1. Who is responsible for your data
2. Personal information we collect and how we collect it
We will only retain personal information for as long as is necessary to carry out the purposes stated below and in Section 4 or as is required by applicable legislation or other regulation.
We will treat personal information as private and confidential and we will not disclose the information except in the circumstances set out under section 5 below.
We will collect personal information about you including, name; residential correspondence and email address; phone number, national insurance number, national personal identifier, tax reference number; passport number, date, town and country of birth; payment card and, bank account details; any authorised person nominated or appointed by you and any Financial Adviser; beneficiary and employer details; and the internet protocol (IP) address used to connect your computer to the internet and your geographic location.
From time to time we may also collect sensitive personal information (such as matters relating to your health) in order to provide our services to you. Where this is the case, we will always ask for your explicit consent to record this information at the time we collect it.
We will also collect personal information about you when you apply to use our services and then during the course of our relationship with you. We may collect this information in various ways including, from:
- applications or forms that you or someone acting on your behalf may complete or agreements that you may enter into with us;
- emails, letters and during telephone calls, when you register for services, in customer surveys and when you participate in competitions and promotions; and
- other Alliance Trust Group companies receive from each other and from other organisations such as fraud prevention agencies.
You are not obliged to supply any of the personal information that we may request. However, failure to do so may result in us not being able to act on your instructions or provide our services to you or may result in us having to report you to a competent authority such as HM Revenue and Customs.
3. Recording and monitoring phone calls
We will record and monitor phone calls in case we need to check that we have carried out your instructions correctly, to resolve queries or complaints, for regulatory purposes, to help improve our services and to help detect and prevent fraud. Monitoring may also be undertaken for staff training purposes.
4. How we use your personal information
We will use personal information for the following purposes:
- responding to your requests and processing applications;
- providing our services in accordance with the Terms and Conditions for the relevant product;
- complying with regulatory requirements and our other legal obligations including the prevention of fraud and money laundering;
- complying with a request for disclosure by a competent authority;
- complying with any reasonable request for information from a person with a legal right to it, such as your personal representatives following your death or your trustee in bankruptcy following your bankruptcy;
- developing and improving our services, and to tell you about changes to our services;
- providing you by letter, telephone, email or website with:
- any information that we consider that we need to send you in order to comply with regulatory and other legal requirements (including the obligation to treat customers fairly) including annual statements and details of regulatory changes affecting your use of our services;
- market news and investment information;
- details of any of our services that we consider may be of interest to you, provided you have consented to be contacted for such purposes; and
- carrying out market research and analysis and obtaining feedback from you on our services.
We may use information from third parties and/or aggregate your personal information with data from third-party sources for these purposes.
We also use automated decisions based on personal information we have or collect about you in order to verify your identity or to comply with antimoney laundering legislation. The use of such systems is only undertaken for website applications and will not result in an automatic refusal of a website application.
We rely on the following legal bases to process and use your information:
- processing is necessary for the performance of the services we provide to you in accordance with the Terms and Conditions of the relevant product;
- processing is necessary for the purposes of our legitimate business interests including:
- where processing enables us to enhance, modify, personalise or otherwise improve our services for the benefit of our customers;
- to develop new products and services;
- to enhance the security of our network and information systems;
- to better understand how people interact with our websites;
- to determine the effectiveness of promotional campaigns and advertising; and
- to promote further sales of our products and services;
- processing is necessary for compliance with a legal obligation; and
- processing is carried out where you have provided your consent.
5. How we share information
We may disclose and share personal information with:
- other companies within the Alliance Trust Group;
- third parties including, credit referencing, fraud prevention, regulatory and law enforcement agencies to investigate or prevent crime;
- our agents and sub-contractors who administer or process the information on our behalf;
- market research companies who may assist us in improving our products and services for you;
- any providers of IT solutions including platform support, cloud-based storage and applications for sales, services and marketing;
- our professional advisers;
- our insurers and any intermediary brokers;
- our bankers and other companies to facilitate payments, including direct debit payments; and
- certain companies (including investment trusts) and funds in which you invest, and to mailing houses which they use, as required by law or regulation or to enable such companies or funds to send you information in relation to the company or Fund.
We may also need to disclose some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. The recipient of the information will be bound by confidentiality obligations.
We may disclose and share your personal information and information concerning your account and transactions with companies with whom you have accounts which may include Self-Invested Personal Pension (SIPP), Individual Savings Account (ISA) or General Investment Account (GIA) providers, and in respect of which we provide you with share dealing or custody services, as required by law or regulation or pursuant to contractual arrangements with such companies.
We may also disclose information concerning your account and transactions as required by law or regulation to any of the following if requested:
- HM Revenue & Customs (HMRC);
- Financial Conduct Authority (FCA); and
- Prudential Regulation Authority (PRA);
- Information Commissioner’s Office (ICO);
- Competition & Markets Authority (CMA); and
- any other competent regulatory, governmental or law enforcement authority.
We also have obligations under the European Union tax rules and agreements and tax treaties with worldwide jurisdictions which require us to provide certain information about you as the beneficial owners of your investments to other appropriate authorities in such member states and other worldwide jurisdictions.
Your personal information may be transferred to or accessed from other countries (including those outside the European Economic Area) and processed for us in those countries on the basis that anyone we pass it to will provide a level of protection equivalent to the Data Protection Laws. Such information may be accessed by local law enforcement agencies and other authorities to prevent and detect crime and comply with legal obligations. Further details as to where your data may be transferred and the basis for such transfers can be found at www.alliancetrustsavings.co.uk/non-eea-processing.html.
6. Your rights
This section explains the rights you have under Data Protection Laws with respect to how your personal information is held and used by us. If you wish to request to exercise any of these rights, you can contact us using the details set out in section 9 below. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under Data Protection Laws.
Where we rely on consent as the legal basis for processing your personal information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing of your personal information that we carried out before your withdrawal.
You have the right to access the information we hold about you, free of charge. You have the right to ask us (and third parties to whom we transfer your personal information) to rectify your personal information if it becomes inaccurate. In order for us to do so, you must inform us of any changes to your personal information so that we can keep it up-to-date.
You have the right to ask us to erase your personal information if:
- you withdraw your consent to our processing of your personal information; or
- your personal information has been processed unlawfully by us; or
- your personal information is no longer necessary for the purposes for which it was collected by us; or
- you object to us processing your personal information on grounds relating to your personal situation.
You have the right to restrict our processing of your personal information if:
- you contest the accuracy of the personal information held by us (for a period enabling us to verify the accuracy of the information);
- our processing activities are unlawful; or
- we no longer need your personal information but you would like us to retain it to ensure its continued availability to you in connection with any legal claims; or
- you object to us processing your personal information on grounds relating to your personal situation and it is still to be confirmed whether our legitimate grounds override your right to object.
You have certain rights to obtain and reuse your personal information for your own purposes across different organisations (for example, if you wish to move to a new financial services provider, this enables you to move, copy or transfer your personal information easily between our IT systems and theirs). This applies only to your personal information that we are processing with your consent or as required for the purposes of fulfilling a contract with you, and which is being processed by automated means. In these circumstances, you have the right to obtain your personal information from us in a usable format and for that personal information to be transmitted to another company, where this is feasible.
If you believe our processing of your personal information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:
Information Commissioner's Office
T: 0303 123 1113
7. Keeping information up-to-date
Please let us know if the personal information that we hold about you needs to be updated or is incorrect.
8. Keeping personal information secure
We will take reasonable technical and organisational security measures to safeguard all personal information. Personal information is stored securely on our computer system and/or in a secure filing system, and we restrict access to those who have a need to know. We provide training and education to our staff on Information security.
However, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security of any personal information which is transferred through the internet or email.
Internet communications are not secure unless the data being sent is encrypted. We cannot accept any responsibility for unauthorised access by a third party or the corruption of data sent to us. For security purposes we may monitor emails received or issued by us.
Alliance Trust Savings Limited
PO Box 164
8 West Marketgait Dundee
T: 01382 573737