This statement sets out how Hermes Investment Management is committed to protecting the privacy and security of your personal data (“personal information”). This notice gives individuals information on how their personal information (i.e. information which directly or indirectly identifies you) is processed.
This statement also sets out why we use your personal information (as a controller) and how you may contact Hermes Investment Management in relation to the use of your personal information.
Who are Hermes Investment Management?
Hermes Investment Management provides world class active investment management and stewardship services. Our goal is to help people invest better, retire better and create a better society for all, in line with our pledge. Hermes Investment Management will conduct the firm's business in accordance with the highest ethical standards, respecting the firm's customers, suppliers, and other business counterparties, dealing responsibly with the firm's assets, and complying with applicable legal and regulatory requirements. Hermes Investment Management consists of Hermes Fund Managers Limited and its subsidiaries including its joint venture Hermes GPE LLP (and its subsidiaries).
Collecting your personal information
We may collect certain personal information with respect to the representatives of institutional clients, other business relationships and employees/applicants, by way of example:
- Name and contact details
- Tax information
- Nationality, passport or other identification documents
- Details of role responsibilities
- Information on investigations, litigation, court proceedings, civil liabilities or criminal convictions against you
- Employee information required for HR purposes (including payroll, job history)
- Where permitted, information received from credit reference agencies, fraud prevention agencies and from other public sources such as Companies House, and
- We monitor and/or record your telephone calls and electronic transactions.
How we will use your personal information
We will use your personal information for:
- The provision of products and/or services to clients or investors in our funds
- Managing business relationships with you
- Archiving documents (electronic and paper based)
- Detecting and preventing fraud and/or money laundering
- Statistical analysis and assessment,
- Job applicants, employee and training records
- Communicating with you, and
- Otherwise as is necessary to comply with applicable laws, regulations and/or codes of practice.
The provision of personal information by you may be necessary in order for us and other third parties (to which personal information is disclosed) to provide you with the requested services, for the performance of any contractual relationship with you and for the other purposes as set out in this notice where in our legitimate interests.
How we disclose your personal information
We may disclose certain personal information:
- To Hermes Investment Management which consists of Hermes Fund Managers Limited and its subsidiaries including its joint venture Hermes GPE LLP (and its subsidiaries)
- To courts, governmental and non-governmental regulators, tax authorities and ombudsmen
- To law enforcement agencies or as otherwise required under law or regulation;
- To any third party that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or a part of its business, whether by merger, acquisition, reorganisation or otherwise
- To credit reference agencies who may use it to perform credit reporting and affordability checks for us and to verify your identity (e.g. age and residence), and to prevent and detect criminal activity, fraud and money laundering and
- To fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, and
- To our agents, advisers or outsource providers in order to provide agreed products or services.
International transfer of information
We may transfer your personal information to recipients (including affiliates of Hermes Investment Management) located in countries outside of the European Economic Area (“EEA”) including in USA, Singapore, Channel Islands, Cayman Islands, Mauritius, India, Philippines, Canada and Australia. In those instances we will take all necessary steps to protect your personal information in accordance with applicable data privacy laws.
Your rights
Under applicable EU data privacy laws, you may have a right to:
- Request access to and rectification or erasure of your personal information
- Obtain restriction of processing or to object to processing of your personal information, and
- Data portability (i.e. to request the transfer of personal information from one data controller to another in certain circumstances).
If you wish to exercise any of these rights you should contact Hermes Information Protection Coordinator as described below. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority.
Marketing
As a representative of a client, we may contact you occasionally to inform you of products and services we and other members of Hermes Investment Management provide. We will also respond to enquiries for the request of information.
The Hermes Investment Management website provides a convenient method to discontinue electronic communication via an "unsubscribe" link tick box via emails. Alternatively you can contact Hermes Investment Management at marketing@hermes-investment.com to unsubscribe.
When visiting our websites, we collect information about you using cookies in order to process your visit, remember your preferences, increase security and analytics on how a visitor uses the website. Further details can be viewed at https://www.hermes-investment.com/cookies/
Security and data retention
Hermes Investment Management strives to maintain the reliability, accuracy and completeness of all personal information it holds to protect privacy and security at all times. The security measures in place on our websites and computer systems aim to prevent the loss or misuse of the information we hold including 3rd parties.
We update and test our security and technology on an ongoing basis. Access to personal information is restricted to those employees responsible for providing benefits or services to you. Employees at Hermes Investment Management are regularly trained on the importance of confidentiality and keeping your information is kept private and secure.
Subject at all times to applicable laws, we will retain your personal information for a period up to 7 years from the end of the relationship.
Changes to this privacy notice
We may revise and/or supplement our privacy notice from time to time to reflect (including but not limited to), any changes in our business, law, regulation, markets and/or the introduction of any new technology.
Enquiries, requests or concerns
All enquiries, requests or concerns regarding this notice or relating to the processing of your personal information, should be sent to the Information Protection Coordinator at Hermes Investment Management at 150 Cheapside, London EC2V 6ET or via e-mail to InfoProtect@hermes-investment.com
Last updated 23 May 2018