SJP Personal Information Collection Statement (PICS)
St. James's Place International (Hong Kong) Limited (“Company” and/or “we”) is a company registered in Hong Kong (Company number 2207694) with its registered address at 1/F Henley Building, 5 Queen’s Road Central, Hong Kong and is regulated by Insurance Authority.
As a corporation incorporated in Hong Kong, the Company has an obligation to comply with the Personal Data (Privacy) Ordinance of Hong Kong, and other applicable regulations, codes, guidelines, directives, handbooks, practice notes or binding notices, circulars and policy statements as applicable to the entities incorporated in the Hong Kong (“Data Protection Legislation”).
The Company is committed to protecting the privacy of all individuals it interacts with. This includes, but is not limited to, the clients and prospective clients.
The Company will be the data controller of your personal information, and this PICS provides you with notice as to why we process your personal data, what personal information we may collect about you, how we intend to use it, with whom your personal data may be shared, to and how to access, or rectify personal data we hold about you.
Please note, that where you provide us with personal information about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal data and we are responsible for protecting their personal data and using it appropriately. This PICS will therefore apply to those individuals and you should refer them to this notice.
There are a number of reasons we use your personal information and for each use we need to have a lawful basis to do so, and any one or more of the following shall constitute a lawful basis for processing of your personal information:
- we have your consent,
- the personal data is necessary to perform a contract we have or intent to enter into with you, which includes but is not limited to the following:
- processing and assessing of applications for any insurance products and provision of the related services;
- administering your insurance policy and providing services in relation to your insurance policy;
- any alterations, variations or cancellation of any insurance and related services;
- investigating, analyzing, processing and paying claims made under your insurance policy;
- processing payment instructions;
- invoicing and collecting premiums and outstanding amounts from you;
- conducting suitability check/needs analysis by assessing the information you provided for insurance products taken out via our broker channel;
- exercising any right under the insurance policy including right of subrogation, if applicable;
- the personal data is necessary to comply with a legal obligation,
- the personal data is necessary to protect the vital interests of a natural person , the personal data is necessary for a public interest or the personal data is necessary to fulfil a legitimate interest of the controller or third party (provided that the interest is not overridden by the data subject's privacy interests and the data subject has not made use of his/her right to object), which may include but is not limited the following processing purposes:
- to conduct research, insurance survey and analysis for the purpose of product design and development and improvement of our services to you;
- for statistical or actuarial research undertaken by the Company, other member(s) of the St James’s Place Group or its regulators;
- for the operation and administration of the Company’s internal business including without limitation any corporate reorganisation;
- to contact you for any of the above purposes.
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
Although it is not compulsory to share your personal data with the Company, Failure to supply such data may result in the Company being unable to establish or continue the relationship with you, or provide you with the products or services.
We will collect information directly from you when:
- You apply purchase, vary or renew any product or service provided by the Company; and
- You contact us by email, telephone and through other written and verbal communications.
We will also collect your personal information from:
- Your St. James's Place Partner where applicable.
- Publicly available sources such as (but not limited to) court judgments, insolvency registers, internet search engines and social media sites.
- Other companies within the St James's Place Group.
- Third parties such as SS&C who provide anti money laundering and fraud prevention services who we have appointed to carry out electronic ID checks, sanctions and politically exposed persons checking services, and platforms such as Dow Jones and Napier.
Your personal data will be stored either for as long as you (or your joint policyholder) are our customer, or longer if required by law or as is otherwise necessary.
- General information such as your name, address, phone numbers, email addresses, date of birth, gender and marital status.
- Identification information including passport, driving licence, government issued ID verification and address verification documents such bank statement.
- Employment information such as job title, employment history and professional accreditations.
- Financial information relevant to the products we recommend, including:
- Bank details
- Financial reviews (fact finds)
- Information relating to your personal finances such as your financial liabilities and assets, income and outgoings.
- Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders or where you have been flagged as a PEP.
- Information about your family including information about your dependants.
- Information obtained during telephone recordings where recorded.
- Information obtained during the course of emails, queries and complaints.
- Details of your customer experience with us.
- Information such as IP address and browsing history obtained through our use of cookies.
- Personal data of those individuals who have rights under or in connection with products you hold such as lives assured, dependents, nominated beneficiaries, trustees, authorised representatives, independent financial advisors, and lawyers.
There are a number of instances where your personal information may be transferred outside Hong Kong such as when we transfer information to our other companies in the wider St. James’s Place Group or to third party suppliers who are based outside Hong Kong or when third parties who act on our behalf transfer your personal information outside Hong Kong.
Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will only transfer personal information the countries that are deemed to have adequate levels of data protection for the purpose of the transfer of personal data out of Hong Kong.
You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice.
We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:
- in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
- in doing so we could not provide services to you and would have to cancel your client agreement.
We will of course inform you if any of the above situations arise and if we are unable to comply with your request.
1. The right to access your personal information
You are entitled to a copy of the personal information we hold about you and certain details of how we use it.
We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information.
We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.
2. The right to rectification
Please help us to keep your personal information accurate and up to date so if you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.
3. The right to withdraw your consent
Where we rely on your consent to process your personal data, you have the right to withdraw such consent to further use of your personal data. However, your decision to withdraw your consent will not affect the processing of personal data previously based on your authorization.
In accordance with the provisions of Data Protection Legislation we have the right to charge a reasonable fee for processing any data access request.
If you want to exercise your rights, request may be made in writing to the Data Protection Officer at:
St. James’s Place International (Hong Kong) Limited
1/F Henley Building, 5 Queen’s Road Central,
Hong Kong.
With your consent, we intend to use your personal data for direct marketing as set out in paragraph 7 of this PICS.
Consent for using personal data for direct marketing purpose
You can opt out of marketing communications at any time by contacting the Data Protection Officer at the address below to opt out from direct marketing at any time:
St. James’s Place International (Hong Kong) Limited
1/F Henley Building, 5 Queen’s Road Central,
Hong Kong.
The Company reserves the right, at any time and without notice, to add to, change, update or modify this PICS,
We will provide you with the most up-to-date notice and you can check our website periodically to view it or you can request a copy from your St. James’s Place Partner.
Should you have any questions related to any part of this PICS or would like additional information regarding the Company’s data privacy practices, please do not hesitate to contact us.