Privacy Policy

As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide.

This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.

“We”, “Us” “Our” refers to the Partner named on this website.

Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy

About us 

In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a “data controller”.

Constantia Wealth and Finance on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management.

Our processing of your personal information 

Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.

Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.

We also use details of any unspent criminal convictions for fraud prevention purposes.

Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.

In order to make this notice as user friendly as possible, we have split it into different sections. 

Prospective clients

This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system.

What personal information may we collect? 

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.

• Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters, bank statements and evidence of benefit entitlement.

• Employment information such as job title, employment history and professional accreditations.

 Financial information.

 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.

• Information relevant to the services we provide such as:

· previous and current investments

· information about your lifestyle

· attitude to investment risk

· existing plan details

· objectives

· copies of your will

· information about any trusts you have

• Information about your family including information about your dependants.

• Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 7 below.

• Information obtained during telephone recordings.

• Information we may have gather from publicly available sources such as the electoral roll, internet search engines and social media sites such as LinkedIn where you have been flagged as a PEP and we need to carry out enhanced due diligence.

What special categories of personal information may we collect? 

• Details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.

• We may collect details about your health which are relevant to your application (e.g. as part of a pension or income protection need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client) or where you have disclosed such information to us because it explains your risk appetite for investments.

• In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.

How will we collect your personal information? 

We will collect information directly from you when:

• you enquire about or apply to receive our wealth management services; and

• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.

• St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found at www.sjp.co.uk/site-services/privacy

 

What will we use your personal information for? 

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.

We will rely on the following “Lawful Basis” when we process your “personal information”:

• We need to use your personal information to enter into the client agreement, for example, we need to use your personal information to assess whether we can provide services to you and to set you up as a client on the St. James’s Place client relationship management system.

• We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you and we are required to report to St. James’s Place on our relationship with you.

• We have a valid business reason to use your personal information and which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis.

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.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

• You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you certain advice or financial products unless we have your health information.

• There is a substantial public interest such as prevention and detection of fraud.

• We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.

• It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.

Who will we share your personal information with? 

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.

• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found at www.sjp.co.uk/site-services/privacy.

• Third parties who provide sanctions checking services including Experian.

• Compliance consultants including the Consulting Consortium.

• Financial crime and fraud detection agencies.

• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.

• Selected third parties in connection with any sale, transfer or disposal of our business.

• Our insurers.

• The police, HMRC and other crime prevention and detection agencies.

• Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

Existing clients 

This section will apply if you currently receive wealth management services from us. This section will set out how we use your information.

What personal information may we collect? 

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.

• Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters or bank statement and evidence of benefit entitlement.

• Employment information such as job title, employment history and professional accreditations.

• Financial information:

o Bank details

o Financial reviews (fact finds)

o 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 relevant to the services we

 provide, such as:

o previous and current investments

o information about your lifestyle

o attitude to investment risk

o existing plan details

o objectives

o copies of your will

o information about any trusts you have

• Information contained in client review meeting records and file notes

• Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.

• Information about your family including information about your dependants.

• Information obtained during telephone recordings where applicable.

• Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 7 below.

• Your marketing preferences and details of your customer experience with us.

• Information which we have gathered from publicly available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and we need to carry out enhanced due diligence.

What special categories of information will we collect? 

• Details about any criminal convictions and any related information which have been obtained from our sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.

• We may collect details about your health which are relevant to your application (e.g. as part of a pension need we may ask you about any medical conditions that affect you to establish whether you are deemed to be a vulnerable client or where we are applying for income protection insurance we will need to ask you about any medical conditions and information about lifestyle choices such as whether you drink alcohol or smoke so that appropriate insurance can be obtained) or where you have disclosed such information to us because it explains your risk appetite for investments.

• In limited circumstances, we may also collect other special categories of data as detailed on a separate consent form.

How will we collect your personal information? 

We will collect information directly from you when:

• you register to receive our services and complete and return to us all applicable application forms; and

• you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

• Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.

• Any records held by previous independent financial advisers (otherwise known as IFAs) with whom you were previously a client and any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.

• St. James’s Place group companies.

• Third parties such as Experian 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.

What will we use your personal information for? 

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. We will rely on the following “Lawful Basis” when we process your “personal information”:

• We need to use your personal information to enter into or perform the client agreement that we hold with you. For example, we need to use your personal information to provide our services, to arrange and implement recommendations, review your ongoing suitability of current arrangements and handle claims.

• We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.

• We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis.

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.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

• You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to offer you certain advice or financial products unless we have your relevant health information.

• There is a substantial public interest such as prevention and detection of fraud.

• We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves. 

Who will we share your personal information with? 

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.

• Third parties who provide a service in relation to the management of your investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where you are buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.

• St. James’s Place group companies who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy

• Third parties who provide sanctions checking services including Experian.

• Compliance consultants including the Consulting Consortium

• Financial crime and fraud detection agencies.

• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.

• Selected third parties in connection with any sale, transfer or disposal of our business.

• Our insurers.

• The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

Clients’ family members, business associates or beneficiaries 

This section will apply if your personal information has been provided to us by a client to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse or partner, dependant mentioned in a will or trust document, another beneficiary a business partner) and will set out how we use your information.

What personal information may we collect? 

• General information such as your name, address, phone numbers and email addresses, date of birth and gender.

• Your relationship to our client.

• Financial information relating to your financial liabilities, such as a property portfolio which is owned jointly between you and our client.

• Any information which is relevant to the services we provide for our client.

What special categories of personal information may we collect? 

• We may collect details about your physical and mental health which are relevant to your the services we provide for our client (for example where you are the client’s partner and you have a medical condition which means that you are unable to work and therefore our client has a higher need for investment return and a lower risk appetite).

• Information contained in any records held by previous independent financial advisers (otherwise known as IFAs) with whom your family member or business associate was previously a client and which have been transferred to us when that IFA was acquired by St. James’s Place group companies.

• In limited circumstances, we may also collect information concerning your sex life or sexual orientation for example where you are in a civil partnership with our client.

How will we collect your personal information? 

• Directly from our client.

• From documents directly provided to us by our client, such as wills or trust documents where you are listed as a dependant or employment related documents and you are listed as a business partner of our client.

• From any records held by previous independent financial advisers (otherwise known as IFAs) with whom your family member or business associate was previously a client and from any advisers of that IFA which have been transferred to us when that IFA was acquired by St. James’s Place group companies.

• St. James’s Place group companies.

What will we use your personal information for? 

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.

We will rely on the following “Lawful Basis” when we process your “personal information”:

• We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.

• We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis.

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.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:

• You have given your explicit consent to our use of your special categories of personal information which may have been provided to us by your family member, spouse, partner or business associate who is our client.

• There is a substantial public interest such as prevention and detection of fraud.

• We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.

Who will we share your personal information with? 

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

• Other Partners within the Partnership to provide specialist services where we do not have the authorisation to carry out certain activities such as high risk investments and you shall deal directly with that Partner for that specific advice.

• Third parties who provide a service in relation to the management of our client’s investments or facilitate the arrangement of products we recommend such as product providers, portfolio and fund managers, insurers where our client is buying income protection products. Where we have shared your personal information with these third parties, they will also be a data controller and responsible for how they use your personal information. Their uses of your personal information will be governed by their own fair processing notices.

• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy

• Compliance consultants including the Consulting Consortium

• Financial crime and fraud detection agencies.

defend legal rights.

To provide marketing information where you have provided your consent.

• You have given us your explicit consent

To provide marketing information by post, by telephone and in other circumstances where we don’t require your consent.

• We have a valid business reason (to send you selected communications about other products and services we offer)

• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.

• Selected third parties in connection with any sale, transfer or disposal of our business.

• Our insurers.

• The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax adviser

Other business partners 

If you are a business partner such as a products provider, portfolio or fund manager or contractor who carries out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.

What personal information may we collect? 

• General information such as your name, address, business phone numbers and email addresses.

• Employment information such as job title, business cards and professional accreditations.

• Information about your clients, your employees and the services and products you offer.

• Your bank details and information obtained from checking sanction lists and credit checks.

• Information which we have gathered from publicly available sources such as internet search engines and generally obtained as part of the due diligence process conducted by St. James’s Place group companies.

How will we collect your information? 

• Directly from you

• St. James’s Place group companies.

• Publicly available sources such as internet search engines.

• From service providers who carry out sanctions checks.

What will we use your personal information for? 

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.

We will rely on the following “Lawful Basis” when we process your “personal information”:

• We need to use your personal information to enter into or perform the contract that we hold with you.

• We have a legal or regulatory obligation to use such personal information. For example, we may be required to carry out certain background checks.

• We have a valid business reason to use your personal information which is necessary for our everyday business operations and activities, for example to keep records of investments and the reasoning behind such investments, to maintain business records, to carry out due diligence, to review our business models and undertake strategic and operational business analysis including reviewing the performance of our business partners.

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.

Who will we share your personal information with? 

We will not sell or transfer your personal information to anyone unless we have a valid reason as set out above and we will only disclose it to the following parties:

• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found https://www.sjp.co.uk/site-services/privacy.

• Your agents or employees as appropriate.

• Third parties who provide sanctions checking services including Experian.

terms of confidentiality and security measures you implement to protect the information we are sharing with you about our clients).

To comply with our legal or regulatory obligations.

• We need to use your information in order to comply with our legal obligations, for example to pay your invoices for the services you have provided.

For business purposes and activities including maintaining business records, file keeping and strategic business planning.

• We have a valid business reason (to run our business efficiently and effectively)

For compliance and monitoring purposes.

• It is necessary to enter into a contract with you.

• We have a valid business reason (to ensure we are compliant and carrying out appropriate monitoring activities).

• Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.

• Selected third parties in connection with any sale, transfer or disposal of our business.

• Our insurers.

• Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

Users of our website 

If you use our website, this section will be relevant to you and sets out our uses of your personal information.

What personal information may we collect? 

• General information submitted via the website, for example where you provide your details in the contact section such as your name, contact details and company name.

• Information such as IP address and browsing history obtained through our use of cookies. You can find more information about this in our cookies policy in section 7 below.

How will we collect your personal information? 

We will collect your information directly from our website.

What will we use your personal information for? 

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.

We will rely on the following “lawful basis” when we process your “personal information”:

• We have a valid business reason to use your personal information, necessary for our everyday business operations and activities, for example to maintain business records and to monitor usage of the website.

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.

Who will we share your personal information with? 

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to:

• St. James’s Place group companies, who will process your personal data in accordance with their Privacy Policy which can be found www.sjp.co.uk/site-services/privacy

• Third parties who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as IT suppliers and website providers.

Where you are a job applicant 

This section will apply if you are a job applicant within the St. James’s Place Partnership.

What personal information may we collect? 

• We have set out below the main categories of candidate personal information which we process in connection with our recruiting activities on a day to day basis:

• personal contact information (including your name, home address, personal telephone number(s) and personal e-mail address)

• work history and other relevant experience including information contained in CV, cover letter or job application form

• education information including degrees awarded, transcripts and other information provided in support of the job application

• remuneration history

• information collected during phone screenings and interviews

• details regarding the type of employment sought, desired salary, willingness to relocate, job preferences, and other information related to compensation and benefits

What background checking do we undertake?

• As part of our referencing and vetting procedures, we will contact certain third parties in order to verify your personal information (including personal information that you provide as part of the application and recruitment process). These third parties will include:

• former employers, in order to verify your previous employment history

• universities and/or other establishments for higher education that you attended, in order to verify your education history

• for specific roles we will undertake electronic ID checks, sanctions and politically exposed persons checks via a third-party agency

• We will also gather data from publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.

• We will only conduct background checking in relation to successful candidates that have accepted a conditional offer of employment with us, and we will specifically inform such candidates that we will be contacting these third parties in advance of doing so.

What will we use your personal information for? 

St. James’s Place uses your personal information for a variety of purposes to take steps necessary to enter into an employment contract with you, to comply with legal obligations or otherwise in pursuit of its legitimate business interests. We have set out below the main purposes for which candidate personal information is processed:

• To identify and evaluate job applicants, including assessing skills, qualifications and experience

• Verifying candidate information and carrying out employment, background (including criminal records) and reference checks, where applicable, and in order to prevent fraud

Stewart Douglas is a mortgage broker based at Constantia Wealth and Finance which is a Partner Practice of St. James's Place Wealth Management PLC. Stewart assists a diverse range of mortgage clients including home movers, first time buyers and landlords.

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 The Partner together with St. James’s Place plc are the data controllers of any personal data you provide to us. For further information on our uses of your personal data, please see the Partner’s Privacy Policyor the St. James’s Place Privacy Policy.