(1.1) Schroders collects and uses certain Personal Data and is responsible for ensuring that it uses Personal Data in compliance with data protection laws.
(1.2) At Schroders, we respect your privacy and we are committed to keeping your Personal Data secure.
“Client” means an investor in our products or a recipient of our services, who may be an individual investor, or an employee, director, officer, trustee, beneficiary, or representative of an institutional or intermediary client of Schroders.
“Schroders”, “we" or “us” means Schroders plc with its registered office at 1 London Wall Place, London EC2Y 5AU or any of its subsidiaries or affiliates, details of which can be found on the Schroders website. Together these are referred to as the Schroders Group.
“Schroders Websites” means the websites operated by Schroders.
“Schroders Products and Services” means the products and services that we offer to our Clients, including through our related support, mobile or cloud-based services
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Schroders (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.
“You” means each individual to whom this notice is addressed, who may be:
(a) a Client or prospective Client of ours;
(b) a visitor to the Schroders website; or
(c) an employee, director, officer or representative of another organisation with which we have a business
2. Overview of circumstances in which we handle your personal data
(B) Information we receive as a result of Schroders Products and Services.
3. The types of personal data we collect
Many of the products or services offered by Schroders require us to obtain Personal Data in order to provide the products and services we have been engaged to provide. We will collect and process the following Personal Data:
(3.1) Many of the products or services offered by Schroders require us to obtain Personal Data in order to provide the products and services we have been engaged to provide. We will collect and process the following Personal Data:
- Information that you provide to Schroders. This includes information about you that you provide to us. The nature of our relationship with you will determine the kind of Personal Data we might ask for, though such information may include:
◦ basic Personal Data such as first name; family name; national insurance number; email address; phone number; address (including city postcode and country); occupation and job title; bank details; ID documentation; date of birth; life events and family information;
◦ sensitive Personal Data, which may be included in information we handle about your nationality, place of birth, health related information, disability status, or details of political affiliations.
- Information that we collect or generate about you. This may include:
◦ files that we may produce as a record of our relationship with our Clients and prospective Clients, including contact history; and
◦ any Personal Data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements or any Personal Data that we obtain in relation to your use of Schroders Websites.
- Information we obtain from other sources. This may include:
◦ information from publicly available sources, including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources;
◦ information obtained from independent financial advisors (IFAs), other professional advisers, product providers, events organisers, and other agents and/or representatives; and
◦ information obtained from sanctions checking and background screening providers.
4. How we use your information
(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- to allow Clients and prospective Clients to use and access Schroders Products and Services;
- to assess Client and prospective Client applications or contracts for Schroders Products and Services;
- to set up / on-board prospective Clients to use Schroders Products and Services;
- to keep our records up to date;
- to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
- to administer or maintain IT systems in order to uphold standards of service;
- for ongoing review and improvement of the information provided on Schroders
- to understand feedback on Schroders Products and Services and to help provide more information on the use of those products and services quickly and easily;
- to communicate with Clients and prospective Clients in order to provide services or information about Schroders and other Schroders Products and Services;
- to effectively manage and strengthen Client and prospective Client relationships, understand Client and prospective Client needs and interests and learn more about our Clients and prospective Clients in order to develop, improve and manage the products and services we can offer;
- for the management and administration of our business;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
- for the administration and maintenance of databases storing your Personal Data.
(4.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:
- we are performing our contractual obligations;
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
- we have obtained your consent;
- the use of your Personal Data as described is necessary for our legitimate business interests, such as:
◦ allowing us to effectively and efficiently manage and administer the operation of our business;
◦ maintaining compliance with internal policies and procedures;
◦ enabling quick and easy access to information on Schroders Products and Services; and
◦ offering effective, up-to-date security solutions for mobile devices and IT systems.
5. Disclosure of your information to third parties
(5.1) We may share your Personal Data within the Schroders Group for the purposes described above.
(5.2) We may also share your Personal Data outside of the Schroders Group as further described below:
- with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
- with representatives, agents, custodians, intermediaries and/or other third party product providers appointed by the Client or prospective Client (such as accountants, professional advisors, custody service providers and product providers);
- with third party agents and contractors for the purposes of them providing services both to us (for example, Schroders’accountants, professional advisors, IT and communications providers, background screening providers, credit reference agencies and debt collectors) and to Clients or prospective Clients. These third parties will be subject to appropriate data protection obligations;
- with any depository, stock exchange, clearing or settlement system, counterparties, dealers and others where disclosure of your Personal Data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
- where you are a joint account or portfolio holder (or otherwise one of multiple persons holding an account or portfolio), we may disclose your Personal Data to the other joint account or portfolio holder or other person;
- to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend its legal rights; and
- if we sell any part of our business or our assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.
6. International transfers of personal data
(6.1) Schroders is a global business with Clients and operations around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Datato locations outside of your country.
(6.2) Where we transfer your Personal Data to another country it will be protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the European Economic Area (the “EEA”), for example, this may be done in one of the following ways:
- the country to which we send your Personal Data might be approved by the European Commission as offering an adequate level of protection for Personal Data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your Personal Data;
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.
(6.3) You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us as described in paragraph 12 below.
7. How we safeguard your personal data
(7.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value. We operate layers of safeguards and defences designed to ensure that Schroders is able to operate safely. We have extensive controls and mechanisms in place designed to detect, respond and recover in case of any adverse events that may arise.
8. How long we keep your personal data
(8.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:
- our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
9. Your rights
(9.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Schroders;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
(9.2) You can exercise your rights by contacting us using the details provided at paragraph 12 below.
10. Schroders websites and other websites
12. Questions and concerns
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.
With effect from 2 July 2014, the Singapore Personal Data Protection Act (“PDPA”) comes into full force. The purpose of PDPA is to govern the collection, use and disclosure of personal data by organisations in a manner that recognises both the right of individuals to protect their personal data and the need of organisations to collect, use or disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances.
The purpose of this Annexure is to highlight key requirements specified within PDPA that are applicable to Schroder & Co (Asia) Ltd (“SCAL”) business operations.
1. Appointment of PDPA Officer
SCAL shall designate one or more individuals to be responsible for ensuring that the organisation complies with the PDPA.
SCAL shall make available to the public the business contact information of at least one of the individuals designated as the Personal Data Protection Officer (“PDPO”).
The designation of the Head of Operations as the PDPO for SCAL shall not relieve it of any of its obligations under the PDPA.
2. Personal Data
Under PDPA, “personal data” refers to data, whether true or not, about an individual who can be identified:
a. from that data; or
b. from that data and other information to which the organization has or is likely to have access.
This includes personal data of individuals who have been deceased for less than 10 years but exclude business contact information unless expressly referred to in PDPA.
3. Collection, Use and Disclosure of Personal Data
The collection, use and disclosure of personal data may only be carried out if the individual has provided consent (after having been notified of the purpose of collecting, using and disclosing the personal data) or in case of no consent, exceptionally authorized under the PDPA (2nd, 3rd, and 4th Schedules). Please contact the PDPO when exception is required. An individual can withdraw consent by giving reasonable notice to SCAL, which will have to explain the likely consequences of withdrawal of consent.
SCAL shall not inform any individual that it has disclosed personal data to a prescribed law enforcement agency if the disclosure was made without the consent of the individual pursuant to the 4th Schedule or under any other written law.
4. Access to and Correction of Personal Data
Upon the request of an individual, SCAL shall provide, as soon as reasonably possible, the individual with:
- personal data about the individual that is in its possession or under its control
- information about the ways in which the personal data has been used or disclosed by itself within a year before the date of the request
In addition to the exceptions as provided in the 5th Schedule of PDPA, SCAL does not need to comply with the request of the individual if such provision of personal data:
- could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request
- could reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request
- reveal personal data about another individual
- reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity
- is contrary to the national interest of Singapore