Neville Registrars Limited is committed to respecting your privacy. The purpose of this Privacy Policy is to explain how NR processes and stores the data it holds on behalf of its Issuers.
This document covers:
- The types of information we hold on behalf of Issuers;
- How we hold and use the data;
- Who we share the information with;
- The steps we take to make sure it stays secure; and
- The rights of the members to their information.
In accordance with the terms of our service contract with the Issuer, we are appointed (as their agent) to maintain the Issuer's register(s) of holders of shares, debentures or other securities and to carry out all specified registration, transfer, receiving or settlement agent services on the Issuer's behalf and in accordance with applicable laws and regulations.
It is of the essence of the agency relationship which we have with our Issuers that the information which we are given belongs to our Issuers and is received and stored by us on their behalf: conversely, any relevant register information received by our Issuers is made available by them to us.
What information do we hold on behalf of the Issuer?
Our function as a registration agent is to keep and maintain the statutory register of members on the Issuer's behalf. Every Issuer is required to keep and maintain a register of its members (under section 113, Companies Act 2006) and the register is evidence of who the members of the Issuer are and the shares, debentures or other securities they hold. Register entries for former members may be removed after 10 years from the date they cease to be members.
In addition to the register of members, we may also hold information about members that has been provided to us either directly by members, or by the Issuer.
We receive information about members:
- from the Issuer;
- directly from a member; or
- from a third party acting on behalf of a member (e.g. their intermediary or stockbroker).
We will only hold (and process) member information in line with relevant regulations and law and our service contract with the Issuer, for the purpose of administering the register of members.
What do we do with the information we hold about members?
We process the information we hold about members for the following purposes:
- To enable the Issuer to meet its statutory duty to keep and maintain its statutory register of members;
- To allow us to discharge our duties and obligations as registration agent to the Issuer in accordance with the terms of our service contract and the Issuer's articles of association;
- To facilitate the sending of statutory communications to members on the Issuer's behalf and only on its specific instruction;
- To record responses to direct communications with members and to report them to the Issuer; and
- To allow us to provide current or historic copies of the register of members, share transfer reports, payment records or other information relating to the register of members, to the Issuer or its advisers, as instructed by the Issuer and in accordance with our service contract.
Who do we share member information with?
As a registration agent, our role is to keep and maintain the register of members on behalf of the Issuer. As such, we share member information with the Issuer, its professional advisers (as instructed from time to time by the Issuer) and in order to comply with any imposed legal or regulatory requirements, all in accordance with our service contract with the Issuer.
We do not, under any circumstances, share member data with third parties for advertising, marketing or sales purposes.
How do we keep your information secure?
All information that we hold is stored securely in an access-limited and audited database. We take appropriate security measures to protect such information from unauthorised access, including utilisation of data encryption.
We retain information only for as long as necessary to meet our contractual and legal obligations as a registration, transfer, receiving or settlement agent.
When member data is transferred we use only secure methods of transmission, so that the data can be retrieved in an audited and limited manner by the recipient(s).
If you have any additional questions about the security or retention of member data, you can contact us at info@nevilleregistrars.co.uk.
What rights do members have to their information?
Individuals have rights to their data which we will respect and comply with to the best of our ability. Individuals can exercise their rights in the following ways:
- Right of access – enabling individuals to access their personal data.
- Right to rectification – we will, if requested, rectify or amend the personal data of the individual which is inaccurate or incomplete.
- Right to erasure – subject to our legal requirements, we will delete or remove an individual's data if requested, it is not required to be kept by law and there is no compelling reason for its retention.
- Right to restrict processing – subject to our legal requirements, we will comply with any request to restrict, block, or otherwise suppress the processing of personal data.
- Right to data portability – we will provide individuals with their data so that they can reuse it for their own purposes or across different services. We will provide it in a commonly used, machine-readable format.
Cookies
Neville Registrars do not currently employ the use of cookies for tracking user data but do utilise session cookies which allow users to move freely through the Sharegateway without the need for continual re-authentication. Session cookies are erased when a browser session is terminated.
Users can refuse cookies by turning them off in their browser or opting to be notified each time a cookie is issued.
Changes to our Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy on our website and any other places we deem appropriate, so that you are aware of what information we hold, how we use it and under what circumstances, if any, we disclose it.
If we make material changes to this Privacy Policy, we will notify you here, by email, or by means of a notice on our website home page.
Contact us
If you have any questions, concerns or complaints about this Privacy Policy, our practices or our services, you may contact our office and our privacy officer by email at info@nevilleregistrars.co.uk
Alternatively, you may contact us either:
- By Mail: Attn: Privacy Officer, Neville Registrars Limited, Steelpark Road, Halesowen, West Midlands, B62 8HD; or
- By Phone: +44 (0)121 585 1131.
We will respond to all requests, enquiries or concerns within thirty (30) days.
