Shareholder Privacy Statement
This statement, our “Shareholder Privacy Statement”, explains what personal information we collect about you when you become a shareholder, how we use, share and look after that information, and what your rights are in relation to it.
This Shareholder Privacy Statement applies from 27 June 2019. It applies to you as a shareholder of Imperial Brands PLC shares on our share register.
For details on how we use your personal information as a visitor to our website or when you engage with us in other ways, please refer to our Imperial Brands Privacy Notice.
Who we are
We are Imperial Brands PLC, 121 Winterstoke Road, Bristol, BS3 2LL in the United Kingdom. We are registered as a controller with the Information Commissioner in the United Kingdom with registration number Z7601206.
Personal information we collect
Personal information is any information relating to or which identifies you. We collect the following basic information:
- Name
- Contact details (address, email, phone numbers)
- Shareholder reference number
- Bank details
- Shareholding and related instructions and transactions
- Details of your beneficiaries / nominees / proxies
- Voting instructions
- Voice and/or image
We need to collect national and other ID information to carry out identity checks, which may involve us collecting information that reveals your race or ethnicity. To carry out certain instructions concerning your shareholding, we may need to ask you for details about your health or your marital status.
We collect personal information directly from you or through your broker, agent, trustee, investment or other company that introduces you to us. We may also collect personal information from third parties, such as fraud prevention agencies. Failure to provide the necessary information or to keep us up to date with changes to your personal information may prevent or delay the fulfilment of our obligations to you.
How we use your personal information
We use your personal information for the following purposes:
- to identify you;
- to administer your shareholding;
- to deal with your requests and enquiries;
- to tell you about our shareholder services;
- to pay dividends or other similar payments to you;
- to handle your instructions in relation to your shareholding;
- to provide you with shareholder communications, such as notices of meetings and circulars, and copies of our annual reports and accounts;
- to process any proxy forms;
- to enable you to exercise your shareholder rights, such as voting rights;
- to make efforts to trace you if we lose contact with you and reunite you with your assets;
- to comply with our regulatory obligations;
- to run fraud prevention checks;
- to maintain our share register;
- to understand the composition of our shareholders;
- to keep a record of shareholder meetings;
- to bring or defend legal claims and protect our legal rights.
What is the legal basis that permits us to use your personal information?
We need to tell you the legal basis that allows us to process your personal information. Sometimes we will ask you for your permission to carry out specific processing, such as when we need to conduct ID checks. Otherwise, we rely on the following:
- to comply with our legal obligations (for example, in relation to keeping a register of shareholders or reporting to the Financial Conduct Authority or the London Stock Exchange);
- to comply with our legal obligations to you (for example, in relation to maintaining your account, paying you dividends or sending you the annual report and accounts); and
- where it is necessary to fulfil our legitimate interests (for example, in relation to analysing the composition of our shareholder register to consider how best to serve them, handling complaints or bringing and defending legal claims) as long as those interests are not overridden by your own interests and rights.
Who we share your personal information with
We treat all personal information as confidential. However, sometimes we need to share your personal information with others for specific purposes.
We share your personal information with other Imperial Brands companies and with third-party service-providers to provide shareholder administration services. For instance, we share your personal information with:
- our registrar, Equiniti Limited and other Equiniti Group companies, such as Equiniti Financial Services Limited and Equiniti India, who provide our end to end shareholder administration service to you on our behalf;
- our share plan administrator, Computershare, if you are also a current or former employee;
- our professional advisers from time to time (for example, accountants, lawyers, brokers and other consultants);
- printing firms when we need to send you shareholder correspondence and circulars;
- banks and other payment services providers when we make dividend payments to you;
- service providers that facilitate email, IT and administration; and
- fraud detection agencies as part of our identification procedures.
We may share your personal information with public authorities, law enforcement agencies, regulatory bodies or courts if we are required or permitted to do so by law, or if we consider disclosure necessary to protect and defend our rights or the rights of any third party.
Sometimes, to comply with laws, we have to make a copy of our share register available (for example, for research purposes). We have strict procedures in place for checking the validity of any requests.
In the past, by law, we had to submit annual updates of our share register to Companies House. Your details may still be visible to anybody searching the public record. If you have any questions about this, please contact Companies House at: https://www.gov.uk/government/organisations/companies-house.
The recipients referred to in this section may be located outside the jurisdiction in which you are located (or in which we provide the services). Refer to the “Cross-border transfers” section for more information.
Cross-border transfers
Your personal information will only be transferred to countries in the European Economic Area (the “EEA”) or where the recipient has confirmed an adequate level of protection for it, for instance, by contractual agreement. You can ask us about the arrangements we have in place.
How we look after your personal information
We take measures to ensure a level of security appropriate to the risk to the personal information we process. We evaluate these measures regularly and monitor compliance with our policies, taking disciplinary action where appropriate. Where we use service providers, we require them to take appropriate security measures to protect your personal information.
How long we hold personal information for
We keep your personal information for as long as we need it to administer your shareholdings. If you cease to hold Imperial Brands shares, your record as a shareholder will be kept for a period of up to 12 years following the last update to your record on the shareholder register, or for as long as necessary:
- to maintain business records for analysis, audit or risk management purposes;
- to comply with our legal, regulatory and tax obligations;
- to resolve any outstanding matters in relation to your shareholdings;
- to bring or defend legal claims, protect our rights and enforce our agreements.
Your information rights
You have the right, within certain legal parameters, to ask:
- for details about how we use your personal information;
- to see what personal information we hold about you;
- to correct your personal information;
- to erase your personal information in certain circumstances;
- us not to use your personal information in a particular way;
- to port your personal information in a commonly used electronic format;
- us to restrict how we use your personal information; and
- not be subject to automated decisions about you and to request human intervention.
If we have asked you and you have given us permission to use your personal information in any particular way, you have the right to withdraw that permission at any time. For more information and to exercise your rights, please contact us using the details below.
It is important that the personal information we hold about you is up to date. Please let Equiniti know if your personal information changes. Equiniti’s details can be found in the “Contact” section below.
Changes to this Privacy Statement
We may make changes to this Privacy Statement at any time. We will do this by posting an updated version of the Privacy Statement on our website. We recommend that you check this page from time to time to ensure that you are aware of any changes.
Contact
Your normal point of contact for shareholder matters is Equiniti, our registrar, and their details can be found here
If you have a query or complaint about how we handle your personal information, please contact us:
By post:
Senior Privacy & Legal Compliance Counsel
Imperial Brands PLC
121 Winterstoke Road
Bristol, BS3 2LL
By email:
data.protection@uk.imptob.com
Lodging a complaint
If you have made a complaint to us about how we handle your personal information that we have not been able to resolve, you have the right to complain to the UK’s Information Commissioner’s Office at https://ico.org.uk.
