This page contains the information gathering and use policies adopted by Smith & Williamson ("Smith & Williamson", "we", "us", "our") in connection with this website (the "Site"). References to Smith & Williamson shall include Smith & Williamson Holdings Limited of 25 Moorgate, London EC2R 6AY and bodies corporate and partnerships controlled by it (directly or indirectly). References to "you" and "your" are references to a user of our website.
Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. We are committed to protecting and respecting your privacy and handling your information in an open and transparent manner. These policies are subject to periodic review and any changes will be included within this section of the site.
In this Privacy Statement, your information is sometimes called "personal data". We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as "processing" such personal data.
In this Privacy Statement the term "Data Protection Legislation" means the EU General Data Protection Regulation 2016/679; together with all other applicable legislation relating to privacy or data protection.
For the purposes of Data Protection Legislation the data controller is Smith & Williamson.
- What personal information do we collect and how do we use it?
- Sensitive personal data
- How we use your information
- Legal grounds for using your personal information
- Provision of information to third parties
- Retention of information
- Protecting and storing your information
- Your Rights
- Opting Out
- Changes to privacy statement
1. What personal information do we collect and how do we use it?
Personal information (which includes 'personal data' as defined in Data Protection Legislation) is generally collected so we can deliver requested materials or information.
Your Internet Protocol (IP) address. The IP address indicates the location of your computer on the Internet and is used to connect your computer to the Internet. This information may be aggregated to provide statistical information about the users of our Site. No individual user will be identifiable from such information, which is used to ensure the Site reflects the needs of users. Whilst IP addresses may be categorised as personal information, we do not use this data to track your session.
Your browser type and language;
When you register with us, use our services, book to attend an event or submit a subscription request (e.g. to receive a newsletter or for marketing information), make an enquiry (either by submitting an online enquiry form or by corresponding with us by phone, e-mail or otherwise), and/or if you apply to work for Smith & Williamson, you may be asked to provide some personal information such as your name and contact details (including telephone number, home address, date of birth and email address) and website registration credentials (username and password). Smith & Williamson does not require registration for access to the Site in general but you may be asked to register to access certain areas. Please note that if you send us your CV, you may be asked to provide us with certain additional sensitive personal data. For more information, please see paragraph 2 headed "Sensitive Personal Data" below.
Your postings on any other social media applications. Depending on your settings or the privacy policies for social media and messaging services such as Facebook, LinkedIn and Instagram you might give us permission to access information from those accounts;
Information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.
We may also, from time to time while you are accessing the Site, request you to complete a survey form which may relate either to your use of the Site and/or information posted on the Site.
Your personal information is necessary to enable Smith & Williamson to deal with your enquiry, but additional information may be requested to help us to provide the most appropriate response. If such additional information is requested, it is highlighted and its provision is voluntary.
We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with Data Protection Legislation and as set out in this Privacy Statement.
We may collect and process the following types of personal information about you:
2. Sensitive Personal Data
When you apply for one of our jobs, you will need to register with us and submit an application. Data Protection Legislation gives special protection to certain types of sensitive information (which includes 'sensitive' or 'special categories' of personal data as defined by Data Protection Legislation). Special categories of personal data can include data about your race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record. You should only provide this information if it is required in response to a mandatory question on our registration form, or if you are otherwise content for us to process this information in accordance with the terms of this Privacy Statement. Where you do provide sensitive information this will be accepted as explicit consent to Smith & Williamson to use that information in connection with the purpose for which it has been provided.
4. How we use your information
Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customised experience and to provide the services you have requested. We may also use the information that you have provided to ensure that the content on our Site is presented in the most effective manner for you and your computer.
We use your information for the following specific purposes:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to notify you about changes to our service;
- to ensure that content from our Site is presented in the most effective manner for you and for your computer;
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- as part of our efforts to keep our Site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to consider your application where you have applied for a position with us; and
- to send you our newsletter or updates, or to make suggestions and recommendations to you and other users of our Site about services that may interest you or them; and provide you or them with targeted marketing in relation to our services (unless you or they indicate at any time that you or they do not wish us to do so); and
- When requesting material or asking someone to contact you, you will have the option to request other information that may be of interest.
5. Legal grounds for using your personal information
The law permits us to process your personal data in the way that it does because the processing is:
- necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business, to discharge our legal obligations, to store and disclose information where necessary and to evaluate, develop and improve our services; or
- necessary for the performance of a contract with you; or
- necessary in order to comply with a legal obligation to which we are subject.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that personal data; (ii) you have made the personal data manifestly public; or (iii) the processing is necessary for the establishment, exercise or defence of legal claims.
6. Provision of information to third parties
Information is normally only provided to a third party if it is required in order to deal with your enquiry, but there may be other circumstances where it is necessary for Smith & Williamson to provide information, including as a result of legal or regulatory process.
The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy Statement:
third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our products and services, respond to your enquiries or for any other related purposes;
analytics and search engine providers that may assist us in the improvement and optimisation of our Site;
third parties who support our information technology or handle mailings or events on our behalf;
law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
any successor in interest, in the event of a liquidation or administration of Smith & Williamson.
Smith & Williamson does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.
The Site contains links to other websites. Smith & Williamson is not responsible for the privacy policies of third party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered via, the Site.
8. Retention of information
We will only keep the information we collect about you, through your use of the Site or otherwise, for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
9. Protecting and storing your information
We take your online security seriously and have implemented generally accepted standards of technology and operational security to protect your personal information from loss, misuse, alteration or destruction. Once we have received your information we will ensure that the collection and use of it is in accordance with Data Protection Legislation. All personnel of Smith & Williamson are required to keep personal information confidential and only authorised persons have access to such information.
Please note, however, that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though the Site.
Data that you submit via our website is sent to and stored on secure servers owned by or operated for us.
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA”), to a country not deemed to provide adequate protection of your information by the European Commission, and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers, related companies, agents or contractors. Such transfers may be made in order to improve our Site or to assist in our security or fraud protection activities.
When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the European Economic Area. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. We do not generally rely on your consent as the legal basis for transferring your personal data outside the EEA, however where we feel it is necessary or appropriate we may seek to rely on your consent as the legal basis for such processing. Where we do, you may withdraw your consent at any time in the manner described below.
10. Your rights
At any time, you have the right:
- to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from whom it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
- to request access to or a copy of any personal data which we hold about you;
- to rectification of your personal data, if you consider that it is inaccurate;
- to ask us to delete your personal data, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
- to restrict processing of your personal data;
- to data portability (moving some of your personal data elsewhere) in certain circumstances;
- to object to your personal data being processed in certain circumstances; and
- not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
11. Opting Out
You have the option of "unsubscribing" from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you. To unsubscribe just visit www.smithandwilliamson.com/subscribe and update your preferences. In addition, each electronic mailing we send you will contain details of how you can unsubscribe by clicking on the ‘unsubscribe’ link in the email.
Please note that it may take up to one month to action your request.
If you have any concerns or questions about the security of our Site, this Privacy Statement or any personal information we collect from you, please do not hesitate to contact our Marketing Department on +44 (0)207 131 4000.
Additionally, if you have any concerns about our use of your information, you also have the right (as a UK resident) to make a complaint to the Information Commissioner's Office, which regulates and supervises the use of personal data in the UK, via their helpline on +44 (0)303 123 1113. If you are receiving services in Ireland you can contact the Data Protection Commissioner in Ireland on +353 (0761) 104 800.
13. Changes to Privacy Statement