This Privacy Statement applies between you, an individual, and us, The Share Centre, Share plc and Share Nominees. It applies to all personal data that you provide to us as a customer, as a shareholder in Share plc, or simply as a user of our website.
Our Privacy Promise
- To keep your data safe and private
- Not to sell your data
- To give you ways to manage and review your marketing choices at any time
How the Law Protects You
In addition to our Privacy Promise, your privacy is protected by law. The General Data Protection Regulation (GDPR) is the relevant legislation which came into force across the EU on 25th May 2018.
Data protection law states that we should only collect and use your personal information if we have a proper reason to do so. This includes sharing it within and outside of The Share Centre, Share plc and Share Nominees. The law states we must have one or more of these reasons:
- To provide the services you have requested from us or,
- When it is our legal duty or,
- When it is in our legitimate interest e.g. a valid business or commercial reason, or
- When you consent to it
You agree that we may hold information about you and your affairs in order to (as applicable):
- Verify your identity and financial standing (among other things we are likely to consult a credit or reference agency, which may retain a record of the enquiry);
- Provide you with our services (which may also necessitate liaising with third parties, such as companies and their registrars, and disclosing some aspects of your personal information in order to verify, or otherwise discuss, your investments in the proper provision of our services);
- Comply with your legal and regulatory rights as a shareholder in Share plc; and
- Keep you up-to-date regarding other services which we or firms for whom we provide outsourced share dealing and/or administration services considers may be of interest to you. When you open your account you will be asked to confirm what, if any, direct marketing information you want to receive. Should you change your mind at any time you will be able to easily update your preferences.
We will treat all personal information about you and your financial affairs as confidential. We may however disclose any such information:
- To our authorised agents and firms for whom we provide outsourced share dealing and/or administration services;
- To our authorised agents who assist us in the provision of support to our shareholders (including our registrars)
- If required to do so by law or regulation;
- If requested by a financial regulator or HMRC; and/or
- Where you have given your consent to the disclosure.
The information may also be shared with other financial organisations to protect us and our customers, and other financial organisations and their customers, against financial crime.
Your personal information is important to us
We recognise that when you provide us with information you expect us to use it responsibly, to keep it up to date and to ensure it is only used for the purpose for which it is provided.
We see it as a partnership. You provide relevant, timely information about yourself and keep us advised of changes. We undertake to seek only relevant details, to safeguard them, and to use them only to meet our statutory obligations and with your permission.
In the sections below you'll see why we need certain pieces of information, how we use and safeguard it, and how you can help us keep it up to date.
What information do we record?
Your personal information falls into two categories:
- Information you give us directly – this may be your address, nationality, National Insurance Number, telephone numbers, email address and investment information you provide when you open an account.
- Information we obtain indirectly from the way you use your account – this will include your dealing frequency, the type of investments you make and the range of services you use.
However this information is received we aim to store it securely and accurately, and to keep it up-to-date.
Where do we collect your personal information from?
We may collect personal information about you from these sources:
You give your personal information to us:
- When you apply for our products and services
- When you speak to us on the phone (we record all incoming and outgoing calls);
- When you use our website and mobile app
- In emails and letters
We collect personal information from you when you use our services and this includes:
- Payment and transaction data
- Profile and usage data including the profile you create to identify yourself when you connect to our internet and mobile app services
How is it stored?
Information you provide is stored in two ways; in paper format and electronically:
Paper-based information may include application forms you complete, letters and faxes you send to us and correspondence we send to you. Correspondence received from you is also scanned and stored electronically for easy reference in the event of a query.
All paper records are stored at our premises in Aylesbury. Access is controlled by electronic pass card and 24-hour security is in place.
Electronic information includes all personal details extracted from application forms etc., and transactional data from activity passing through your accounts, such as credits to your account, withdrawals, dividends received, share sales and purchases.
All electronic information is stored in our own database which is not accessible other than by authorised employees of The Share Centre and its agents. Our agents include organisations that assist us with mailing your account statement and other large volume mailings. In order to ensure the security of data, all agents are carefully selected and abide by stringent Service Level and Non-Disclosure agreements.
In addition, electronic information is 'backed-up' on a regular basis and discs are stored off-site at both our Disaster Recovery Site and a secure data back-up service provided by a third party in order to ensure we can have our systems up and running as soon as possible in the event of a fire or other incidents. Off-site storage of data is subject to the same stringent safeguards as that stored on-site.
How is your personal information used?
Use of your information falls into two main categories:
Operating your account with The Share Centre
The information you provide to us is used to ensure we can maintain contact with you and provide the services you have requested. Specifically we will use your personal information:
- To enable you to access and trade investments through your account
- To enable you to deposit money and make withdrawals
- To manage fees, charges and any interest due
- To detect, investigate, report and seek to prevent financial crime
- To comply with relevant laws and regulations
- To respond to complaints and seek to resolve them to your satisfaction
- To test new systems, products and services
Providing you with information on products and services
As new products are introduced or changes made to existing services, we would like to advise you of them from time to time. We may use your personal information, with your previously obtained consent:
- To develop new products and services
- To carry out marketing activities
- To understand how customers use our products and services
- To provide guidance about our products and services
In addition, if you are a Share plc shareholder, we will use your information to ensure that we comply with your statutory rights. These shareholder rights are mainly concerned with ensuring that we communicate details to you about certain developments and corporate events, including our annual report and details of general meetings at which you have an entitlement to exercise your voting rights.
How we use your information to make automated decisions
We do not generally use systems to make automated decisions based on personal information we have about you or your business.
However, we may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.
You have rights over automated decisions and you can ask to be excluded from this decision making.
If you want to know more about these rights, please contact us.
If you choose not to provide personal information
The majority of information we collect from you is necessary for us to be able to provide the products and services you have requested.
If you choose not to give us this personal information, it may delay or prevent us from providing these products and services. This could mean that we cancel that product or service you have with us.
Any personal information that is optional will be made clear at the point we request it.
How long we keep your personal information
We will keep your personal information for as long as you remain a customer (or, where relevant a shareholder).
When you stop being a customer (or shareholder) we still need to retain your personal information to fulfil our ongoing legal and regulatory obligations. In most cases this will not be for longer than 5 years after our business relationship with you is ended.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to keep it e.g. to fulfil our regulatory record keeping obligations. These rights are known as the “right to object”, the “right to erasure”, or the “right to be forgotten”.
There may be legal or regulatory reasons why we need to keep or use your data and therefore we may not be able to comply with your request.
If you want to object to how we use your data, ask us to delete it or restrict how we use it, please contact us at email@example.com.
How to withdraw your consent
Where you have provided your consent for us to process your personal data you can request to withdraw your consent at any time. Please contact us if you want to do so at firstname.lastname@example.org.
Please be aware that if you withdraw your consent, we may not be able to provide some of our services to you. If this is the case, we will tell you.
How to complain
If you are at any stage unhappy with how we have used your personal information, please let us know. You can contact us at email@example.com.
You also have the right to complain to the Information Commissioner’s Office. Full details of how to do this can be found on their website at www.ico.org.uk/concerns/.
Sharing your data
You have the right to obtain your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations. If you would like to do this you can contact us at firstname.lastname@example.org.
Who Do We Share Your Personal Information With?
We may share your personal information with the following organisations to be able to provide you with the accounts and services you have chosen:
- HM Revenue & Customs
- The UK’s Financial Conduct Authority and other regulators or authorities
- The UK’s Financial Services Compensation Scheme
- The UK’s Financial Ombudsman Service
- Fraud prevention agencies
- Credit reference agencies to confirm your identity to help and detect and prevent financial crime
- Any party linked with you or your business’s account or service
- Companies we have a joint venture or agreement to co-operate with
- Companies you ask us to share your data with
- If you make payments to your account with a debit card we will share transaction details with companies which help us to provide this service
- If you make payments to your account by direct debit, we will share data with the Direct Debit scheme
- Tracing agencies should we lose contact with you
We may also share your personal information as a result of future potential corporate transactions involving The Share Centre:
- We may choose to sell, transfer or merge parts of our business or our assets. Or we may seek to acquire other businesses or merge with them
- During any such process, we may share your data with other parties. We will only do this if they agree to keep your data safe and private
Sending your data outside of the EEA
We will only send your data outside of the European Economic Area (EEA) to either follow your instructions or to comply with a legal or regulatory requirement.
Whatever the reason we will make sure the same stringent data protection arrangements are in place.
How can I check it?
Details that are recorded in your profile can be viewed online anytime by signing in to your account. You can also amend those details in order to keep them up-to-date.
Other information stored about you, but not visible via the 'my profile' section can be examined, free of charge, on request.
To request details of information stored, please contact the Data Protection Officer by post at:
The Share Centre
P O Box 2000
Or by e-mail:
Please note, to help us process your request as quickly as possible, we may contact you to clarify what information you require from us and the format in which it should be provided to you.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
We want to ensure we only advise you of services that are directly relevant to you or which may be of interest. To help identify this we will take into account your previous investment activity and other criteria, such as age, investment requirements and the type of investments you make which may indicate a possible interest.
The Share Centre does not make your information available to any other organisation or business, other than its agents as detailed above. You can be sure, therefore, that the information you give us is used only to provide the services you have requested and to keep you informed and up-to-date.
We may communicate with you in a number of ways, for instance by letter, telephone, email or via the Internet. If you have a particular preference we will endeavour to use your preferred method of communication although there may be occasions where this is impracticable or where we are required by law or by our regulators to communicate in a particular way.
Tell us what information you want to receive, and your preferred method of contact, and we'll keep in touch in that way. If you tell us you don't want to receive marketing material then we won't contact you, other than to tell you about statutory changes, amendments to Terms and Conditions or other important changes you need to be aware of.
Our preferred method of contact is, wherever possible, by email or via your on line account but you may also choose to continue to receive certain information by post. This option currently covers Contract Notes for share sales /purchases and your half-yearly account statement. Please be aware that an additional monthly charge applies should you decide to receive this information by post.
Your commitment to us – Keeping Your Information Up to Date
It is important that details like your address, e-mail address, contact telephone numbers and bank account details are kept up to date.
It is vital, therefore, that you remember to advise us of any changes to these details.
We make it easy for you to update your records and control how you manage your account through the 'my profile' section of your account.
Letting us know if your personal information is incorrect
If you believe any of the information that we hold about you is wrong or incomplete then please contact us to let us know and we will take reasonable steps to check its accuracy and correct it. Alternatively you may be able to correct it yourself through the 'my profile' section of your account.
How can I help safeguard my personal information?
Safeguarding your information is important to both us and you, and you can help.
Online, we use a technology called "session cookies" in order to provide you with access to your account information. Session cookies are small pieces of data which are sent to your Internet browser. They are not permanently stored on your computer.
Once you have signed in, you will have access to all parts of the site. Unless you override the setting, if you are inactive for 20 minutes we will, for your own security, automatically sign you out from that 'session'. When you return to your account details (or other areas of the site where you need to be signed in) you will need to re-enter your customer reference and password.
Here are some ways you can help ensure your online security:
- When you sign in to your account online, make sure you are using a secure computer – internet cafes, public networks and even work-based computers may all enable other users to see what sites you've used and even 'remember' your access details.
- Some computers and programs allow you to 'store' a password for later use. Consider carefully whether or not other individuals may have access to that computer and may, therefore, be able to access your account. We recommend that you do not use these 'auto-complete' features and so when you sign in using the top right corner of our site, your auto-complete function will not be activated.
- We will never ask you for your internet password – so if you receive any request asking for these details you should not respond.
- You will be asked to provide a memorable word as an additional way for us to confirm your identity. Please note that we will never send you an email, text message or a direct link to a website asking you to enter your memorable word details. If you receive anything of the kind do not reply but forward it to our compliance team at email@example.com.
- When you call us with instructions we may ask you for these memorable details. This security check is for your protection and so, while on occasions you just feel you want to get on with the business in hand, we do hope you will help us to safeguard your interests by providing them. If you do happen to provide the wrong details inadvertently we know you will understand why we cannot provide the information requested. On the, hopefully, rare occasions this may happen we will however write to you with the details you had requested.