Privacy


This webpage is comprised of the following privacy policies: (1) Privacy & Cookie Policy – General, which is the privacy policy applicable to clients, prospective clients, and website users; and (2) Privacy Policy – Employee and Tied Agent, which is the privacy policy applicable to our employees and tied agents.

Fisher Investments UK
Employee and Contractor Privacy & Cookie Policy

Last Updated: November 2023

1. General

This Employee and Contractor Privacy & Cookie Policy (“Policy”) is in accordance with the UK Data Protection Act 2018 and the UK General Data Protection Regulation, as incorporated into UK law under the European Union (Withdrawal) Act 2018 and sets out how Fisher Investments Europe Limited, trading as Fisher Investments UK, and its branches (collectively, the “Company”), uses Personal Data relating to the following natural people (“ Individuals”):

  • prospective employees, current, and former employees, whether permanent or temporary (“Employees”);
  • prospective, current, and former contractors, including tied agents (“Contractors”).

In this Policy, “Personal Data” means any information about identified or identifiable Individuals. The Company is committed to privacy and will use Individuals’ Personal Data only in accordance with this Policy.

The Company can be contacted about this Policy using the following details:

Fisher Investments Europe Limited
trading as Fisher Investments UK
Attn: Data Protection Officer
Level 18, One Canada Square
Canary Wharf, London, E14 5AX
United Kingdom
privacy@fisherinvestments.co.uk
+44 0800 144 4731

2. Types of Personal Data

The Company processes the following types of Personal Data for Individuals:

  • records of work history (including internal and external work history and references), education and qualifications (including information provided on an application or CV);
  • contact details (e.g. name, address, email address, telephone number)
  • contact information of spouse / partner / dependent(s) and emergency contact details;
  • date and place of birth and nationality;
  • identification numbers;
  • marital status;
  • background check information, which may reveal data concerning criminal convictions or offences;
  • bank details and account numbers;
  • compensation, fees, bonus or incentive information, tax rates and withholding information (including invoices, amounts paid or withheld, the frequency and currency of payments);
  • expense reimbursements (including receipts and amounts paid)
  • Employee benefits information (e.g. health insurance, pension contributions) (including amounts paid, the frequency and currency of payments);
  • records of performance (including evaluations of competence, ongoing supervision and monitoring under financial services regulations, monitoring activity data as recorded on computer and telecommunication systems, economic viability and ratings, complaints, grievances, and disciplinary records);
  • information relating to Employee absences from work;
  • information relating to Employees’ mental and physical health and mental or physical disabilities (collectively, “Health Data”);
  • general organisational data (such as department, work location, job title and seniority);
  • information technology data (e.g., passwords, access rights and usage data);
  • recordings of telephone calls made by certain representatives of the Company;
  • photographic and video images; and
  • other data that the Individual provides to the Company or its affiliates (collectively, the “Fisher Group”).

Personal Data are collected mainly from Individuals themselves. In addition, the Company collects reference check information from previous employers of (or companies to which services were provided by) Individuals. Background check information, which may reveal data concerning criminal convictions or offences, is collected from Sterling Talent Solutions UK Limited (“Sterling”), a background checking firm that collects Personal Data from both public and private sources with consent of the Individual.

3. Use of Personal Data

a. Purposes and Lawful Bases

The Company processes Individuals’ Personal Data for the following purposes, and upon the legal bases set out in the table below.

Purpose for which the Company uses Personal Data

Legal Basis upon which the Company relies

To manage the recruitment process

This includes making decisions about hiring Employees or engaging Contractors, arranging travel, and reimbursing expenses.

The Company can use Personal Data for this purpose because it is necessary to take steps at the request of the Individual prior to entering into a contract.

To market employment opportunities at the Company

This includes contacting candidates by email, phone or mail who have consented to be considered for future employment or engagement opportunities.

The Company can use Personal Data for this purpose with the consent of the Individual.

To make decisions about Individuals’ fitness for work

This includes making decisions about Individuals’ competence and qualifications to carry out roles, including conducting background checks on candidates for employment or engagements.

The Company can use Personal Data for this purpose where required to comply with legal obligations to which the Company is subject, including the laws and regulations of the UK Financial Conduct Authority and other applicable financial services regulators (collectively, “Financial Services Laws”).

To administer the Company’s relationship with Individuals

This includes administering payroll, processing invoices and reimbursements, providing support services, and, if relevant, pension, medical insurance and similar benefits.

The Company can use Personal Data for this purpose because it is necessary to perform a contract to which the Individual is a party.

To fulfilling legal obligations

This includes verifying identify and work authorization, complying with social security and tax requirements, and providing information to governmental and quasi-governmental bodies and law enforcement agencies.

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws and other applicable laws.

To obtain work authorisation or visas for Employees

The Company can use Personal Data for this purpose because it is necessary to take steps at the request of the Employee.

To train, evaluate performance and recognise Employees and Contractors

This includes training and surveying Individuals, monitoring and analysing performance, carrying out performance reviews, and making decisions about recognition, rewards, discipline and termination.

The Company can use Personal Data for this purpose because it is in the Company’s legitimate interest to evaluate its Employees and Contractors, and to give Individuals opportunities to improve performance.

To administer Employees’ sick leave and absence

The Company may ask for, and Employees may need to provide, Health Data where such information impacts the Employee’s ability to perform his or her role.

The Company can use Personal Data for this purpose where required to comply with employment laws or to protect the health and safety of employees or others.

To monitor Employees and Contractors

This includes monitoring the advice process, recording and monitoring certain telephone calls, supervising Employees and Contractors, including monitoring emails, voicemails and other activities as recorded on computer, telecommunications and security systems, and carrying out the Company’s compliance plan.

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws.

In addition, the Company has a legitimate interest in using personal data for the purpose of supervising employee activity.

To monitor systems

This includes monitoring emails, voicemails and other activities as recorded on computer, telecommunications and security systems, and carrying out the Company’s compliance plan.

The Company has a legitimate interest in using Personal Data for the purposes of ensuring network and information security.

To provide references to future employers and other third parties

This includes providing employment or earnings confirmation letters to banks, mortgage lenders and landlords at the request of the Individual.

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws or with the consent of the Individual.

To keep records

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws and other applicable laws.

In addition, the Company can use Personal Data for this purpose beyond the legally mandated record retention period because it is in the Company’s legitimate interest to keep data for as long as the statute of limitations so that the Company can enforce and defend its legal rights.

To share data with courts and tribunals

The Company can use Personal Data for this purpose because it is in the Company’s legitimate interest to enforce and defend its legal rights.

To use photos and contact information to enable effective communication across the Fisher Group

The Company can use Personal Data for this purpose because it is in the Company’s legitimate interest to ensure effective communication across the Fisher Group.

To use images and recordings to promote the Company in internal and external materials and advertising

The Company can use Personal Data for this purpose with the consent of the Individual.

To conduct candidate research

This includes conducting market research to ask about recruitment and servicing preferences.

The Company can use Personal Data for this purpose when the Company has a legitimate interest in doing so.

To enhance security of Company facilities

This includes the use of video surveillance equipment.

The Company can use limited Personal Data for this purpose because it is in the Company’s legitimate interest to secure its facilities.

Where the Company has relied upon its ‘legitimate interest’ as a legal basis for a particular purpose, it has performed a ‘balancing test’ to ensure that Individuals’ rights and interests are taken into account when their Personal Data is used. Further information on the balancing test can be obtained by contacting the Company’s Data Protection Officer.

b. If Employees/Tied Agents fail to provide Personal Data

Failure of an Individual to provide Personal Data to the Company, in whole or in part, could make it impossible for the Company to fulfil some or all of its obligations towards the Individual, such as payment of compensation or fees, calculation of withholdings, or consideration of an employment application.

4. Sharing of Personal Data

a. Who will the Company share Personal Data with?

The Company will not sell or lease Individuals’ Personal Data to third parties.

For the purposes listed in Section 3 above, the Company may share Personal Data with:

  • Fisher Group companies, including:
    • Fisher Investments (“FI”), the Company’s parent company in the United States;
    • Fisher Investments Ireland Limited (“FII”), a wholly-owned subsidiary of FI in the EU; and
    • Fisher Investments Luxembourg, Sàrl (“FIL”), a wholly-owned subsidiary of FI in the EU.

FI, FII and/or FIL (the “Outsourced Fisher Companies”) act as service providers of marketing, human resources, finance, information technology, legal support services, and investment sub-management and trading functions to the Company. In these capacities, the Outsourced Fisher Companies may have access to Personal Data collected and used by the Company.

  • Company-authorised vendors, service providers, contractors and representatives. These organisations are as follows:
    • Other Contractors of the Fisher Group who have access to Company systems, including email, and receive emails that may include Personal Data of Individuals.
    • Information technology and security providers, including cloud software, communications, internet firewall and malware detection providers.
    • Providers of the Company’s employee benefit programmes.
    • Service providers that carry out checks and assessments at the request of the Company, including Sterling.
    • Service providers that assist Employees with work authorization or visas and/or relocation.
    • Vendors providing training or firm events, which may receive names and/or Company email addresses of Individuals.
    • Photographers and videographers capturing images of Individuals.
    • Providers of third party professional advice, such as lawyers and auditors.
  • Future employers requesting reference checks and third parties (including banks, mortgage lenders and landlords) to which the Individual has requested the Company provide an employment or earnings confirmation letter.
  • Courts and tribunals, as described above in Section 3.
  • Regulators (including the relevant financial regulators), tax authorities, other government agencies and law enforcement organisations, as described above in Section 3.
  • If the Company sells, transfers or merges part or all of its business, or attempts to do so, then third parties may receive Personal Data.

b. What safeguards are in place where Personal Data is transferred outside of the EEA?

Where the Company transfers Personal Data to a data recipient in a jurisdiction outside of the EEA where the laws do not provide an equivalent level of data protection as the country in which the Individual initially provided the data, the Company and the data recipient will make the transfer in accordance with standard contractual clauses approved by the European Commission (“Model Clauses”). Prior to such transfer, the Company will assess and confirm that the protections of the Model Clauses are effective in light of the legal regime in the data recipient’s jurisdiction and, if necessary, adopt supplementary technical, organisational, or contractual measures. For more information on Model Clauses, please visit https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.

Concerning Personal Data transferred to the United Kingdom, if the European Commission has issued a decision that the UK legal regime provides an adequate level of data protection (an “Adequacy Decision”), the Company can transfer Personal Data to data recipients in the UK without the need for additional safeguards. In the event the European Commission has not issued an Adequacy Decision for the UK, the Company and the recipient in the UK will make the transfer in accordance with the Model Clauses, as described above.

Please contact the Company using the contact details in Section 1 with any questions about the legal safeguards in place to protect Personal Data when transferred outside the EEA (including how to obtain a copy or consult these safeguards).

5. Consent

In accordance with applicable data protection laws, Individuals who consent to the Company using their Personal Data may withdraw that consent at any time. Individuals may do so using the details set out in Section 1 above.

When doing so, Individuals should:

  • ensure that a full name and address and/or email address is provided in exactly the form in which it was originally provided to the Company to avoid any possible confusion with a different Individual; and
  • ensure that the particular uses for which consent is being withdrawn are specified. The uses for which the Company relies on consent are set out in Section 3

6. Individuals’ Rights

In accordance with applicable data protection laws, Individuals may exercise the following rights in relation to the Personal Data that the Company holds about them:

  • Individuals have the right to obtain confirmation as to whether or not their Personal Data is being processed and, where this is the case, have access to the Personal Data.
  • Individuals have the right to ask the Company to rectify Personal Data about them that they think is inaccurate. They also have the right to ask the Company to complete data they think is incomplete.
  • Individuals have the right to request the erasure of their Personal Data where there is no compelling reason for the Company to keep using the data. This is not a general right to erasure; there are exceptions, g., if the Company has a legal obligation to keep the data.
  • Individuals have the right to ask the Company to restrict processing of their Personal Data in certain circumstances.
  • The right to data portability applies only to Personal Data Individuals have given to the Company. Individuals have the right to ask that the Company transfer the data to another organisation or give the data back to the Individual.
  • Where Individuals have provided the Company with consent to process their Personal Data, they have the right to withdraw consent at any time. This will not affect the lawfulness of the processing that has been carried out based on Individuals’ consent prior to the withdrawal.
  • When the Company processes Personal Data for purposes of pursuing a legitimate interest, Individuals have the right to object to such processing at any time. If an Individual objects, the Company will stop the processing unless it has strong and legitimate reasons to continue using the data.
  • To exercise these rights, Individuals should contact the Company using the details set out in Section 1 In such case, Individuals should ensure that the full name and address and/or email address are provided in exactly the form in which they were originally provided to the Company to avoid any possible confusion with a different Individual. If Individuals are not satisfied with the way the Company handles the request, they may lodge a complaint with the supervisory authority in the country where that Individual lives or works, or the country where the Individual believes the infringement took place.

7. Security

The Company is committed to ensuring that Personal Data is secure. In order to prevent unauthorised access or disclosure, the Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure Personal Data collected. The Company also uses encryption when collecting or transferring sensitive data.

8. Cookies

A cookie is a small text file with an identification tag that is created and downloaded to a user’s computer (or other device) when accessing websites that use cookies. Cookies allow a website to, among other things, store and retrieve information about a user’s online activity and browsing habits. Depending on the information they contain and user behaviour, cookies may be used to identify the user. 

Cookies can be categorised by who places them:

  • First-party cookies: These cookies are downloaded to a user’s computer (or other device) by the publisher of the website whose service the user is requesting.
  • Third-party cookies: These cookies are downloaded to a user’s computer (or other device) by another entity that may be seeking data obtained through cookies.

Cookies can also be categorised by their duration:

  • Session cookies: These cookies are designed to collect and store data while the user accesses a website. They are often used to store information for the duration of a visit to the website (e.g., what account user is logged into). Once a user leaves the website, the session cookie is deleted.
  • Persistent cookies: These cookies store data on the user’s computer (or other device) for the duration period set within the cookie’s file, which is determined by the entity controlling the cookie and can range from a few minutes to several years, or until the user manually deletes them.

Lastly, cookies can be categorised by the function they serve. The Company uses the following types of first- and third-party cookies:

  • Required: Required cookies are necessary to enable the basic features of this site to function. They keep track of whether or not a user has consented to have other types of cookies placed on their computer (or other device). Required cookies do not collect Personal Data. Required cookies may also include authentication cookies.
  • Statistical: Statistical cookies analyse anonymised site statistics. They enable measuring the number of visitors and analysing how users interact with the website. This information is used to improve the website and the products or services offered.
  • Marketing: Marketing cookies are used to understand user interests, provide relevant ads, and make a user’s online experience more enjoyable. They can be used to build a user profile to provide users with content more relevant to their interests. They adapt advertising and the content users see on other websites based on their website browsing habits, as well as how users interact with internet advertising.
  • Preferences: Preferences cookies allow the website to personalise website content, such as the language selected for viewing the page. These also save a user’s cookie preference settings.

The Company uses first- and third-party required, statistical, marketing and preferences cookies. The following vendors load cookies on this website:

  • Adform
  • Dianomi
  • Doubeclick
  • Drawbridge
  • Facebook
  • Google Ads
  • Google Analytics
  • Hotjar
  • LinkedIn
  • MathMedia
  • Microsoft
  • Outbrain
  • Pingdom
  • Taboola
  • Tag Inspector
  • Tealium
  • Vidyard
  • Vimeo
  • Yahoo/Verizon
  • YouTube
  • Zemanta

For further information on cookies and to manage them, please click here.

Some browsers have a “Do Not Track” setting that allows users to send a signal to the websites they visit that the user does not wish to be tracked. The Company’s website does not respond to these signals.

The websites used by the Company for job postings and submitting applications have their own privacy and cookie policies, which are listed below:

9. How Long Data Will Be Kept

Personal Data relating to Individuals who have entered into an employment or contractor agreement with the Company will generally be kept for the duration of the employee or contractor relationship plus seven years in order for the Company to satisfy its recordkeeping obligations under Financial Services Laws and other applicable law, as well as to enforce or defend its legal rights. An Individual’s Personal Data that forms part of the records of clients may need to be kept for a longer period to satisfy the Company’s recordkeeping obligations under Financial Services Laws with respect to such client records as set out in the Company’s separate Privacy & Cookie Policy. Recordings of telephone calls will be retained for a period of five years in order for the Company to satisfy its recordkeeping obligations under applicable Financial Services Laws. Personal Data relating to candidates will generally be kept for a period of up to one year from the date of collection or the date of rejection. Where a candidate consents to have Personal Data retained by the Company for consideration for future positions with the Company, it will be kept for five years unless the Individual requests earlier erasure of their information.

10. Social Media

The Company maintains a presence on various social media platforms. The terms and conditions set by the operators of the various platforms apply to the Company and any Individuals who interact with the Company through the platforms. More information about each of the various platforms is available below.

  • Facebook: The Company is subject to an agreement with Facebook Ireland Limited, which determines their respective responsibilities with respect to Personal Data. Facebook Ireland Limited is responsible for enabling Individuals’ rights with respect to Personal Data it stores. Information about how Facebook processes Personal Data is available at https://www.facebook.com/about/privacy. The terms applicable to the various Facebook products set out the purposes for which Personal Data is collected and transmitted.
  • LinkedIn: Information about how LinkedIn processes Personal Data is available at https://www.linkedin.com/legal/privacy-policy.
  • Instagram: Information about how Instagram processes Personal Data is available at https://www.instagram.com/legal/privacy.
  • YouTube: Information about how YouTube processes Personal Data is available at https://policies.google.com/privacy.

11. Changes to Privacy & Cookie Policy

From time to time, the Company may use Personal Data for new, unanticipated uses not previously disclosed in this Policy to the extent permitted by law. If its practices regarding Personal Data change at some time in the future, the Company will post the policy changes to https://www.fisherinvestments.com/en-gb/privacy.

Fisher Investments UK
Employee and Contractor Privacy & Cookie Policy

Last Updated: November 2023

1. General

This Employee and Contractor Privacy & Cookie Policy (“Policy”) is in accordance with the UK Data Protection Act 2018 and the UK General Data Protection Regulation, as incorporated into UK law under the European Union (Withdrawal) Act 2018 and sets out how Fisher Investments Europe Limited, trading as Fisher Investments UK, and its branches (collectively, the “Company”), uses Personal Data relating to the following natural people (“ Individuals”):

  • prospective employees, current, and former employees, whether permanent or temporary (“Employees”);
  • prospective, current, and former contractors, including tied agents (“Contractors”).

In this Policy, “Personal Data” means any information about identified or identifiable Individuals. The Company is committed to privacy and will use Individuals’ Personal Data only in accordance with this Policy.

The Company can be contacted about this Policy using the following details:

Fisher Investments Europe Limited
trading as Fisher Investments UK
Attn: Data Protection Officer
Level 18, One Canada Square
Canary Wharf, London, E14 5AX
United Kingdom
privacy@fisherinvestments.co.uk
+44 0800 144 4731

2. Types of Personal Data

The Company processes the following types of Personal Data for Individuals:

  • records of work history (including internal and external work history and references), education and qualifications (including information provided on an application or CV);
  • contact details (e.g. name, address, email address, telephone number)
  • contact information of spouse / partner / dependent(s) and emergency contact details;
  • date and place of birth and nationality;
  • identification numbers;
  • marital status;
  • background check information, which may reveal data concerning criminal convictions or offences;
  • bank details and account numbers;
  • compensation, fees, bonus or incentive information, tax rates and withholding information (including invoices, amounts paid or withheld, the frequency and currency of payments);
  • expense reimbursements (including receipts and amounts paid)
  • Employee benefits information (e.g. health insurance, pension contributions) (including amounts paid, the frequency and currency of payments);
  • records of performance (including evaluations of competence, ongoing supervision and monitoring under financial services regulations, monitoring activity data as recorded on computer and telecommunication systems, economic viability and ratings, complaints, grievances, and disciplinary records);
  • information relating to Employee absences from work;
  • information relating to Employees’ mental and physical health and mental or physical disabilities (collectively, “Health Data”);
  • general organisational data (such as department, work location, job title and seniority);
  • information technology data (e.g., passwords, access rights and usage data);
  • recordings of telephone calls made by certain representatives of the Company;
  • photographic and video images; and
  • other data that the Individual provides to the Company or its affiliates (collectively, the “Fisher Group”).

Personal Data are collected mainly from Individuals themselves. In addition, the Company collects reference check information from previous employers of (or companies to which services were provided by) Individuals. Background check information, which may reveal data concerning criminal convictions or offences, is collected from Sterling Talent Solutions UK Limited (“Sterling”), a background checking firm that collects Personal Data from both public and private sources with consent of the Individual.

3. Use of Personal Data

a. Purposes and Lawful Bases

The Company processes Individuals’ Personal Data for the following purposes, and upon the legal bases set out in the table below.

Purpose for which the Company uses Personal Data

Legal Basis upon which the Company relies

To manage the recruitment process

This includes making decisions about hiring Employees or engaging Contractors, arranging travel, and reimbursing expenses.

The Company can use Personal Data for this purpose because it is necessary to take steps at the request of the Individual prior to entering into a contract.

To market employment opportunities at the Company

This includes contacting candidates by email, phone or mail who have consented to be considered for future employment or engagement opportunities.

The Company can use Personal Data for this purpose with the consent of the Individual.

To make decisions about Individuals’ fitness for work

This includes making decisions about Individuals’ competence and qualifications to carry out roles, including conducting background checks on candidates for employment or engagements.

The Company can use Personal Data for this purpose where required to comply with legal obligations to which the Company is subject, including the laws and regulations of the UK Financial Conduct Authority and other applicable financial services regulators (collectively, “Financial Services Laws”).

To administer the Company’s relationship with Individuals

This includes administering payroll, processing invoices and reimbursements, providing support services, and, if relevant, pension, medical insurance and similar benefits.

The Company can use Personal Data for this purpose because it is necessary to perform a contract to which the Individual is a party.

To fulfilling legal obligations

This includes verifying identify and work authorization, complying with social security and tax requirements, and providing information to governmental and quasi-governmental bodies and law enforcement agencies.

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws and other applicable laws.

To obtain work authorisation or visas for Employees

The Company can use Personal Data for this purpose because it is necessary to take steps at the request of the Employee.

To train, evaluate performance and recognise Employees and Contractors

This includes training and surveying Individuals, monitoring and analysing performance, carrying out performance reviews, and making decisions about recognition, rewards, discipline and termination.

The Company can use Personal Data for this purpose because it is in the Company’s legitimate interest to evaluate its Employees and Contractors, and to give Individuals opportunities to improve performance.

To administer Employees’ sick leave and absence

The Company may ask for, and Employees may need to provide, Health Data where such information impacts the Employee’s ability to perform his or her role.

The Company can use Personal Data for this purpose where required to comply with employment laws or to protect the health and safety of employees or others.

To monitor Employees and Contractors

This includes monitoring the advice process, recording and monitoring certain telephone calls, supervising Employees and Contractors, including monitoring emails, voicemails and other activities as recorded on computer, telecommunications and security systems, and carrying out the Company’s compliance plan.

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws.

In addition, the Company has a legitimate interest in using personal data for the purpose of supervising employee activity.

To monitor systems

This includes monitoring emails, voicemails and other activities as recorded on computer, telecommunications and security systems, and carrying out the Company’s compliance plan.

The Company has a legitimate interest in using Personal Data for the purposes of ensuring network and information security.

To provide references to future employers and other third parties

This includes providing employment or earnings confirmation letters to banks, mortgage lenders and landlords at the request of the Individual.

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws or with the consent of the Individual.

To keep records

The Company can use Personal Data for this purpose where required to comply with Financial Services Laws and other applicable laws.

In addition, the Company can use Personal Data for this purpose beyond the legally mandated record retention period because it is in the Company’s legitimate interest to keep data for as long as the statute of limitations so that the Company can enforce and defend its legal rights.

To share data with courts and tribunals

The Company can use Personal Data for this purpose because it is in the Company’s legitimate interest to enforce and defend its legal rights.

To use photos and contact information to enable effective communication across the Fisher Group

The Company can use Personal Data for this purpose because it is in the Company’s legitimate interest to ensure effective communication across the Fisher Group.

To use images and recordings to promote the Company in internal and external materials and advertising

The Company can use Personal Data for this purpose with the consent of the Individual.

To conduct candidate research

This includes conducting market research to ask about recruitment and servicing preferences.

The Company can use Personal Data for this purpose when the Company has a legitimate interest in doing so.

To enhance security of Company facilities

This includes the use of video surveillance equipment.

The Company can use limited Personal Data for this purpose because it is in the Company’s legitimate interest to secure its facilities.

Where the Company has relied upon its ‘legitimate interest’ as a legal basis for a particular purpose, it has performed a ‘balancing test’ to ensure that Individuals’ rights and interests are taken into account when their Personal Data is used. Further information on the balancing test can be obtained by contacting the Company’s Data Protection Officer.

b. If Employees/Tied Agents fail to provide Personal Data

Failure of an Individual to provide Personal Data to the Company, in whole or in part, could make it impossible for the Company to fulfil some or all of its obligations towards the Individual, such as payment of compensation or fees, calculation of withholdings, or consideration of an employment application.

4. Sharing of Personal Data

a. Who will the Company share Personal Data with?

The Company will not sell or lease Individuals’ Personal Data to third parties.

For the purposes listed in Section 3 above, the Company may share Personal Data with:

  • Fisher Group companies, including:
    • Fisher Investments (“FI”), the Company’s parent company in the United States;
    • Fisher Investments Ireland Limited (“FII”), a wholly-owned subsidiary of FI in the EU; and
    • Fisher Investments Luxembourg, Sàrl (“FIL”), a wholly-owned subsidiary of FI in the EU.

FI, FII and/or FIL (the “Outsourced Fisher Companies”) act as service providers of marketing, human resources, finance, information technology, legal support services, and investment sub-management and trading functions to the Company. In these capacities, the Outsourced Fisher Companies may have access to Personal Data collected and used by the Company.

  • Company-authorised vendors, service providers, contractors and representatives. These organisations are as follows:
    • Other Contractors of the Fisher Group who have access to Company systems, including email, and receive emails that may include Personal Data of Individuals.
    • Information technology and security providers, including cloud software, communications, internet firewall and malware detection providers.
    • Providers of the Company’s employee benefit programmes.
    • Service providers that carry out checks and assessments at the request of the Company, including Sterling.
    • Service providers that assist Employees with work authorization or visas and/or relocation.
    • Vendors providing training or firm events, which may receive names and/or Company email addresses of Individuals.
    • Photographers and videographers capturing images of Individuals.
    • Providers of third party professional advice, such as lawyers and auditors.
  • Future employers requesting reference checks and third parties (including banks, mortgage lenders and landlords) to which the Individual has requested the Company provide an employment or earnings confirmation letter.
  • Courts and tribunals, as described above in Section 3.
  • Regulators (including the relevant financial regulators), tax authorities, other government agencies and law enforcement organisations, as described above in Section 3.
  • If the Company sells, transfers or merges part or all of its business, or attempts to do so, then third parties may receive Personal Data.

b. What safeguards are in place where Personal Data is transferred outside of the EEA?

Where the Company transfers Personal Data to a data recipient in a jurisdiction outside of the EEA where the laws do not provide an equivalent level of data protection as the country in which the Individual initially provided the data, the Company and the data recipient will make the transfer in accordance with standard contractual clauses approved by the European Commission (“Model Clauses”). Prior to such transfer, the Company will assess and confirm that the protections of the Model Clauses are effective in light of the legal regime in the data recipient’s jurisdiction and, if necessary, adopt supplementary technical, organisational, or contractual measures. For more information on Model Clauses, please visit https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.

Concerning Personal Data transferred to the United Kingdom, if the European Commission has issued a decision that the UK legal regime provides an adequate level of data protection (an “Adequacy Decision”), the Company can transfer Personal Data to data recipients in the UK without the need for additional safeguards. In the event the European Commission has not issued an Adequacy Decision for the UK, the Company and the recipient in the UK will make the transfer in accordance with the Model Clauses, as described above.

Please contact the Company using the contact details in Section 1 with any questions about the legal safeguards in place to protect Personal Data when transferred outside the EEA (including how to obtain a copy or consult these safeguards).

5. Consent

In accordance with applicable data protection laws, Individuals who consent to the Company using their Personal Data may withdraw that consent at any time. Individuals may do so using the details set out in Section 1 above.

When doing so, Individuals should:

  • ensure that a full name and address and/or email address is provided in exactly the form in which it was originally provided to the Company to avoid any possible confusion with a different Individual; and
  • ensure that the particular uses for which consent is being withdrawn are specified. The uses for which the Company relies on consent are set out in Section 3

6. Individuals’ Rights

In accordance with applicable data protection laws, Individuals may exercise the following rights in relation to the Personal Data that the Company holds about them:

  • Individuals have the right to obtain confirmation as to whether or not their Personal Data is being processed and, where this is the case, have access to the Personal Data.
  • Individuals have the right to ask the Company to rectify Personal Data about them that they think is inaccurate. They also have the right to ask the Company to complete data they think is incomplete.
  • Individuals have the right to request the erasure of their Personal Data where there is no compelling reason for the Company to keep using the data. This is not a general right to erasure; there are exceptions, g., if the Company has a legal obligation to keep the data.
  • Individuals have the right to ask the Company to restrict processing of their Personal Data in certain circumstances.
  • The right to data portability applies only to Personal Data Individuals have given to the Company. Individuals have the right to ask that the Company transfer the data to another organisation or give the data back to the Individual.
  • Where Individuals have provided the Company with consent to process their Personal Data, they have the right to withdraw consent at any time. This will not affect the lawfulness of the processing that has been carried out based on Individuals’ consent prior to the withdrawal.
  • When the Company processes Personal Data for purposes of pursuing a legitimate interest, Individuals have the right to object to such processing at any time. If an Individual objects, the Company will stop the processing unless it has strong and legitimate reasons to continue using the data.
  • To exercise these rights, Individuals should contact the Company using the details set out in Section 1 In such case, Individuals should ensure that the full name and address and/or email address are provided in exactly the form in which they were originally provided to the Company to avoid any possible confusion with a different Individual. If Individuals are not satisfied with the way the Company handles the request, they may lodge a complaint with the supervisory authority in the country where that Individual lives or works, or the country where the Individual believes the infringement took place.

7. Security

The Company is committed to ensuring that Personal Data is secure. In order to prevent unauthorised access or disclosure, the Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure Personal Data collected. The Company also uses encryption when collecting or transferring sensitive data.

8. Cookies

A cookie is a small text file with an identification tag that is created and downloaded to a user’s computer (or other device) when accessing websites that use cookies. Cookies allow a website to, among other things, store and retrieve information about a user’s online activity and browsing habits. Depending on the information they contain and user behaviour, cookies may be used to identify the user. 

Cookies can be categorised by who places them:

  • First-party cookies: These cookies are downloaded to a user’s computer (or other device) by the publisher of the website whose service the user is requesting.
  • Third-party cookies: These cookies are downloaded to a user’s computer (or other device) by another entity that may be seeking data obtained through cookies.

Cookies can also be categorised by their duration:

  • Session cookies: These cookies are designed to collect and store data while the user accesses a website. They are often used to store information for the duration of a visit to the website (e.g., what account user is logged into). Once a user leaves the website, the session cookie is deleted.
  • Persistent cookies: These cookies store data on the user’s computer (or other device) for the duration period set within the cookie’s file, which is determined by the entity controlling the cookie and can range from a few minutes to several years, or until the user manually deletes them.

Lastly, cookies can be categorised by the function they serve. The Company uses the following types of first- and third-party cookies:

  • Required: Required cookies are necessary to enable the basic features of this site to function. They keep track of whether or not a user has consented to have other types of cookies placed on their computer (or other device). Required cookies do not collect Personal Data. Required cookies may also include authentication cookies.
  • Statistical: Statistical cookies analyse anonymised site statistics. They enable measuring the number of visitors and analysing how users interact with the website. This information is used to improve the website and the products or services offered.
  • Marketing: Marketing cookies are used to understand user interests, provide relevant ads, and make a user’s online experience more enjoyable. They can be used to build a user profile to provide users with content more relevant to their interests. They adapt advertising and the content users see on other websites based on their website browsing habits, as well as how users interact with internet advertising.
  • Preferences: Preferences cookies allow the website to personalise website content, such as the language selected for viewing the page. These also save a user’s cookie preference settings.

The Company uses first- and third-party required, statistical, marketing and preferences cookies. The following vendors load cookies on this website:

  • Adform
  • Dianomi
  • Doubeclick
  • Drawbridge
  • Facebook
  • Google Ads
  • Google Analytics
  • Hotjar
  • LinkedIn
  • MathMedia
  • Microsoft
  • Outbrain
  • Pingdom
  • Taboola
  • Tag Inspector
  • Tealium
  • Vidyard
  • Vimeo
  • Yahoo/Verizon
  • YouTube
  • Zemanta

For further information on cookies and to manage them, please click here.

Some browsers have a “Do Not Track” setting that allows users to send a signal to the websites they visit that the user does not wish to be tracked. The Company’s website does not respond to these signals.

The websites used by the Company for job postings and submitting applications have their own privacy and cookie policies, which are listed below:

9. How Long Data Will Be Kept

Personal Data relating to Individuals who have entered into an employment or contractor agreement with the Company will generally be kept for the duration of the employee or contractor relationship plus seven years in order for the Company to satisfy its recordkeeping obligations under Financial Services Laws and other applicable law, as well as to enforce or defend its legal rights. An Individual’s Personal Data that forms part of the records of clients may need to be kept for a longer period to satisfy the Company’s recordkeeping obligations under Financial Services Laws with respect to such client records as set out in the Company’s separate Privacy & Cookie Policy. Recordings of telephone calls will be retained for a period of five years in order for the Company to satisfy its recordkeeping obligations under applicable Financial Services Laws. Personal Data relating to candidates will generally be kept for a period of up to one year from the date of collection or the date of rejection. Where a candidate consents to have Personal Data retained by the Company for consideration for future positions with the Company, it will be kept for five years unless the Individual requests earlier erasure of their information.

10. Social Media

The Company maintains a presence on various social media platforms. The terms and conditions set by the operators of the various platforms apply to the Company and any Individuals who interact with the Company through the platforms. More information about each of the various platforms is available below.

  • Facebook: The Company is subject to an agreement with Facebook Ireland Limited, which determines their respective responsibilities with respect to Personal Data. Facebook Ireland Limited is responsible for enabling Individuals’ rights with respect to Personal Data it stores. Information about how Facebook processes Personal Data is available at https://www.facebook.com/about/privacy. The terms applicable to the various Facebook products set out the purposes for which Personal Data is collected and transmitted.
  • LinkedIn: Information about how LinkedIn processes Personal Data is available at https://www.linkedin.com/legal/privacy-policy.
  • Instagram: Information about how Instagram processes Personal Data is available at https://www.instagram.com/legal/privacy.
  • YouTube: Information about how YouTube processes Personal Data is available at https://policies.google.com/privacy.

11. Changes to Privacy & Cookie Policy

From time to time, the Company may use Personal Data for new, unanticipated uses not previously disclosed in this Policy to the extent permitted by law. If its practices regarding Personal Data change at some time in the future, the Company will post the policy changes to https://www.fisherinvestments.com/en-gb/privacy.

Investing in financial markets involves a risk of loss and there is no guarantee that all or any invested capital will be repaid. Past performance neither guarantees nor reliably indicates future performance. The value of investments and the income from them will fluctuate with world financial markets and international currency exchange rates.