Privacy Policy

St. James’s Place Plc (Company No. 03183415) has its registered office at St. James’s Place plc Head Office: St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom. For the purpose of the Data Protection Act 1998 the data controller is: The Data Protection Officer, St. James’s Place Plc, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP.

St. James’s Place International (Hong Kong) Limited complies with its obligations under the Hong Kong Personal Data (Privacy) Ordinance (PDPO). Please ask for a copy of our Personal Information collection statement (PICS) before providing us with any personal information. You have the right to access and to request correction of any personal data concerning you held by St. James’s Place International (Hong Kong) Limited. In accordance with the PDPO and the PICS, we have the right to charge a reasonable fee for the processing of any data access request. Such request or notice can be made in writing to: William Ho, the designated Data Protection Officer, 1/F Henley Building, 5 Queen’s Road Central, Hong Kong.

St. James’s Place (Hong Kong) Limited complies with its obligations under the Hong Kong Personal Data (Privacy) Ordinance (PDPO). Please ask for a copy of our Personal Information collection statement (PICS) before providing us with any personal data. You have the right to access and to request correction of any personal data concerning you held by St. James’s Place (Hong Kong) Limited. In accordance with the PDPO and the PICS, we have the right to charge a reasonable fee for the processing of any data access request. Such request or notice can be made in writing to: Jacky Leung, the designated Data Protection Officer, 1/F Henley Building, 5 Queen’s Road Central, Hong Kong.

St. James’s Place (Shanghai) Limited complies with its obligations under the Shanghai Consumer Protection Regulation 1994 (SCPR). You have the right to access and to request correction of any personal information concerning you held by St. James’s Place (Shanghai) Limited. We reserve the right to charge a reasonable fee for the processing of any data access request. Such request or notice can be made in writing to: Mandy Huang, Data Protection Officer, Unit 101-102, Building 9, Yuejie Shankangli, 358 Kangding Road, Shanghai, China 200041.

St. James’s Place (Singapore) Private Limited complies with its obligations under the Personal Data Protection Act 2012 (PDPA). You have the right to access and to request correction of any personal information concerning you held by St. James’s Place (Singapore) Private Limited. In accordance with the PDPA, we have the right to charge a reasonable fee for the processing of any data access request. Such request or notice can be made in writing to: Joel Carpenter, 1 Raffles Place, #15-61 One Raffles Place, Tower 2, Singapore 048616.

St. James’s Place International plc (Singapore Branch) complies with its obligations under the Personal Data Protection Act 2012 (PDPA). You have the right to access and to request correction of any personal information concerning you held by St. James’s Place International plc (Singapore Branch). In accordance with the PDPA, we have the right to charge a reasonable fee for the processing of any data access request. Such request or notice can be made in writing to: Reagan Koh,1 Raffles Place, #15-61 One Raffles Place, Tower 2, Singapore 048616.

When might we disclose your personal information to others?

Please be assured that except for the reasons listed below, we will not disclose your personal information to others.

We may disclose your personal information to others in the following circumstances and/or for the following purposes:

• Where it is necessary for the provision of information or services to you
• Where we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements
• To prevent and/or detect crime
• Where we believe that you may be interested in the services offered by other organisations including our group companies. Please contact us if you would like details about these companies. If you do not wish to receive direct marketing from St. James’s Place, please write to us.
• For evaluation purposes
• Where we have your consent (implied or expressed)
• Personal information collected from you so that you may receive your Unit Trust Manager’s Reports by email will only be disclosed to third parties who process this information on our behalf for administrative purposes; where we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements and to prevent and/or detect crime.

Requests for access to personal information

We are happy to provide you with details of the personal information or personal data, which we hold about you. To protect our customers’ privacy, we follow strict storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. We may charge a small administration fee in relation to any requests for access to personal information or personal data. Please direct any such request to the Data Protection Officer, St. James’s Place plc Head Office: St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom. Visitors from Hong Kong should contact the relevant Data Protection Officer of St. James’s Place International (Hong Kong Limited) or St. James’s Place (Hong Kong Limited) at the address set out above, as the case may be.

Contacting us

At St. James’s Place, we take our responsibility to look after your personal information and privacy seriously. In today’s world, we have all seen a growing trend in cybercrime and security breaches. We have a number of security measures in place to help prevent fraud and cybercrime.

If we become aware that a personal data breach has occurred and is likely to result in a high risk to the rights and freedoms of our clients, Partners or employees, we will inform them without undue delay.

We have a dedicated group, the ‘Information Security Oversight Committee’, that provides oversight and guidance to our information security and privacy programme.

The executive body responsible for privacy and data security is the Information Security Oversight Committee (ISOC) – chaired by the Data Protection Officer. ISOC has a reporting line that enables effective escalation of issues up to the Board where appropriate.

We educate and train our employees, Partners and contractors on their information security, fraud prevention and privacy obligations annually.

Our employees, Partners and contractors take part in an annual Information Security training and awareness program and must agree to adhere to the Data Protection Act and our own Information Security Policy that are designed to keep your information safe. These are refreshed each year to reflect the current trends that are being observed across the information security landscape. Information Security awareness also forms part of our new employee induction program.

We also educate our employees in identifying potential financial crime and internal fraud; any suspicious activity is reported to our Financial Crime Prevention team.

When you login, or send us information on the internet we protect the security of this information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).

When you use your web browser to login, view or share information with us, all electronic information exchanged is encrypted using 2048bit SSL (Secure Sockets Layer) certificate. You can identify this by looking for the HTTPS:// and the padlock in the address bar at the top of your browser.

We will always interact with you in a safe, secure and consistent manner

To keep your information secure and to protect our clients from fraud, St. James’s Place will only interact with you in the following ways. If in doubt, call your St. James’s Place Partner directly or alternatively email the St. James’s Place Data Protection Office at dpo@sjp.co.uk.

When interacting with you, we will:

Only send funds that you have requested to be withdrawn to a verified bank account in your name.

Verify who you are when speaking to you on the phone, by asking you security questions.

We will not:

Ask you for your password over the phone.

Send you an unsolicited email with a link to our login page asking you to enter your Online Wealth Account credentials.

Ask you for payment or credit card details by email or telephone.

Call you to notify you of a problem, and then request you call us back immediately to discuss the problem further.

We continually review our physical and logical security controls in place across the business.

Physical controls – As well as protecting your digital information, St. James’s Place also protects their premises and physical locations where personal data may be used and stored. These measures include security guards, security entrances, secure disposal of confidential waste and hardware, CCTV, personal card access and locks on doors and file storage cabinets, with a ‘clear desk’ policy to ensure all information is locked away and protected.

Logical controls – St. James’s Place uses technical security measures to make sure our systems where we store and use personal information are protected from unauthorised access. Tools such as authentication controls, antivirus, firewalls, malware detection and back-up procedures are used across the business.

All employee emails and devices are encrypted to enable secure transfer and storage of personal information.

We conduct security testing of our applications and services in a controlled testing environment before they are made available for our clients to use on an ongoing basis.

• We perform security risk assessments for each of our sites to identify and control risks.
• External technical assessments are conducted by an independent external 3rd party.
• Security audits and vendor due diligence are conducted on a continual basis.

We have a business resiliency plan with disaster recovery and business continuity testing.

The purpose of Business Continuity Management and the St. James’s Place Business Continuity Plan, is to provide an effective, predefined and documented framework to respond to an incident affecting the Group’s activities. The key drivers in developing the business recovery plans are;

• To mitigate the risks that could lead to the significant disruption of our products and services to our clients.
• To provide a recovery plan that supports a timely and full restoration of our products and services for our clients

However, whilst we take appropriate technical and organisational measures to safeguard your Personal Information, please note that we cannot guarantee the security of any data that you transfer over the internet to us.

The St. James’s Place website uses cookies – small text files that are stored on your computer or in your browser – to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. The website does not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example the number of visits the website receives. In order to respect our visitors’ rights of privacy, this information is anonymous and no individual visitor can be identified from it.

You can disable and delete cookies by changing the appropriate setting within your browser’s ‘Help’, ‘Tools’ or ‘Settings’ menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org.

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

In addition, we use Google’s remarketing technology to advertise online. In doing so, Google will place or read a unique ad-serving cookie on your computer and will use non-personal information about your browser and your activity on our sites to serve ads on their content network. Please click here for more information about remarketing or to opt-out of the Google remarketing cookie.

We will only collect personal information about you if you send us an e-mail enquiry via the ‘contact us’ facility or you register to receive your Unit Trust Manager’s Reports by email. In order for this to happen, you will need to fill out the on line ‘contact us’ form or complete the registration details. The type of information being collected for an enquiry will be apparent from the layout of the ‘contact us’ form, which also tells you how this information will be used. The type of information collected to register to receive the Unit Trust Manager’s Reports by email will be apparent from the details requested when you register. The information collected when you register will only be used to email your Unit Trust Manager’s Reports and for no other reason.

We take all reasonable precautions to protect our visitors’ information, both on and off line. If your personal information changes, please let us know and we will correct, update or remove any information that we hold about you on our active databases. We may however need to retain archive copies of that personal information for legal or audit purposes. If you have any queries regarding the way in which St. James’s Place handles data collected from you on this website, please visit the contact us page.

By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out in the above four paragraphs.

Please note that if you communicate with us electronically, including by e-mail, telephone or fax, this communication may be randomly monitored and/or recorded to protect the interests of our business and our customers. This includes for the purposes of maintaining customer/service quality standards, detection of and/or prevention of crime and to ensure that St. James’s Place employees comply with legal obligations and St. James’s Place policies and procedures (including our customer relations practices).

We may provide hyperlinks from this web site (‘the Site’) to web sites of other organisations including websites of associated companies. Please note that this Privacy Policy applies only to this Site and that St. James’s Place will not liable for the contents of linked web sites or any transactions carried out with organisations operating those web sites.

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, other developments or new products and services being offered.

We will provide you with the most up-to-date notice and you can check our website periodically to view it or you can request a copy from your St. James’s Place Partner.

This notice was last updated on 04/01/2021.