity purposes, so we maintain a backup of the holdings and flow of our funds.  It is important we have a plan to ensure a smooth recovery in the event an incident happens to one of our Transfer Agents.
  • If you are an IFA, we may send them your name to our data visualisation provider (this is a tool that allows us to create different graphs and charts for analysis purposes, so we can monitor the flows from and into our funds.

If you are working with us we in launching a new product, we may share your contact information with the other suppliers involved in the same launch.

Launch new products

If you are an Independent Financial Adviser (IFA), wealth manager or work for our existing or potential clients, we could call or send information relating to your products and other products, you or your employer may be interested in. We won`t do this if you have told us not to.

We may source contact information in order to market new products to you or promote brand awareness and benefits of your existing products. We may analyse your personal data to create a profile so that we can contact you with the relevant information.

Sending you marketing electronic communications or calling you to check if you need information about products and services.

We need to ensure our communications are in line with Royal London’s values.

We also need to grow and sustain our business, develop our brand and effectively communicate with our institutions, IFAs and wealth managers.

 

As you’d expect, our employees will access your records in order to use your information for the uses mentioned above. However, only those employees who need access to particular information are given it. We regularly check who has access to our systems.

We may also share your personal information with these categories of third parties:

•Our service providers and agents e.g. transfer agents, mailing houses for printing, offsite storage companies, confidential waste disposal and IT companies who support our technology;

• Our professional advisers: auditors and legal advisers;

• Identity authentication and fraud prevention agencies; one of our transfer agents' uses a credit reference agency, which is currently Experian, to support money laundering checks. Please find Experian’s privacy policy and contact details at https://www.experian.co.uk/consumer/privacy.html 

• HM Revenue & Customs, regulators such as the FCA and other authorities like the Information Commissioner’s Office;

• Any relevant overseas tax authorities;

• UK Financial Services Compensation Scheme;

• Your financial adviser(s) where you have given your authority;

• Organisations that introduce you to us;

• Market research agencies;

• Companies you ask us to share your information with.

We sometimes use third parties located in other countries to provide support services. As a result, your personal information may be processed in countries outside the European Economic Area (EEA).

These services will be carried out by experienced and reputable organisations on terms which safeguard the security of your information and comply with the European data protection requirements. Some countries have been assessed by the EU as being ‘adequate’, which means their legal system offers a level of protection for personal information which is equal to the EU’s protection. Where the country hasn’t been assessed as adequate, the method we have chosen to ensure appropriate standards and processes is through the addition of standard contractual clauses.

The European Commission has recognised ‘standard contractual clauses’ as offering adequate safeguards to protect your rights and we’ll use these where required, ensuring adequate protection for your information. The European Commission approved standard contractual clauses are available here.

We use standard contractual clauses for the below activities, to help us provide:

• IT support and technology development with operations based in India.

• Data visualisation provider (this is a tool that allows us to create different graphs and charts in order to better analyse information) that is based in Australia.

• Other service providers, research partners and administrators with operations based in India, Thailand, Canada and the United States.

We always ensure all personal information is provided with adequate protection and all transfers of personal information outside the EEA are done lawfully.

We use Transport Layer Security (TLS) to encrypt and protect email traffic. However if your email service doesn’t support TLS, any emails we send or receive won’t be protected. We recommend you don’t send anything confidential to us by email.

Once we receive your information, we use strict procedures and security features to protect your information from unauthorised access.

We’ll keep your personal information for as long as it’s considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your investment or your relationship with us has ended.

In the absence of specific legal, regulatory or contractual requirements, any other personal information is kept for our baseline retention period - this is seven years after your investment or lease has ended. In some circumstances we may retain your information for longer. For example we are required by the FCA to keep some pension transfer information indefinitely.

Automated decisions are where a computer makes a decision about you without a person being involved. We do not make automated decisions about you nor profile you.

Your rights are outlined below. The easiest way to exercise any of your rights would be to contact our Data Protection Officer at the contact details provided. We’ll provide a response within 30 days, if not sooner. There’s normally no charge for exercising any of your rights.

Accessing your personal information

You have the right to find out what personal information we hold about you, in many circumstances.

Correcting or adding to your personal information

If any of your details are incorrect, inaccurate or incomplete you can ask us to correct them or to add information.

Data portability

In some circumstances you can ask us to send an electronic copy of the personal information you have provided to us, either to you or to another organisation.

Objecting to the use of your personal information for legitimate interest

You also have the right to object to any processing done under legitimate interest. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason we may still continue to use your information.

Objecting to direct marketing

You have a specific right to object to our use of your information for direct marketing purposes, which we will always act upon.

Restricting the use of your personal information

If you are uncertain about the accuracy or our use of your information, you can ask us to stop using your information until your query is resolved. We will let you know the outcome before we take any further action in relation to this information.

Right to Erasure

You can ask us to delete your personal information in some circumstances, such as if you no longer invest with us and we do not need to keep your information for legal or regulatory reasons. If we are using consent to process your information and you withdraw it, you can ask us to erase your information.

If you are unhappy with how we’re using your information, you have the right to complain to the Information Commissioner’s Office. However, we’d encourage you to contact us first, so we can have the opportunity to deal with your concerns.

The United Kingdom’s Information Commissioner’s Office can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If we want to use your personal information for a new purpose which we haven’t previously told you about, we’ll contact you to explain the new use of your information. We’ll set out why we’re using it and our legal reasons.

Making sure that we keep you up to date with privacy information is a continuous responsibility and we keep this notice under review. We’ll update our notice as changes are required.

This privacy notice was last updated on 18 November 2019.

If you have any questions or comments regarding this privacy notice, or if you’re not happy with the way we use your information, please contact us using the details below.

By post:

Data Protection Officer
Royal London
Royal London House
Alderley Road
Wilmslow
Cheshire SK9 1PF

By email: GDPR@royallondon.com