Last Updated: November 2023
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”):
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
The Company processes the following types of Personal Data for Individuals:
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.
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.
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.
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:
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.
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).
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:
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:
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.
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:
Cookies can also be categorised by their duration:
Lastly, cookies can be categorised by the function they serve. The Company uses the following types of first- and third-party cookies:
The Company uses first- and third-party required, statistical, marketing and preferences cookies. The following vendors load cookies on this website:
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:
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.
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.
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.
Last Updated: November 2023
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”):
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
The Company processes the following types of Personal Data for Individuals:
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.
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.
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.
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:
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.
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).
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:
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:
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.
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:
Cookies can also be categorised by their duration:
Lastly, cookies can be categorised by the function they serve. The Company uses the following types of first- and third-party cookies:
The Company uses first- and third-party required, statistical, marketing and preferences cookies. The following vendors load cookies on this website:
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:
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.
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.
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.
