Where a word appears in bold text in this policy, the definition can be found here
“Media Databases” means the third party hosted media intelligence databases we subscribe to, such as Roxhill and Gorkana, which contain journalist and media contacts (including journalists, bloggers and other media outlets).
“Schroders”, “we” or “us” means Schroders plc with its registered office at 1 London Wall Place, London EC2Y 5AU or any of its subsidiaries or affiliates, details of which can be found on the Schroders website. Together these are referred to as the Schroders Group.
“Schroders Websites” means the websites operated by Schroders.
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Schroders (or its representatives or service providers). In addition to factual information such as a name or address, it could include an expression of opinion about or an indication of intention in respect of an individual.
“You” means each individual to whom this notice is addressed, who may be:
(a) a journalist or other media contact; or
(b) an employee, director, officer or representative of a media outlet or other organisation with which we have a business relationship.
(1.1) Schroders collects and uses certain Personal Data. Schroders is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
(1.2) At Schroders, we respect your privacy and we are committed to keeping your Personal Data secure.
2. Overview of circumstances in which we handle your personal data
(a) Information we receive through our Media Databases;
(b) Information that you provide to us;
(c) Information we obtain from other sources; and
3. The types of personal data we collect
(3.1) We will collect and process the following Personal Data in the course of carrying on our commercial PR and media related activities:
- Information we receive through our Media Databases.
- any other Personal Data that you provide to us via enquiries, when you interact with us through Schroders Websites or during telephone and email communications with us.
- information received from media and PR agencies acting on our behalf.
4. How we use your information
(4.1) Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- for the management and administration of our business;
- to keep our records up to date and for the administration and maintenance of Media Databases storing your Personal Data;
- to keep you informed via telephone, email and press releases of information about Schroders that might be of interest;
- to call or return a call from journalists and other media contacts following an enquiry;
- to communicate with you and introduce our spokespeople to journalists;
- to effectively manage and strengthen our relationship with you;
- to correct inaccuracies in stories written by journalists; or
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures.
(4.2) When we use your Personal Data, we comply with applicable law. The law allows or requires us to use your Personal Data for a variety of reasons. These include instances where:
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or those of our Clients or for the purpose of legal proceedings;
- we have obtained your consent;
- the use of your Personal Data as described is necessary for our legitimate business interests, such as:
5. Disclosure of your information to third parties
(5.1) We may share your Personal Data within the Schroders Group for the purposes described above.
(5.2) We may also share your Personal Data outside of the Schroders Group as further described below:
- with business partners of ours where they are contractually obliged to comply with appropriate data protection obligations;
- with third party agents and contractors for the purposes of them providing services to us (for example, Schroders’PR agencies). These third parties will be subject to appropriate data protection obligations; and
- to the extent required by law or regulation, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators, auditors or public authorities), or to establish, exercise or defend our legal rights.
6. International transfers of personal data
(6.1) Schroders is a global business with operations around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Datato locations outside of your country.
(6.2) Where we transfer your Personal Data to another country it will be protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the European Economic Area (the “EEA”), for example, this may be done in one of the following ways:
- the country to which we send your Personal Data might be approved by the European Commission as offering an adequate level of protection for Personal Data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging it to protect your Personal Data;
- in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA.
(6.3) You can obtain more details of the protection given to your Personal Data when it is transferred outside the EEA by contacting us as described in paragraph 12 below.
7. How we safeguard your personal data
(7.1) Data is a critical business asset and must be protected appropriate to its risk as well as its importance or value. Information stored on our Media Databases can only be accessed via a secure and password protected site. We operate layers of safeguards and defences designed to ensure that Schroders is able to operate safely. We have extensive controls and mechanisms in place designed to detect, respond and recover in case of any adverse events that may arise.
8. How long we keep your personal data
(8.1) The length of time for which we hold your Personal Data will vary as determined by the following criteria:
- our legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
9. Your rights
(9.1) In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
- the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
- the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain your Personal Data to comply with a legal or regulatory obligation or to satisfy our internal audit requirements;
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit such data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Schroders;
- the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are required or entitled to retain it;
- the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are required or entitled to refuse that request; and
- the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
(9.2) You can exercise your rights by contacting us using the details provided at paragraph 12 below.
10. Schroders websites and other websites
12. Questions and concerns
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.