Privacy Policy
Lloyds Estate Administration Service Beneficiary Portal Privacy Notice
Last updated: January 2021
We understand how important your
personal data is and are committed to protecting and respecting your privacy.
‘Personal
Data’ means any
information relating to or which identifies you. This can include items
such as your name, address, phone number, identification numbers (such as an
account number or your national insurance number), location data or online
identifiers. Personal data can be held electronically or in certain paper
records.
The UK General Data Protection Regulation (UK GDPR) regulates the processing of personal
data. The UK GDPR seeks to protect your rights to your personal data by
setting out, amongst other things, the conditions under which the processing of
personal data is lawful, the rights of data subjects and the standards that
organisations that handle personal data must adopt. This Privacy
Notice is issued in compliance with UK GDPR
and seeks to explain:
1. Who we are;
2. All website
addresses covered by this Privacy Notice;
3. How we collect your
personal data;
4. Why we collect your personal
data;
5. How long we hold
the personal data;
6. The conditions
under which we may share it with others;
7. Overseas
processing;
8. How we keep your
personal data secure;
9. Your personal
data rights and how to exercise them;
10. Useful information;
11. EU GDPR;
and
12. Any further questions.
1. Who
we are
Equiniti Limited (EL) is one company
within the Equiniti Group. Our main business is administration
services. Our registered address is Aspect House, Spencer Road, Lancing,
West Sussex, BN99 6DA and our ICO registration number is: Z1028602.
EL is a ‘Data Processor’.
This means that we are responsible for processing the personal data we hold
about you.
In this Privacy Notice, ‘we’, ‘us’
and ‘our’ will always mean EL, as Data Processor.
If you have any questions about our
website or services, please contact us at EAExeter@estateadmin.lloydsbanking.com
2. All
website addresses covered by this Privacy
Notice
· https://estates.lloydsbank.com
IMPORTANT
This Privacy Notice relates only to
the webpages that you log into as part of the portal service listed above and
your online account.
3. How
we collect your personal data
We may collect and process the
following personal data about you:
Information you provide to us
o By filling in
forms on our website(s) so that we may contact you;
o By corresponding
with us by phone, e-mail, live-chat, social media channels or otherwise;
o Application/registration
forms/identification documentation;
o Entering surveys;
and
o When you report
any problem or complaints with our website, products and services.
Information we collect about you
o Information about how you logged
on and off of our website(s), including your IP address, information about your
visit, your browsing history, and how you use our website. This will
include the capture of your location information – please see our Cookie
Policy for further information on this;
o If you contact us
via social media, we may collect details from your social media account.
Information we receive from third
parties
o As part of our identity and
financial crime checking procedures with credit reference agencies, fraud
detection agencies and registration or stockbroking industry exchanges;
o From third parties when you have
instructed or agreed for them to pass information to us or as part of their
offering services to you.
o From online advertising networks
(for example Google) through whom we place advertisements. The
information we obtain varies from network to network. It often summarises
the actions of lots of people and so does not enable us to identify you
individually. It relates to what you view, click on, and access through
websites in their network, including the subject matter of the website you
started at and where you subsequently go. It might also include their
analysis of your behaviour across the wider internet and a profile of
you.
If
you are unhappy about this happening you should look out for ‘settings’ and ‘Do
Not Track’ options in online advertisements and in the privacy and cookies
functionality on your devices and consider changing your settings to block
third party cookies in particular. We do not control the information on
you that such networks obtain, or the technology they use to do so.
Special types of data– The law and other regulations treat some types of
personal information as special. We will only collect and use this information
if the law allows us to do so. Special types of data are:
o Criminal convictions
and offences;
o Genetic and
bio-metric data;
o Health data
including gender;
o Racial or ethnic
origin;
o Religious or
philosophical beliefs; and
o Trade union
membership.
Keeping your personal data up to date
The personal data we hold may include
your name, postal address, email address and phone number, date of birth and
financial information to enable us to contact you and respond to your enquiries
as well as provide you with our products and services.
It is important to us that the
personal data we hold about you remains accurate and up to date at all times,
but we need your help in doing this. Please let us know as soon as
anything needs updating or correcting.
Other people’s personal
data
The information you give us, or that
we collect through your use of our services, may contain your or another
person’s personal data. If you provide us with information about another
person, you confirm that they have appointed you to act for them, they consent
to you providing their personal data to us and any processing of their personal
data and that you have informed them of our identity and the purpose for which
their personal data will be processed – as set out in this Privacy Notice.
4. Why
we collect your personal data
In the table below we demonstrate why
and how we use your personal data as well as providing the legal reasons which
we rely upon.
Under Data Protection legislation we
must always have a legal reason for processing your personal data. One of
the legal reasons is when we use your personal data for our legitimate
interests, this is usually when we have a business reason. However, we
must always ensure that we take your interests into consideration too, and
ensure that the use is fairly balanced. We tell you below when we rely on
legitimate interests and what our legitimate interests are.
Type of processing | Purpose of the processing | Lawful basis for the processing of personal data |
Provision of services, including the
administration and management of customer records | To manage and operate your online account with us
to facilitate the provision of services, this includes retaining records of
your instructions and telephone calls and keeping your online account records
up to date. To respond to any data rights that you invoke. To complete any transaction or instructions that
you provide us, and any legal obligations we have in relation to the
transactions / instructions. To keep our websites and portals secure and
permit you safe access to our services. Enforcing or obtaining a settlement of debts owed to us or in relation
to investments made on your behalf. | The performance of a contract between you and us and/or taking steps,
at your request, to enter into such a contract. To comply with legal requirement placed upon us, such as Data
Protection legislation Our legitimate interests, such as the proper
administration of our service and business, for example:
With your consent. |
Marketing our products and services | To allow you to participate in interactive features of our website, when
you choose to do so. To provide you with the information, products and
services that you request from us. | With your consent. When we have collected your personal data as part of a transaction
with us o Our legitimate interests, such
as the proper administration of our service and business, for example:
To meet our regulatory requirements. |
Improving our products and services | To identify service improvements such as when troubleshooting,
undertaking data analysis, testing new products, using your personal data for
research, statistical and survey purposes. o To ensure that content from our websites are
presented in the most effective manner for you and for your device. o How we manage and work with other companies in the
delivery of our products and services. o To study how you and our other customers use our products
and services. o To measure or understand the effectiveness of
advertising we serve to you and others, and to deliver relevant advertising
to you, which can be based on your activity on our website(s) or the website
of another Equiniti Company or third parties’ websites. We can do this
ourselves or appoint an agency to do this on our behalf. | With your consent. To comply with legal requirements placed upon us,
such as the Data Protection legislation. Our legitimate interests, such as the proper
administration of our service and business, for example:
Some of this information will be gathered by cookies that you have
consented can access your computer. Please see our cookie policy for
further information on how to manage cookies. |
If you choose not to give personal
information
We need to collect personal
information required by law or under the terms of service you have elected to
use. If you choose not to give us the personal data we need, it can mean
that we have to cancel or decline a service that you request or have with
us. So that you know what information is optional, we make it clear at
the time we collect your personal data.
5. How
long we hold your personal data for
Personal data will not be retained
for longer than necessary for us to achieve the purpose for which we obtained
your personal data. We will then either securely delete it or anonymise
it so that it cannot be linked back to you. We review our retention periods for
personal data on a regular basis.
We will retain personal data for 10 years following the completion of
the estate for the reasons noted below:
o To respond to enquiries and
complaints;
o To demonstrate that your
instructions were carried out properly; and
o To maintain records to meet
rules and regulatory requirements that are applicable to the request you made
or the service you were using.
We can keep your data for longer than
stated above if we cannot delete it for legal, regulatory or technical reasons.
We can also keep it for research or statistical purposes. If we do, we will
make sure that your privacy is protected and only use it for those purposes
For full details of our retention
policies, please contact us at:
EAExeter@estateadmin.lloydsbanking.com
6. The
conditions under which we may share your personal data with others
The personal data we hold about you
is confidential, and we will only share your personal data to enable us to
deliver our product(s) or service(s), examples are as follows:
· At
your request, or with your consent;
· Other
Equiniti Group companies who help us deliver our products and services, such
Equiniti India Private Limited;
· Non-Equiniti
entities, in connection with running accounts and services for you, including:
- Service
suppliers to facilitate website, email, IT and administration services;
- Selected third parties in accordance with any
specific instructions you provide to us including:
- Lloyds Banking Group
- Our
professional advisors, for example, our lawyers and technology
consultants, when they need it to provide advice to us;
- Your
agent(s), in accordance with any specific instructions you provide to us;
- Market Research Agencies to measure or
understand the effectiveness of advertising we serve to you and
others. We may do this ourselves or appoint an agency to do this on
our behalf. This will include your use of social media sites;
- Credit reference agencies and fraud detection
agencies as part of our identification procedures;
- Fraud prevention agencies who will use it to
prevent fraud and money-laundering and to verify your identity. If fraud
is detected, you could be refused certain services, finance, or
employment. Further details of how your information will be used by
us and these fraud prevention agencies, can be obtain by contacting the
Equiniti Data Protection Officer using the details noted below; and
- Your
Official Receiver or appointed insolvency practitioner if we receive
notice of your insolvency, bankruptcy or insolvency proceedings /
arrangement
We will only transfer your personal
information to trusted third parties who provide sufficient security guarantees
and who demonstrate a commitment to compliance with applicable law and this
policy. Where third parties are processing personal information on our
behalf, they will be required to agree, by contractual means, to process the
personal information in accordance with the applicable law. This contract will
stipulate, amongst other things, that the third party and its representatives
shall act only on our instructions, or as permitted by law.
We are also required to share your
personal data with external third parties as follows (but not limited to):
· Regulators
and supervisory authorities e.g. Information Commissioner’s Office
(ICO) as part of our legal obligations;
· Where
the law requires or permits disclosure, or there is a duty to the public to
reveal it;
· When
we need to defend or exercise our legal rights or those of a third party;
· Debt
collecting, debt chasing or another agent for enforcing payment of monies owed
to us;
· Efforts
to trace you if we lose contact with you;
· Police
and other law enforcement agencies for the prevention and detection of crime
and where a valid permission is applicable;
· As
a result of a court order or other regulatory instruction; and
· Our
insurers and insurance brokers where required for underwriting our risks and as
part of ongoing risk assessments
We may transfer your personal data to
a third party as part of a sale of some or all of our business and assets to
any third party or as part of any business restructuring or reorganisation. At
all times, we take steps to ensure your privacy rights continue to be protected
as per this Privacy Notice.
7. Overseas
Processing
Personal data will be shared with
members of the Equiniti Group outside of the UK, including Equiniti India which
is based in India, for the purposes described in this policy. For transfers to
Equiniti India, we utilise Model Clauses recognised by the European Commission.
If you would like to obtain a copy of the Model
Clauses we use to share personal information within the Equiniti Group, please
contact our Data Protection Officer using the details provided in this Privacy
Notice.
Please note that information
protection laws do vary from country to country. In particular, the law
of the country in which you are resident or domiciled may offer a higher
standard of protection than the laws in the United Kingdom and / or those other
countries in which we store and use the personal data we
collect. Our transfer of personal data to other countries could result in
that personal data being available to governments and other authorities in
those countries under their laws.
By using our Service, you agree to
this international transfer, storing and processing.
8. How
we keep your personal data secure
We understand how important your
personal data is to you and we take its security very seriously.
We safeguard your personal data
across all our computer systems, networks, websites and offices as much as
possible through appropriate procedures and technical security measures
(including strict encryption, anonymisation and archiving techniques).
We also use secure ways of
communicating with you such as when collecting your personal data or providing
your account information:
- online through the use of ‘‘https’’ and other
security and encryption protocols. This is indicated by a lock icon on the
bottom of the web browser, or the address will include the letters https
in the top left-hand corner; and
- before we discuss matters relating to your
account(s) by telephone we will always ask you security questions to
confirm your identity
Where we have given you (or where you
have chosen) a password or unique identifier (PIN) which enables you to access
certain parts of online services, you are responsible for keeping this password
/ PIN confidential, along with any username. We will never ask for your full
password or PIN, and you must not divulge your full password to us or anyone
else. We recommend that any password or PIN you set is not easily
guessable, and changed frequently (at least once a month).
Because we cannot guarantee the
confidentiality of personal data sent on the internet you should never send
your login details via email.
Security concerns
If you ever receive a communication
from us by post, email or by phone that you are concerned it is not genuine,
please contact us using the contact details in Section 11.
You must immediately inform us if you
become aware, or suspect, that someone else has knowledge of your account
details.
If you have any concerns about the
security of your own personal computers and mobile devices, we suggest you read
the advice of Get Safe Online, which can be accessed at www.getsafeonline.org.
9. Your
personal data rights and how to exercise them
You have rights in respect of the
personal data that we hold about you. They include the right to request a
copy of the information that we hold about you, to know about any automated
decisions that are made about you and to change your marketing preferences at
any time. Details about all of your rights are provided below.
Some of these rights are conditional
and depend upon why we are processing your personal data. This means that
we cannot always be able to respond to your request in the way that you
want. For example:
o If you ask us to erase your
personal data and we are processing the information because we are required to
do so because of a legal requirement, we will not be able to delete your
personal data; however,
o If you ask us to
erase your personal data and we are processing the information because you
provided us with consent (for example as part of a survey response), we will be
able to consider and respond to your request.
Your rights | Explanatory detail |
The right to be informed about how we use your
personal data. | This Privacy Notice provides you with the details
on how we use and process your data. |
The right of access to a copy of
any personal data processed about you, together with certain additional
information. | If you request to see your personal data, your
initial request will be free of charge; subsequent requests may attract an administration
fee. The additional information includes details of the categories and
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. |
The right to request us to rectify or
update it. | This will be relevant where the personal data we
hold is or has become inaccurate or incomplete, taking into account the
purposes of the processing. Please explain why you consider the data
inaccurate or incomplete. |
The right to request us to erase your
personal data in certain circumstances. | The circumstances when erasure can apply include
when we no longer need your personal data to meet a lawful basis for
processing unless that basis is consent and you withdraw your consent or you
object to the processing or the processing is unlawful. However, certain exclusions apply - where the
processing is necessary for compliance with a legal obligation or to
establish, exercise or defend legal claims. |
The right to request us to restrict processing
it. | This request can be used to stop us processing
your personal data: if you disagree over the accuracy of the personal data
until we have verified the data; the reason for processing; or if you wish us
to retain your personal data for longer than our retention period, e.g. to
establish, exercise or defend a legal claim. |
The right to request a copy of your information
for data portability purposes. | If you have provided personal data to us
under contract or because you consented to
the processing and use of the data by automated means,
then you have the right to instruct us to transmit that personal data to
you or another data controller in a machine-readable format. |
The right to object to us
processing your personal data. | You have a right to object to us processing your
data where we are processing it for the purpose of legitimate interests. You can also object to direct marketing
communications from us about products, offers, competitions, or services and
any profiling that we can perform in relation to direct marketing. You
can do this at the point of data collection, through the use of any opt-out
functionality on text and emails, via your preference centre or by contacting
the helpline service. You can update your marketing preferences at any
time through the use of the opt-out functionality. You have the right to withdraw your consent at
any time. However, this will not affect the lawfulness of processing before
the withdrawal. If you would like to receive the marketing
described above, please ensure you have indicated your preferences
accordingly. |
Rights related to decisions based solely on automated
processing. | Where this processing produces legal effects or
significantly affects you, you can object to this processing unless the processing
is necessary as part of our contract, or is required by
legislation. |
Right to lodge a complaint with
a supervisory authority. | If you wish to raise a complaint on how we have
handled your personal data, please contact our Data Protection team who will
investigate the matter and report back to you. If you remain unsatisfied with our response or
believe we are not processing your personal data in accordance with the law,
you are able to contact the Information Commissioner’s Office (ICO) who
regulates UK Data Controllers compliance with data protection legislation.
They can be contacted by email: casework@ico.org.uk, post: Information Commissioner's Office, Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF or by telephone: 0303 123 1113. |
10. Useful
information
10.1 - Children (16 years and under)
and Vulnerable Adults
We are committed to the privacy
protection of children and vulnerable adults. If you are aged 16 or under‚ and
we need to process your personal data you must obtain the permission of your
parent/guardian before you share your personal data with
us. If we are notified that you are a vulnerable adult we will liaise
with your authorised representative, once we are in receipt of the appropriate
permissions.
10.2 - Use of ‘cookies’
For full details of how we use
cookies, please refer to this website’s cookies policy.
10.3 - Links to other websites
Our websites can contain links to
other websites run by other organisations, or other Equiniti Group
companies. When you are on another website, we encourage you to read
their privacy policies as they will take precedence over this Privacy Notice.
10.4 - Social media,
blogs, reviews, and similar services
Any social media posts or comments
you make to us (e.g. on our own Facebook page) will be shared under the terms
of the relevant social media platform (e.g. Facebook or Twitter) on which they
are made and could be made public by that platform. These platforms are
controlled by other organisations, and so we are not responsible for this
sharing. You should review the terms and conditions and privacy policies of the
social media platforms you use to ensure you understand how they will use your
information, what information relating to you they will place in the public
domain and how you can stop them from doing so if you are unhappy about it.
Any blog, review or other posts or
comments you make about us, our products and Services on any of our blog,
review or user community services will be shared with all other members of that
service and the public at large.
You are responsible for ensuring that
any comments you make comply with any relevant policy on acceptable use of
those services
10.5 - Changes to this
Privacy Notice
We review our use of your personal
data regularly. In doing so, we can change what personal data we collect,
how we keep it and what we do with it. As a result, we can change this
Privacy Notice from time to time to keep it relevant and up to date.
We will endeavour to alert you to
these changes so that you can check you are happy with it before proceeding any
further. Please look out for notices from us alerting you to these
changes, via our websites or other timely communications. If you use our
websites and see such an alert, please take a moment to ensure that you’re
happy with any changes.
By continuing to use our products and
services, you will be bound by this Privacy Notice.
However, we will also tell you of the
changes where required by law to do so.
This policy was issued on 18.01.2021.
If you require copies of previous versions of the Privacy Notice, please
contact the Data Protection Officer using the contact details noted below.
11. EU
GDPR
The European Union adopted the
European General Data Protection Regulation (EU GDPR) on May 25, 2018 and you
are protected by the provisions of the EU GDPR if you are in the EU.
The information within this Privacy
Notice meets the EU GDPR requirements, however, you also have the right to
lodge a complaint (as per section 9 above) with your relevant data protection
supervisory authority.
12. Any
further questions about this Privacy Notice
We hope that this Privacy Notice has
been helpful in setting out how we handle your personal data and your rights to
control it. If you have any questions that remain unanswered, please
contact our Data Protection Officer:
- By email at DPO@equiniti.com,
- By post at Data Protection Officer,
Equiniti, Highdown House, Yeoman Way, Worthing, BN99 3HH, or
- By telephone on 0333-207-5962 (from UK) and
+44 121-415-0196 (from overseas).
(Lines are open 8.30am to 5.30pm (UK
time), Monday to Friday (excluding public holidays in England and Wales).