Equiniti Share Plan Trustees Limited For GESPP, SAYE, And SIP

Equiniti Share Plan Trustees Limited (ESPTL) is one company within the Equiniti Group. Our main business is provision of Employee Share Plan services.

Our registered address is Highdown House, Yeoman Way, Worthing, BN99 3HH and our Information Commissioner’s Office (ICO) registration number is Z7941663.

This Privacy Notice covers the trustee services provided by us in relation to Employee Share Plans (‘the Employee Share Plan’ or ‘Plan’) as set out in the Plan’s trust deed and rules. Plans include UK and International Share Incentive Plans.  We also hold savings for International Sharesave (SAYE) plans.

If you have questions about your Employee Share Plan and services, please contact the helpline shown in your Employee Share Plan documentation.

Please note, tax advantaged Plans are operated in accordance with Social Security legislative requirements such as ITEPA for UK tax advantaged Plans. You should refer to your Plan documentation to check if this applies to you.

The personal information we hold includes your account number, title and name, postal address, and dependent upon the Plan requirements and your circumstances, also include your email address and phone number, date of birth, gender, nationality, payroll details such as salary, tax status and tax residency, bonus payments, local employer’s PAYE reference, your pay site code, your payroll reference, your National Insurance Number or other tax identification number such as social security number and your salary bank account, financial information about the value of the Plan, savings information where there is a linked savings arrangement, the number of Plan shares or shares under option, performance indicators, any Persons Discharging Managerial Responsibilities, Directors’ Interest or Closed Period indicators and elections made in connection with the running of the Plan or made as part of a Corporate Action.

This could include special personal data, if we need to record the reason why and when you are no longer an employee of the Company or temporarily not at work, for example due to injury or disability, in order to administer the Plan.

We use different kinds of personal data dependent upon the relationship you have with us, the Employee Share Plan that you participate in and the products and services that you use. We collect it through a variety of different ways:

Information you provide to us

• By filling in forms via the website;
• Through using Interactive Voice Recognition (IVR), Text or Touchtone services;
• By corresponding with us, either directly or via your local Plan co-ordinator, in writing, by phone, e-mail, live-chat or otherwise;
• Through application and registration forms, identification and legal documentation; and
• Through promotions or surveys.

Information we collect about you

• If you contact us via IVR or Text or Touchtone, we will collect details about the date and time of contact, the call reference number and your telephone number;
• Images and voice recordings of your communications with us for quality control, training, security and regulatory purposes, but these can also capture your location e.g. use of home landline number;
• Information about the transactions and investments you make as part of the running of the Plan, including financial data and voting instructions; and
• If you contact us via social media, we will collect details from your social media account.

Information we receive from third parties

• Data from your employer as part of the set up and running of the plan, including identification data, your contact details, information about your job, your payroll details and information about your share plan entitlement and participation
• As part of our identity and financial crime checking procedures with credit reference agencies, fraud detection agencies and registration or stockbroking industry exchanges;
• In accordance with the Money Laundering Regulations when we require verification of your identity, we will conduct searches of databases and other credit data; and
• Market researchers.

Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use this information if the law allows us to do so:

• Criminal convictions and offences.
• Genetic and bio-metric data.
• Health data including gender.
• Political Opinion
• Racial or ethnic origin.
• Religious or philosophical beliefs.
• Trade union membership.

Keeping your personal data up to date

It is important to us that the information we hold about you remains accurate and up to date at all times, but we need your help in doing this. Please help us by ensuring that you review the information held about you regularly and let us know as soon as anything needs updating or correcting.

Other people’s personal data

The information you give us in connection with your Plan, can contain yours or another person’s personal data. If you provide us with information about another person, you confirm that they have appointed you to act for them and/or they consent to you providing their personal data to us and that you have informed them of our identity and the purpose for which their personal data will be processed – as set out in this Privacy Notice

In the table below we demonstrate why and how we use your personal data as well as providing the legal reasons which we rely upon.

Under Data Protection legislation we must always have a legal reason for processing your personal data. One of the legal reasons is when we use your personal data for our legitimate interests, and this is usually when we have a business reason. However, we must always ensure that we take your interests into consideration too and ensure that the use is fairly balanced. We tell you below when we rely on legitimate interests and what our legitimate interests are.

Personal data will not be retained for longer than necessary for us to achieve the purpose for which we obtained your personal data. We will then either securely delete it or anonymise it so that it cannot be linked back to you. We review our retention periods for personal data on a regular basis.

We will retain personal data for the duration of the Plan and for a period of up to 8 years following the closure of the Plan, for the reasons noted below:

• To respond to enquiries and complaints;
• To demonstrate that your instructions were carried out properly; and
• To maintain records to meet rules and regulatory requirements that are applicable to the administration of the Plan.

For full details of our retention policies, please contact us.