Privacy Notice

We may collect your personal data in a number of ways including when you:

• interact with us before becoming a client, for example, when you contact us about our services;
• apply for and use our products and services;
• communicate with us over the phone, by letter, via email or the website.
• enter into any agreement with us;
• ask us to contact you;
• attend events, participate in surveys, prize draws or competitions

We may also collect your personal data from someone else, for example:

• if a person applies for a joint account with you, they may share your personal data with us;
• if you are a stakeholder in, or manager of a business, and the business applies for products or services, or enters into an agreement or interacts with us, we may obtain personal data about you to carry out checks against the business;
• from third parties such as credit reference agencies, fraud prevention agencies, financial advisors, introducers, research and data analysis partners;
• from public sources - for example, Companies House

Where you provide us with personal data relating to others (for example, your family members), we understand that you either have their consent or are entitled to provide this information to us for subsequent use. Where applicable, you should ensure they read this Privacy Notice and understand we will use and disclose their information, in the ways described in this Notice.

Types of information we may collect include:

Personal details

• Name
• Date of birth
• Contact details
• Nationality
• Tax details (including National Insurance No.)
• Employment details
• Regulatory history

Financial information

• Income and outgoings
• Assets and liabilities
• Bank details
• Account information and history
• Account activity
• Credit history and information
• Shareholdings

Information we have from our dealings with you or anyone acting on your behalf

• Recordings of your telephone calls, meetings or other interactions with us
• Our correspondence with you
• Details of your transactions

Sensitive personal data

(We only collect this data where there is a permitted exemption under data protection law or with your explicit consent)

Including but not limited to the following:

• Health data
• Biometric data, such as voice or fingerprint information
• Religious beliefs
• Sexual orientation
• Race and ethnicity

We may use your personal data for reasons including but not limited to the following:

Performing or entering in to a contract

• to verify your identity;
• to verify the accuracy of the data you have provided to us;
• to provide products and/or services requested by you;
• to manage your accounts;
• to manage any contractual relationship with you;
• to make credit decisions

Compliance with legal obligations

• to detect and prevent fraud and money laundering;
• to comply with applicable laws, regulations and/or codes of practice;
• to provide appropriate support and adjustments as needed to assist you

Legitimate Interests

• to trace and recover debts;
• to administer surveys, prize draws or competitions;
• to manage events;
• to support research and analytics that assist us in marketing our products and services
• to conduct analysis and market research, for example, to identify trends in the use of our products and services so that we can:
  • improve the products and services we provide to you;
  • improve our business;
  • keep you up to date with relevant products and services

Your Right to Object – Please note that you have a right to object to the processing of your personal information where that processing is carried out for our legitimate interests. Where we send you direct marketing, we will obtain your consent for this, which you may withdraw at any time.

Automated decision making to detect and prevent fraud

We use real time fraud detection systems to help us to identify whether your account may be being used fraudulently. These systems make automated decisions for us and take account of information such as fraud patterns. Your personal data may be used to make these decisions. For example, fraudulent activity may be suspected where there is unusual activity on your account. If we suspect a risk of fraud, we may stop any activity on the account, or refuse access to the account.  You have the right to object to an automated decision and ask for someone to review the decision.

In addition to sharing your personal data with other members of Rathbones Group Plc, we may also disclose your personal data:

• to our professional advisors, receivers, and administrators (where applicable);
• to service providers (including for example, Information Technology systems providers) who may provide products or services. This includes Investec Group who continue to provide services to Investec Wealth & Investment (UK) during our separation and transition to Rathbones Group Plc;
• to courts, governmental and non-governmental agencies, regulators and ombudsmen;
• to law enforcement agencies;
• to relevant tax authorities;
• to any relevant third party in the course of an acquisition, sale, transfer, reorganisation or merger of parts of our business or our assets;
• as required or permitted by law or regulation, where we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of the Rathbones Group Plc, our clients, or others;
• where you have been introduced to us by an introducer (e.g., an independent financial adviser), unless you have told us not to, we will inform the introducer of the outcome of the enquiry including whether we have agreed to provide you with the relevant product or service;
• to credit reference agencies (CRAs). See CRA section below;
• to fraud prevention agencies (FPAs). See FPA section below.

You may also ask us for details of the CRAs and FPAs we have used for your searches. If there are any errors in the information we hold about you, please tell us so we can correct the information we hold about you.

Credit Reference Agencies (CRAs)

In order to process your application, we may perform credit checks (where applicable) and identity checks on you with one or more credit reference agencies (“CRAs”).

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history (where applicable). CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• verify the accuracy of the data you have provided to us;
• assist in the prevention of criminal activity, fraud and money laundering;
• manage your account(s)
• trace and recover debts

We may continue to exchange information about you with CRAs while you have a relationship with us.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other firms.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at each of the three CRAs websites – visiting any of these three links will take you to the Credit Reference Agency Information Notice (CRAIN document):

Call Credit www.callcredit.co.uk/crain

Equifax www.equifax.co.uk/crain

Experian www.experian.co.uk/crain

Fraud Prevention Agencies

FPAs use your personal data to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.

Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be viewed here. 

We may transfer your personal data to recipients who may carry out services on our behalf (including other members of the Rathbones Group) located in countries outside of the UK or EEA.  Where Investec Group continue to provide services and support for Investec Wealth & Investment (UK) during our separation and transition from the Investec Group to the Rathbones Group Plc, personal data may be transferred to countries outside the UK or EEA, including South Africa.

If we transfer your personal data to such a country, that does not provide the same level of data protection as the UK, we will take all necessary steps to ensure your data is protected to an equivalent standard as within the EEA.

You have the right to:

• request access to, and copies of, the personal data we hold about you (also known as a Data Subject Access Request);
• request rectification or erasure of your personal data;
• request restriction of processing or to object to processing of your personal data; and
• request data portability (i.e., to request the transfer of personal data from one data controller to another)
• withdraw your consent where consent is the only lawful basis for processing

If you wish to exercise any of these rights or withdraw consent to use your personal data, you should contact the Data Protection Officer using the details provided below. You also have the right to lodge a complaint about the processing of your personal data with your local data protection supervisory authority. In the UK, this is the Information Commissioner’s Office.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

We may contact you periodically to provide information regarding events, products, services and content that may be of interest to you and to invite you to participate in market research. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. Where this information is provided electronically, we may track your response, for example, which emails you open.

We may share your data with selected third parties for marketing communications, market research, analysis, and to profile and extend our databases by appending additional information to existing information we may already hold about you as our client.

If you wish to stop receiving marketing or market research communications from Investec Wealth & Investment (UK), you can click on the unsubscribe link in the marketing communication or contact unsubscribe@investecwin.co.uk.

We will take steps to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held. Subject at all times to applicable laws, we will retain your personal data for as long as permitted or required for legal, regulatory, fraud prevention and our legitimate business purposes.

By using our website, the online service or any other online facility or service provided by us, you acknowledge that we may:

• collect information about your computer or device (for example, your IP address, operating system and browser type) for security purposes and to administer and monitor our online services; and/or
• use cookies and similar technologies (including those referred to in the Online Terms in relation to the online service) for security purposes, and where this is essential to provide you with services you have requested; and to monitor and personalise our online services.

The use of cookies is more fully set out in our Online Cookie Policy, which is available on our website.

All enquiries, requests or concerns regarding this Notice or relating to the processing of personal data, should be sent to the Data Protection Officer using the following contact details:

Investec Wealth & Investment (UK)
30 Gresham Street
London
EC2V 7QN
United Kingdom

Email: Data.Protection@investecwin.co.uk 

To comply with Article 27 of the GDPR, we have appointed a European representative which can accept communications on behalf of Investec Wealth & Investment (UK), in relation to personal data processing activities falling within the scope of the GDPR. If you wish to contact them, their details are as follows:

GDPR Representative

Bird & Bird GDPR Representative Services SRL
Avenue Louise 235
1050 Bruxelles
Belgium

Email: EURepresentative.Rathbones@twobirds.com