Who we are
For the purposes of data protection law, TGI is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that TGI can link to you and which TGI has in its possession or control.
Personal data that TGI collects
TGI will collect and process the following personal data:
Information that you or someone acting on your behalf provides to TGI or its Associates. This includes information about you that you give TGI by filling in forms, signing up for services on our website or by communicating with TGI, whether face-to-face, by phone, e-mail or otherwise, such as through our client portal. If you are a client or are connected with one of our client’s matters, this may include personal data about you or others that is provided to TGI in connection with the provision of services to that client.
If you are a client, or are connected with one of our client’s matters, this information may include:
- information about you, your transactions, financial information and relationship to others;
- data that TGI collects about your use of TGI’s IT systems;
- reports and information for tax reporting (e.g. FATCA) or compliance with legal or regulatory obligations (e.g. insider lists, regulator information requests);
- (where required by legal or regulatory obligations or otherwise where we have a specific legal basis) recordings of telephone calls between you and TGI.
Information TGI obtains from other sources. If we collect or receive your personal data in the context of our provision of services, we might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our client.
Uses of your personal data
Personal data may be stored and processed by TGI in the following ways and for the following purposes:
- to provide TGI’s products and services, including processing instructions and providing confirmations, advice and statements to our clients;
- verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage TGI’s relationship with you and/or the client to whom you are connected;
- to contact you in connection with your work with TGI and the products and services that TGI provides to you or a client to whom you are connected;
- to perform the contract with you or a client/supplier to whom you are connected (including performing TGI’s obligations and exercising TGI’s rights);
- to engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from TGI and/or its Associates;
- to engage in Community Investment projects where you choose to participate;
- to notify you about changes to TGI’s service;
- to carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management;
- to comply with TGI’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
- to use it to prevent and respond to actual and potential fraud or illegal activities; or
- to use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.
TGI is entitled to use personal data in these ways because:
- Consent – we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
- Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
- Legitimate interest – we may use your personal data for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation – we may use your personal data as necessary to comply with applicable law/regulation.
Disclosure of personal data to third parties
TGI may disclose personal data to its Associates in the circumstances described below:
- to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
- for the management and administration of the TGI business;
- for the management and administration of internal policies and procedures within TGI.
Where personal data is disclosed to its Associates, TGI will take steps to ensure that the personal data is accessed only by those persons who need to do so for the purposes described in this Privacy Notice.
TGI may also disclose personal data outside of TGI and its Associates, as follows:
- to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use personal data on TGI’s behalf for the purposes described in this Privacy Notice;
- to third parties relevant to the services outlined in the contract with you or the contract of a client/supplier with whom you are connected. This may include for example counterparties to transactions, professional advisers, stock exchanges or regulators;
- to the prospective counterparty, for due diligence purposes, if TGI and/ or TGI’s Associates restructure or sell any of its or their business or assets (for the avoidance of doubt, your personal data would only be transferred in such circumstances to the extent that such a transfer was required for the purposes of due diligence and was subject to appropriate security protections e.g. anonymisation and/or confidentiality restrictions);
- to the extent required by law, regulation or court order for example if TGI is under a duty to disclose personal data in order to comply with any legal or regulatory obligation; and
- in order to establish, exercise or defend TGI’s legal rights, for example if TGI needs to obtain external legal advice or provide personal data in connection with judicial proceedings.
Transfers of personal data outside the European Economic Area
Personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). It may also be stored and processed by staff operating outside of the UK or the EEA, who work for TGI’s Associates or TGI’s third party agents, service providers or contractors.
Where TGI transfers personal data outside the UK or the EEA, TGI will ensure that it is protected in a manner that is consistent with how personal data will be protected by TGI in the UK and the EEA. This may be achieved in one of the following ways:
- the country that TGI sends the data to might be approved by the European Commission or by a relevant data protection authority; or
- the recipient might have signed a contract based on “model contractual clauses” approved by the European Commission or by a relevant data protection authority, obliging them to protect the personal data that they receive.
In other circumstances the law may permit TGI to otherwise transfer personal data outside the UK or the EEA. In all cases, however, TGI will ensure that any transfer of personal data is compliant with applicable data protection law.
You can obtain further details of the protection given to your personal data when it is transferred outside the UK or the EEA by contacting TGI in accordance with the “Contacting The Global Index” section below.
Retention of personal data
How long TGI holds personal data for will vary. The retention period will be determined by various criteria including:
- the purpose for which TGI is using it – TGI will need to keep the data for as long as is necessary for that purpose; and
- legal obligations – laws or regulation may set a minimum period for which TGI has to retain personal data.
Rights in relation to personal data
You have a number of legal rights in relation to the personal data that TGI holds about you. These rights include:
- the right to obtain information regarding the processing of your personal data and access to the personal data which TGI holds about you;
- the right to request that TGI rectify your personal data if it is inaccurate or incomplete;
- the right to request that TGI erase your personal data in certain circumstances. Please note that there may be circumstances where you ask TGI to erase your personal data but TGI is legally entitled to retain it;
- the right to object to, and the right to request that TGI restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask TGI to restrict, its processing of your personal data but TGI is legally entitled to continue processing your personal data and / or to refuse that request;
- in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that TGI transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to TGI;
- the right to withdraw your consent, although in certain circumstance it may be lawful for TGI to continue processing your data where TGI has another legitimate reason (other than consent) for doing so. TGI is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this Privacy Notice; and
- the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by TGI.
You can exercise your rights by contacting TGI using the details set out in the “Contacting The Global Index” section below.
You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data.
Contacting The Global Index
If you would like further information about TGI’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to [email protected].