Last updated: December 2022
Protecting your personal information is extremely important to LGIM Managers (Europe) Limited (“LGIM”) and its affiliates (the “LGIM Group”). The way we collect and share your information is equally important. Our professional business clients and prospects expect us to manage their information privately and securely. If we do not, they may lose trust in us.
This policy tells you how we collect and process your personal information. Please take a few minutes to read it, and show it to anyone else whose data you have shared with us, or the business relationship.
We are a global asset management business and are at the forefront of global index fund management. We are also leading developments in investment solutions for defined benefit and defined contribution pension schemes. We adhere to applicable data protection regulations in the regions we operate, including those provided under the Data Protection Act 2018, the UK GDPR in the UK and the applicable jurisdictional incorporation of the GDPR in the European Union.
The controller of the personal data processed in relation to the website is LGIM Managers (Europe) Limited, 70 Sir John Rogerson’s Quay, Dublin, 2, Ireland which is a member of the LGIM Group.
What does this policy cover?
What is personal information?
When we talk about personal information we mean information about an individual that can identify them, such as their name, address, e-mail address, telephone number, IP address and financial details. It can relate to customers, employees, shareholders, business contacts and suppliers. Any reference to “information” or “data” in this policy is a reference to personal information about a living individual.
What information do we hold?
We may collect and process the following personal information about you. In most cases this will be limited to business information that relates to you, how these have an impact on our products and services that may be of interest to you and how we manage our relationship:
|Type of data
|Examples of how we use it
Documentary data & national identifiers
Where do we get our information from?
Information you give us directly (when you fill in forms or contact us by phone, e-mail etc.).
How do we use your information?
We use information we collect automatically when you visit our website for several purposes. We use this information to be able to deliver the website to your computer. For this purpose, your IP address must be stored for the duration of your visit to the website. We also use this information to ensure and enhance the functionality of the website and to ensure the security of our information technology systems. We will not use the information we collect automatically when you visit our website for marketing purposes.
We use any other personal information that we hold about you to carry out our responsibilities resulting from any business or commercial agreements you have entered into with us, and to provide you with the information, products and services that you have asked from us.
We also will use your personal information to provide you with business to business marketing information about services and products we offer across the LGIM Group which may be of interest to you.
Additionally we use this personal information to tell you about changes to our services and products, to comply with any applicable legal or regulatory requirements (including to comply with any applicable regulatory reporting or disclosure requirements) and to run our business in an efficient and proper way. This includes testing our systems, managing our financial position, business capability, planning, communications, corporate governance, and audit. We may also use your personal information for any other purpose that we have agreed with you from time to time.
Using your information in accordance with data protection laws
- Necessary to complete a contract with you: We will process your personal information to carry out our responsibilities resulting from any commercial agreements or contracts you have entered into with us and to provide you with the information, products and services you have asked from us, which may include online services.
- Complying with legal obligations: We may process your personal information to comply with any legal obligation we are subject to.
- Consent: We may process your personal information for different purposes where you have provided your informed consent to do so (e.g. collecting your preferences when we plan and host conferences and seminars).
- Carry out market research and product development.
- Develop and test the effectiveness of marketing activities.
- Develop, test and manage our brands, products and services.
- Study and also manage how our professional business clients use products and services from us and our business partners.
- Manage risk for us and our customers.
Please be aware that the personal information you provide to us, and which we collect about you, is required for us to be able to provide our services to you and without it we may not be able to do so.
Change of Purpose
We will only use your personal data for the purpose for which it was collected or for reasons that are compatible with the original purpose for which it was collected. .
Where we need to use your personal data for another purpose that is unrelated to the original one, we will notify you and explain to you the legal basis that allows us to do so.
How long do we keep your information for?
We’ll keep your personal information in accordance with our internal retention policies. We’ll determine the length of time we keep it for based on the minimum retention periods (usually 7 years) required by law or regulation. We’ll only keep your personal information after this period if there’s a legitimate and provable business reason to do so.
We may use the information that you provide us with to market and advertise certain products and services to you. We may use your contact data, personal details, preferences and public data to form a view of what products/services we believe that you would be interested in. We may market similar products/services to you as you have previously purchased from us where it is in our legitimate interest to market these products/services to you. We may also send marketing communications to you where you have consented to us doing so.
You can opt-out of marketing and request us to stop sending you marketing messages at any time by getting in touch with your local representatives, following instructions provided to you or replying to marketing messages.
Who do we share your personal information with?
We will only disclose your information to:
- Other companies within the LGIM Group, third-party suppliers, contractors and service providers for the purposes listed under “How do we use your information” above.
- Our regulators, government and law enforcement or fraud prevention agencies.
Additionally, we may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our professional business clients will be one of the transferred assets.
- If you have been dealing with a financial adviser (e.g. employer broker consultant), we will provide information about your product and, where appropriate, with other information about your dealings with us, to enable your adviser to give you informed advice.
- In order to enforce or apply the terms of any contract with you.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or regulatory requirements, or otherwise for the prevention or detection of fraud or crime.
- To protect you and LGIM from financial crime, LGIM may be required to verify the identity of new and sometimes existing professional business clients. This may be achieved by using reference agencies to search sources of information relating to you (an identity search). This will not affect your credit rating. If this fails, LGIM may need to approach you to obtain documentary evidence of identity.
- In accordance with the terms of business agreement, we may perform credit checks on certain types of professional business clients (e.g. directors of intermediary firms).
LGIM may need to check your details with fraud prevention agencies (e.g. we have to screen at firm and director level of anyone we remunerate). If false or inaccurate information is provided and fraud is identified details will be passed to fraud prevention agencies or law enforcement agencies. Please contact the Financial Crime department if you wish to receive the relevant details of the fraud prevention agencies:
Address: Financial Crime, 7th Floor, Brunel House, 2 Fitzalan Road, Cardiff CF24 0EB
Transferring your data outside the EU and Switzerland
We will only transfer your data to a recipient outside the UK or EEA where permitted to do so by law (for instance, where the transfer is based on standard data protection clauses adopted or approved by the European Commission). In the event we rely on the use of data protection contract clauses we will also ensure data protection risk assessments are carried out. Please note that sending information via e-mail is not completely secure; anything you send is done so at your own risk. Once received, we will secure your information in accordance with our security procedures and controls.
How do we keep your personal information secure?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. We limit access to your personal information to those individuals who have a business need to access it. As part of our security measures, we may sometimes require you to give proof of your identity before we disclose personal information to you.
We regularly monitor our systems for possible vulnerabilities and attacks and carry out tests to identify ways to further strengthen our security. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
You have rights under data protection law that relate to the way we process your personal data. More information on these rights can be found on your country Data Protection Authority’s website. If you wish to exercise any of these rights, please get in touch with your relationship manager or your customer services team. Alternatively, you can use the Contact Us section of our consumer website or the adviser, employer or institutional websites. Details of all other LGIM websites can be found on our LGIM Group website.
- The right to access the personal data that we hold about you.
- The right to make us correct any inaccurate personal data we hold about you, or, your right to request a note of contestation is made in relation to the personal data held about you.
- The right to make us erase any personal data we hold about you. This right will only apply where for example:We no longer need to use the personal data to achieve the purpose we collected it for
- You withdraw your consent if we use your personal data based on that consent
- Where you object to the way we use your data, and there is no overriding legitimate interest
- The right to restrict our processing of the personal data we hold about you. This right will only apply where for example:
- You dispute the accuracy of the personal data we hold
- You would like your data erased, but we require to hold it in order to stop its processing
- You have the right to require us to erase the personal data but would prefer that our processing is restricted instead
- Where we no longer need to use the personal data to achieve the purpose we collected it for, but you need the data for legal claims.
- The right to object to our processing, or disclosure to third parties, of personal data we hold about you (including for the purposes of sending marketing materials to you).
- The right to receive personal data, which you have provided to us, in a structured, commonly used and machine-readable format. You also have the right to make us transfer this personal data to another organisation.
- The right to withdraw your consent, where we rely on it to use your personal data.
- The right for you not to be subject to a decision based solely on an automated process, including profiling, which produces legal effects concerning you or similarly significantly affect you. We do not carry out any automated processing or profiling.
- The right to give us instructions regarding the management of your personal information in the event of your death.
- If neither the correctness nor the incorrectness of the personal data in question can be established, you may request that a note of contestation be made.
Contacts and complaints
If you have any concerns about the way we process your personal data, or are not happy with the way we handled a request by you in relation to your rights, you also have the right to make a complaint to your country Data Protection Authority.