EMEA Privacy Notice
EMEA Privacy Notice
We take your privacy seriously and value transparency at the highest possible standard. For more than half a century, we have continued to operate inside of the Europe, Middle East and Africa region and to meet the privacy needs of our clients.
This notice sets out how members of the Northern Trust group (collectively
and individually, "Northern Trust", "we" or "us") will process personal information
as a controller or joint controller in connection with the:
In this notice, "you" means:
If you have any questions about our use of your personal information, please
contact our Data Protection Officer at Privacy_Compliance@ntrs.com.
How and why we obtain your personal data may depend on the capacity in which you interact with us.
We will obtain some of your personal information directly from you, such as when
you are a customer for our products and services or you complete a form, sign up for
marketing or choose to give us personal information as part of the Northern Trust
Matrix, including in connection with the security features of the Northern Trust investor
portal forming part of the Northern Trust Matrix ("Matrix Portal").
We will also obtain some of your information indirectly from Northern Trust clients,
from Funds, from an investor in the Fund(s) (each an "Investor"), or from a Manager,
where you have been appointed by that client, Investor or Manager to access and use
Northern Trust products and services, including the Northern Trust Matrix, on its
behalf. Where you are an investor in a Fund, references to Investor in this notice
should be read as references to you.
We will also obtain some of your information indirectly when we provide the following services to our institutional clients:
We will receive information about you when Northern Trust acts as a service
provider to its institutional clients and where you represent or are employed by such
an institutional client or where you are an underlying investor, shareholder, settlor,
beneficiary, director, officer or beneficial owner of such institutional client. We
also obtain information about you from our service providers and business partners
where you work with us in the course of their business.
We will also collect some information from you when you interact with our
websites or visit our premises.
Where we obtain personal information from you in respect of the third parties, you warrant that you are authorised to provide that information to us, that you will only do so in accordance with applicable data protection laws, and that you will ensure that before doing so, the individuals in question are made aware of the fact that Northern Trust will hold information relating to them and that it may use it for any of the purposes set out in this privacy notice, and where necessary that you will obtain consent to Northern Trust's use of the information.
The types of personal information collected by Northern Trust.
Northern Trust Matrix and Other Services
The types of personal information
collected by Northern Trust include, without limitation:
Operation of the Business
Northern Trust will also collect
and use information in the day-to-day operation of our business, including:
Operating our Electronic Infrastructure
Northern Trust will
collect information through your use of our website or other online services such
apps, including:
Northern Trust may process your personal information for the following
purposes:
Relationship Management and Administration
The legal bases for this processing are:
Development and Management of our Services
Northern
Trust may process your personal information for the following purposes:
The legal bases for this processing are:
Crime Prevention and Detection
Northern Trust may process
your personal information for the following purposes:
The legal bases for this processing are:
Other Legal and Regulatory Obligations
Northern Trust
may process your personal information for the following purposes:
The legal bases for this processing are:
Protection and Administration of our Physical and Electronic Infrastructure
Northern Trust may process your personal information for the following purposes:
The legal bases for this processing are:
Northern Trust Matrix
We may use personal information
which you provided in connection with an investment in a Fund, or which we have received
from a Fund or Manager as a result of services which we provide to that Fund or Manager,
for the purposes of the services provided via the Matrix Portal. We may also use this
information for the purposes of providing services to other Funds (or their Managers)
in which you have invested or in respect of which an Investor has appointed you to
access the Matrix Portal.
Northern Trust may process your personal information
in connection with the Northern Trust Matrix:
Where an Investor has agreed to Northern Trust’s centralised AML procedures,
and your personal data is required in connection with that Investor’s AML compliance
Northern Trust, may process your personal data as a controller by:
• Retaining AML and other records of individuals to assist with the subsequent screening and ongoing AML customer due diligence and monitoring of Investors by Northern Trust and its affiliates, including in relation to other funds or clients of Northern Trust or any of its affiliates.
Where you have subscribed to use Matrix Portal Northern
Trust, as a controller, will additionally use your personal data for:
The legal bases for this processing are:
Northern Trust will not at any time be acting as a joint controller with its institutional clients or a Fund.
While this notice sets out how Northern Trust will use your personal data as controller (and as joint controller with other members of the Northern Trust group), you should also note that where Northern Trust provides services to a Fund or other institutional client, Northern Trust will continue to act as a processor for that institutional client, Fund and / or its Manager, which will act as controller(s). You should refer to the relevant controller's data protection notice to understand how your personal information will be used in connection with that institutional client or investment in that Fund by you or the Investor that has appointed you to act on its behalf. Northern Trust will not at any time be acting as a joint controller with its institutional clients or a Fund.
Northern Trust may disclose your personal information as follows:
We maintain a global operating model to provide services and products to
clients globally.
Northern Trust maintains a global operating model to provide services and products
to clients globally. The disclosure of personal information to the third parties set
out above may therefore involve the transfer of data to the USA and other jurisdictions
outside the European Economic Area (“EEA”) in accordance
with applicable data protection laws in your jurisdiction.
Where such
countries may not have the same data protection laws as your jurisdiction, and are
not recognised as having an adequate level of data protection by the European Commission
or under data protection law in your jurisdiction, we take appropriate steps to implement
alternative arrangements to ensure your data continues to be adequately protected
and your privacy rights respected.
Northern Trust has put in place Standard
Contractual Clauses with relevant parties to whom personal data will be transferred.
Where required, the Standard Contractual Clauses are accompanied by measures that
support an adequate level of data protection, including controlling access to data
by third parties, law enforcement and regulators.
Please contact Privacy_Compliance@ntrs.com for copies of the Standard Contractual
Clauses that have been entered into by Northern Trust.
Northern Trust will retain your personal information for as long as required
for Northern to perform the services.
In general terms, we will
retain your personal information for the length of time we perform the services (including
the Northern Trust Matrix) or the service to the institution you represent. We may
maintain different retention periods for different products and services.
We will also retain your personal information for the period as required by tax
and company laws, or other regulations such as anti-money laundering and know-your-customer
regulations, to which we or your institution are subject, and as long as necessary
for you to be able to bring a claim against us and for us to defend ourselves against
any legal claims. This will generally be the length of the relationship plus the length
of any applicable statutory limitation period under local laws.
In certain
circumstances, information may need to be retained for a longer period of time, for
example where we are in ongoing correspondence or there is a continuing claim or investigation.
Northern Trust will retain your personal information for as long as required
for us to perform the services.
Northern Trust will use reasonable efforts to keep your personal information up to date. However, you will need to notify Northern Trust without delay in the event of any change in your personal circumstances, or those of the others mentioned above, so that Northern Trust can keep the personal information up to date. You should do this through Matrix Portal or by contacting Privacy_Compliance@ntrs.com.
You have the following rights, in certain circumstances and subject to certain exceptions, in relation to your personal information:
Where you have provided your consent to processing (e.g. to receive information
about products and services which may be of interest to you or the institution you
represent), you may withdraw your consent at any time. You can withdraw your consent
or exercise your rights by contacting Northern Trust here.
Where Northern Trust
requires your personal information to comply with AML or other legal requirements,
failure to provide this information means Northern Trust will not be able to provide
services to you or the institution you represent, facilitate dealings in the Fund(s)
(whether electronic or otherwise) or the provision of information in relation to the
Funds to you via the Matrix Portal.
You have the right to lodge a complaint in relation to Northern Trust’s
processing of your personal data:
If you have any questions about our use of your personal information, please contact our Data Protection Officer at Privacy_Compliance@ntrs.com, and/or:
* These entities also act as joint controller for the purposes of providing Northern Trust Matrix services.