Stewart Investors is a trading name for the companies listed below:
First State Investments (UK) Limited*
First State Investment Management (UK) Limited*
First State Investment Services (UK) Limited
First State Investments (UK Holdings) Limited
First State Investments International Limited *
*Authorised and regulated by the Financial Conduct Authority of the United Kingdom
We will act to protect your personal information in accordance with local law and this policy statement.
This policy gives information on how Stewart Investors protects the personal information held about you. Personal information is information or opinion that allows others to identify you. It includes your name, age, gender and contact details, as well as your health and financial information.
At Stewart Investors the privacy of your personal data is important to us. We collect personal data to make and maintain investments on your behalf or on behalf of your clients in funds managed by us, as well as to provide you with information about other products and services we offer. In some circumstances the law may also require us to collect personal data. The Data Protection Act 1998 (“the Act”) defines personal data as data “which relate to a living individual who can be identified:
(a) from those data; or
(b) from those data and other information which is in the possession of, or is likely to come into the possession of the data controller
and includes any expression of opinion about the individual and any indication of the intentions of the data controller or any other person in respect of the individual”. Stewart Investors is bound to protect your personal data in accordance with the Act and the principles contained therein.
How is your personal data dealt with?
In the course of doing business we outsource certain tasks to third party administrators or agents. These third parties are bound by confidentiality arrangements when handling your personal data. Your personal data may also be used by us to administer, monitor and evaluate products and services, inform you about promotional activities, gather, aggregate and report statistical information, assist you with any queries and take measures to detect and prevent fraud and other illegal activity. We may also be allowed or obliged to disclose information by law or by the rules of any applicable regulatory body or otherwise where you have given your consent.
If you used a financial advisor in relation to your investment (as indicated on your application form) then details of your investments may also be provided to such financial advisor (or any replacement or additional advisor which you inform us of).
We aim to ensure that the personal information we retain about you is accurate, complete and up to date. If you provide us with incomplete or inaccurate information, we may not be able to provide you with the products or services you are seeking.
What personal data do we collect?
Stewart Investors collects personal data on investors, clients, intermediaries and business contacts via application forms, other Stewart Investors forms, investment management agreements, correspondence, business cards, phone, fax, e-mail and on-line. Personal data collected may include:
- Job Title
- Date of birth
- Contact details
- National Insurance Number/other tax details
- Bank account information
- Investment information
- Responses to surveys, competitions and prizedraws
The main purpose for Stewart Investors collecting your data is to make and maintain investments on your or your client’s behalf in funds managed by us. If you would like to receive further information from us about other products or services offered by Stewart Investors please ensure you tick the relevant box on the appropriate application form or contact us by emailing us at email@example.com.
Personal data quality
We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date. Please contact us by e-mailing us at firstname.lastname@example.org or writing to Client Services at 23 St Andrew Square, Edinburgh, EH2 1BB if any of the details you have provided change. Please also contact us if you believe that the information we have about you is not accurate, complete or up to date.
Personal information security
We are committed to keeping the personal data you provide to us secure. We take all reasonable precautions to protect the personal data we hold about you from misuse and loss and from unauthorised access, modification or disclosure. We have a range of physical and technological policies and procedures in place to provide a robust security environment. We seek to ensure the ongoing adequacy of these measures by regularly reviewing them. Our security measures include, but are not limited to: restricting access to our computer systems and physical records to authorised persons and preventing users from accessing information they have no need to access; requiring employees to use unique passwords to gain access to systems which are changed regularly; encrypting any data you send us over the internet when logging on to our website; employing firewalls, intrusion detection systems and virus scanning tools to prevent unauthorised persons and viruses from entering our systems; using dedicated secure networks or encryption when we transmit electronic data for purposes of outsourcing; providing secure storage for physical records; and detecting and preventing unauthorised access to buildings by employing physical and electronic means such as alarms and cameras.
We use analytics cookies to collect information on website activity, such as the number of users who visit our website, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering our website from another website, the address of that web site. This information on its own does not identify an individual but it does provide us with statistics that can be used to analyse and improve our website.
The browsers of most computers, smartphones and other web–enabled devices are usually set up to accept cookies. If your browser preferences allow it, you can configure your browser to accept all cookies, reject all cookies, or notify you when cookies are set. Each browser is different, so check the “Help” menu of your browser to learn about how to change your cookie preferences.
However, please remember that cookies are often used to enable and improve certain functions on our website. If you choose to switch certain cookies off, it will affect how our website works and certain functionality may not work.
More information about cookies can be found on www.allaboutcookies.org.
Links to other web sites
Our website may contain links to non Stewart Investors web sites (evident by the use of the external link). While such links are provided for your convenience, you should be aware that the information handling practices of the linked websites might not be the same as ours. You should review any privacy policies on those linked websites. We are not responsible for any linked websites.
We monitor and record telephone calls for training and security purposes.
Access to your personal data
If you wish, you may also have a copy of the personal data held on you by Stewart Investors. Stewart Investors is allowed, by law, to charge you a fee for this. If you would like to exercise this right, please put your request in writing to:
23 St Andrew Square
Stewart Investors will respond promptly and in any event within 4 days, to a request by you for a copy of personal data held. If we deny access to your personal information, we will, unless prevented by law or regulation, let you know why.
How the Commonwealth Bank Group handles your personal information
The entities trading as Stewart Investors are wholly owned subsidiaries of the Commonwealth Bank of Australia Group (the “Group”). The Group is a collection of related organisations that provide banking, finance, insurance, funds management, financial planning and advice, superannuation, stockbroking and other services.
We value your trust, and aim to help you manage and build wealth over a long period. The protection of your personal information is a vital part of this relationship. It is supported by our long experience of keeping personal information confidential.
We collect personal information to provide you with the products and services you request, as well as information on other products and services offered by or through us.
The law may also require us to collect personal information in certain circumstances. We will tell you who collects the personal information, advise you of their contact details, your right of access to that information, and what will happen if you choose not to provide this information.
Personal information may be used and disclosed within the Group to administer our products and services, as well as for prudential and risk management purposes and, unless you tell us otherwise, to provide you with related marketing information. We also use the information we hold to help detect and prevent illegal activity. We co-operate with police and other enforcement bodies as required or allowed by law.
We disclose relevant personal information to external organisations that help us provide services. These organisations are bound by confidentiality arrangements. They may include overseas organisations.
You can seek access to the personal information we hold about you. If the information we hold is inaccurate, incomplete or outdated, please inform us so that we can correct it. If we deny access to your personal information, we will, unless prevented by law or regulation, let you know why.
If you have any questions or would like further information on our privacy and information handling practices, please contact us.