Privacy Policy 

As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide. 

This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records. 

“We”, “Us” “Our” refers to the Partner named on this website. 

Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy 

1. About us

In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a “data controller”.  Grayson Lewis on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management. 

2. Our processing of your personal information

Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.

Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.
We also use details of any unspent criminal convictions for fraud prevention purposes.
Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.
In order to make this notice as user friendly as possible, we have split it into different sections. Please click on the section below that best describes your relationship with us.

Prospective clients

This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system.

What personal information may we collect?

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.
• Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters, bank statements and evidence of benefit entitlement.
• Employment information such as job title, employment history and professional accreditations.
• Financial information:
  • Bank details
  • Financial reviews (fact finds)
  • Information relating to your personal finances such as your financial liabilities and assets, income and outgoings
  • Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders.
• Information relevant to the services we provide such as:
  • previous and current investments
  • information about your lifestyle
  • attitude to investment risk
  • existing plan details
  • objectives
  • copies of your will
  • information about any trusts you have
• Information about your family including information about your dependants.
• Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 7 below.
• Information obtained during telephone recordings.
• Information we may have gather from publicly available sources such as the electoral roll, internet search engines and social media sites such as LinkedIn where you have been flagged as a PEP and we need to carry out enhanced due diligence.

What special categories of personal information may we collect?

• Details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
• We may collect details about your health which are relevant to your application (e.g. as part of a pension or income protection need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client) or where you have disclosed such information to us because it explains your risk appetite for investments.
• In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.

How will we collect your personal information?

We will collect information directly from you when:

• you enquire about or apply to receive our wealth management services; and
• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
• St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found at www.sjp.co.uk/site-services/privacy

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “Lawful Basis” when we process your “personal information”:

• We need to use your personal information to enter into the client agreement, for example, we need to use your personal information to assess whether we can provide services to you and to set you up as a client on the St. James’s Place client relationship management system.
• We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you and we are required to report to St. James’s Place on our relationship with you.
• We have a valid business reason to use your personal information and which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis. In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you certain advice or financial products unless we have your health information.
• There is a substantial public interest such as prevention and detection of fraud.
• We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your special categories of personal information
To verify your information.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to verify your identity).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise or defend legal rights.
To comply with our legal or regulatory obligations.	We need to use your information in order to comply with our legal obligations.	We need to use your information in order to establish, exercise or defend legal rights. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To set you up as a client on client relationship management systems and to communicate with you in respect of your application and service preferences.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to establish you as a client).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
For business purposes and activities including maintaining business records, file keeping and strategic business planning.	We have a valid business reason (to run our business efficiently and effectively).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights
To provide marketing information where you have provided your consent.	You have given us your explicit consent.	Not applicable
To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent.	We have a valid business reason (to send you selected communications about other products and services we offer).	Not applicable
To provide improved quality, training and security (for example, through recorded or monitored phone calls to our contact numbers, or carrying out customer satisfaction surveys).	We have a valid business reason (to develop and improve the products and services we offer).	You have given us your explicit consent.

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.
• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found at www.sjp.co.uk/site-services/privacy.
• Third parties who provide sanctions checking services including Experian.
• Compliance consultants including the Consulting Consortium.
• Financial crime and fraud detection agencies.
• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
• Selected third parties in connection with any sale, transfer or disposal of our business.
• Our insurers.
• The police, HMRC and other crime prevention and detection agencies.
• Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

Existing clients

This section will apply if you currently receive wealth management services from us. This section will set out how we use your information.

What personal information may we collect?

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.
• Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters or bank statement and evidence of benefit entitlement.
• Employment information such as job title, employment history and professional accreditations.
• Financial information:
  • Bank details
  • Financial reviews (fact finds)
  • Information relating to your personal finances such as your financial liabilities and assets, income and outgoings
• Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders or where you have been flagged as a PEP.
• Information relevant to the services we provide, such as: o previous and current investments o information about your lifestyle
  • attitude to investment risk
  • existing plan details
  • objectives
  • copies of your will
  • information about any trusts you have
• Information contained in client review meeting records and file notes
• Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
• Information about your family including information about your dependants.
• Information obtained during telephone recordings where applicable.
• Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 7 below.
• Your marketing preferences and details of your customer experience with us.
• Information which we have gathered from publicly available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and we need to carry out enhanced due diligence.

What special categories of information will we collect?

• Details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences 9 which you are subject to.
• We may collect details about your health which are relevant to your application (e.g. as part of a pension need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client or where we are applying for income protection insurance we will need to ask you about any medical conditions and information about lifestyle choices such as whether you drink alcohol or smoke so that appropriate insurance can be obtained) or where you have disclosed such information to us because it explains your risk appetite for investments.
• In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.

How will we collect your personal information?

We will collect information directly from you when:

• you register to receive our services and complete and return to us all applicable application forms; and
• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
• Any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.
• St. James’s Place group companies.
• Third parties such as Experian who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services.

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “Lawful Basis” when we process your “personal information:

• We need to use your personal information to enter into or perform the client agreement that we hold with you. For example, we need to use your personal information to provide our services, to arrange and implement recommendations, review your ongoing suitability of current arrangements and handle claims.
• We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
• We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis.

In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

• You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you certain advice or financial products unless we have your relevant health information.
• There is a substantial public interest such as prevention and detection of fraud.
• We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.

Purpose for processing	Lawful Basis for using your personal information	Lawful Basis for using your special categories of personal information
To carry out identification checks and checks against sanction lists and politically exposed persons (PEP) screening.	It is necessary to enter into your client agreement. We have a valid business reason (to carry out necessary compliance checks). We have a legal and regulatory obligation.	It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise or defend legal rights. You have given us your explicit consent.
To verify your information throughout the course of our services.	It is necessary to enter into or perform your client agreement. We have a legal and regulatory obligation. We have a valid business reason (to verify your identity and to undertake client due diligence throughout the course of our relationship).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud). We need to establish, exercise or defend legal rights.
To set you up as a client on the St. James’s Place client relationship management system and to communicate with you in respect of your service preferences.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to establish you as a client).	You have given us your explicit consent. It is in the substantial public interest to prevent or detect unlawful acts (where we suspect fraud).
To provide services in accordance with your client agreement.	It is necessary to enter into or perform your client agreement. We have a valid business reason (to ensure that we fulfil our contractual obligations to clients).	You have given us your explicit consent. We need to use your information in order to establish, exercise or defend legal rights.