Shareholder Privacy Notice
St. Modwen Properties PLC (“St. Modwen”) is the Data Controller and the Company in which you own shares, we value our shareholders’ privacy and take steps to ensure the appropriate collection and handling of personal information.
In order to manage and fulfil our obligations in relation to your shareholding, we need to use and sometimes share your personal information. This privacy notice explains how and why we use your personal information. Please read carefully.
We collect and handle various categories of your personal information. This may include:
- basic contact details (name, address, telephone number, email address etc);
- where you have provided and given permission for us to do so for the purposes of electronic payment of your dividends, your bank details;
- details of your shareholding in St. Modwen such as the number and value of shares held;
- Information about your attendance at shareholder meetings and events and voting instructions; and
- Documents evidencing proof of your share ownership.
Why do we need your personal information?
We need to use your personal information for a number of purposes as set out below:-
- for management and administration of your shareholdings, including payment of dividends and maintenance of the share register;
- to notify you about shareholder meetings and events;
- to provide updates about our financial performance and results; and
- to meet any tax, legal or regulatory requirements which we are subject to.
We will notify you separately if we need to collect and use personal information on the basis of your consent, we will specify the uses of your personal information which will be based on your consent, and we will ensure you are presented with the opportunity to give this on a freely given and informed basis.
Who do we share your personal information with?
Equinti Limited together with Equiniti Financial Services Limited is St. Modwen’s appointed registrar and as part of this role handles the collection and storage of information about our shareholders on our behalf.
We will only share your details with any other third parties when it is necessary and lawful, to fulfil our obligations as part of your relationship with us, or when it is in our legitimate interests to do so. We will only disclose your personal information to our registrar and any other third parties, if we are satisfied that they will handle it in accordance with required standards, and as appropriate, where we have a written agreement which contains contractual safeguards to protect your personal information in place with those parties. In certain circumstances, it may be necessary to disclose your personal information to law enforcement agencies, regulatory bodies, tax authorities and our professional services advisers.
How do we safeguard your personal information?
We have implemented our own technical and organisational measures via IT systems and business processes and have assurances from our registrar that they have the same or equivalent measures in place to ensure your personal information is handled in a secure way and accessed by team members only on a need-to-know basis.
Transfer of your personal information
From time to time we may transfer some of your personal information outside of the European Economic Area to India or other overseas subsidiaries of our registrar. Where this occurs our registrar is under an obligation to ensure that there are appropriate safeguards in place which may include standard data protection clauses binding corporate rules or other measures permitted under data protection laws.
What rights do you have over your personal information?
Data Protection laws enable you to have appropriate control and oversight of what we do with your personal information. To exercise any of your rights listed please contact the St. Modwen Data Protection Officer whose details can be found below. The only exception is right 1. If you need to update or correct your personal information, please do this directly with our registrar through the Shareview portal, telephone 0371 384 2198 or by post to Equiniti Limited, Aspect House, Spencer Road, Lancing, West Sussex, BN99 6DA.
Where permitted by relevant Data Protection laws you have the right to:
- update and correct your personal information so that it is accurate;
- access the personal information held about you and to learn the origin of the information, the purposes and ends of the processing, the details of the data controller(s), the data processor(s) and the parties who we share information with;
- withdraw your consent at any time where your personal information is processed on the basis of your consent;
- request your personal information is deleted from our records in certain circumstances;
- restrict the processing of your personal information in certain circumstances;
- request a copy of your personal information in a portable reusable format to enable the transfer of data sets between organisations;
- challenge any profiling and automated decision making, meaning you are not subject to decisions based solely on automated processing significantly affects you; and
- file a complaint with us and/or the UK Information Commissioner’s Office (ICO). You can find out more information about your rights by visiting the ICO website here https://ico.org.uk
In certain circumstances, we will need to use your personal information even though you may have asked us to delete it or restrict our use of it, or when you objected to our use. We will do so in a lawful, fair, and transparent manner. Please contact the St. Modwen Data Protection Officer if you have any questions.
How long is personal information retained for?
We will not retain your personal information for longer than is necessary and we will hold it only for the purposes for which it was obtained in accordance with our retention policy.
In particular you should note that St Modwen is required by company law to maintain and keep the members register for at least the life of the company
St. Modwen has appointed a group Data Protection Officer (DPO) who is responsible for overseeing compliance with the handling of personal information.
If you wish to exercise your rights over your personal information, or if you have any queries about how we use your personal information, you can contact the St. Modwen DPO by post or email at the contact details set out below:-
St. Modwen Data Protection Officer
17 High Street