Privacy notice

Personal data that we collect about you

• Contact details, such as name, postal address, telephone number and email address
• Information about your job, appraisals, performance, compensation, pension, benefits, training
• Education, information obtained from references or background checks
• Health, disabilities, absences
• Financial and transactional data, such as bank account information, payroll records and tax statusinformation
• Security Pass photograph
• Other personal data, such as date of birth, NI number, and:
  • Any data relating to you that could identify you from that data (or from that data and any otherdata in the Company’s possession). E.g. Disciplinary and grievance information, informationobtained through electronic means such as swipe card and key fob records, Shareholding, optionand dividend entitlement, Next of kin, details of family members and emergency contacts.
  • Information relating to your personal characteristics and self-identity, such as information aboutyour age, race or ethnicity, religious beliefs, long-term health condition or disability, sex orgender (including gender identity), sexual orientation, caring responsibilities, parentalresponsibilities and/or socio-economic background having regard to current equality legislationand/or regulatory guidance or rules relating to equality, diversity and inclusion. In particular, theFCA is currently consulting on proposals to introduce requirements for regulated firms to annuallycollect, publish and report on data across a range of demographic characteristics (some to bemandatory and others voluntary, with the potential to become mandatory in the future), inclusion metrics, and targets via a regulatory return. SEI will be impacted by these proposals and is in the process of preparing for their implementation.
• Information about your health, including any medical condition (regardless of length), disability healthand sickness records, including:
  • details of any absences (other than holidays) from work including time on statutory parental leaveand sick leave;
  • where you leave employment and the reason for leaving is related to your health, informationabout that condition needed for pensions and permanent health insurance purposes.
  • Information about criminal convictions and offences.

• work-related details such as your job position, contact details, performance at work, absences, pay andbenefits information, service history, a copy of your employment agreement, passport details,photograph, health information, pregnancy and/or disability status;
• personal data that we collect through your use of our email system (including but not limited to your fullname, email address and the content, date and time of your email correspondence);
• information obtained through an exit interview with you (upon your departure from our organisation),including your reasons for leaving.
• Information obtained from third parties (including swipe card records from building management inrelation to access to the building)
• Information relating to your personal characteristics and self-identity having regard to current equalitylegislation and/or regulatory guidance or rules relating to equality, diversity and inclusion.

• Payroll
• Benefit providers
• Background screening agencies, including credit reference agencies
• Trustees or managers of pension arrangements
• Employment / Recruitment agencies

Uses of your personal data

• to meet our legal and regulatory obligations as an employer, and perform our obligations and exercise ourrights under your contract of employment with us. For example, we use your personal data to pay you, toevaluate your individual performance, and provide benefits in connection with your employment;
• we will use the private contact details relating to you and your next of kin (and that you have provided tous for emergency purposes) only in connection with an emergency;
• we will process personal data related to your use of our email system in order to enable the effectiveoperation of the email system and ensure that it is used in accordance with our policies and procedures;

• we need to in order to perform our obligations and exercise our rights in connection with youremployment contract with us;
• we may need to for the purposes of occupational health and to take decisions regarding your fitness forwork;
• we have legal and regulatory obligations that we have to discharge;
• we may need to in order to establish, exercise or defend our legal rights;
• the use of your personal data as described may be necessary for our legitimate business interests (or thelegitimate interests of one or more of our affiliates), such as:
  • allowing us to effectively and efficiently administer and manage the operation of our business;
  • ensuring that as an employer of choice we are able to monitor, measure (and therefore progressand improve) our equality, diversity and inclusion statistics, for example in relation to age, sexor gender (including gender identity), race or ethnicity, religion, disability or long-term healthcondition, sexual orientation, caring responsibilities, parental responsibilities, socio-economicbackground or other personal characteristics set out in current equality legislation and/orregulatory rules or guidance relating to equality, diversity and inclusion, including equalopportunities monitoring and reporting, including in relation to the FCA proposals as mentionedabove;
  • ensuring a consistent approach to the management of our employees and the employees of ouraffiliate companies worldwide;
  • maintaining compliance with internal policies and procedures; or
  • being able to contact you or your family in the event of an emergency.

If you fail to provide personal information

Change of purpose

Disclosure of your information to third parties

• banks, trustees and administrators of the Company’s pension scheme, payroll administrators, publishersand other relevant parties in the context of the Company’s business and business development strategies
• to governmental, fiscal or regulatory authorities (for example to tax authorities in order to calculate yourappropriate taxation, compensation or salary payments or financial regulators in relation to issues ofregulatory compliance or as part of our supervisory relationship with regulators)
• to other third party agents or contractors for the purposes of providing services to us and to help provide,run and manage our information technology systems
• to the extent required by law, for example if we are under a duty to disclose your personal data in orderto comply with any legal obligation if we sell any of our business or assets or are acquired by a thirdparty, in which case we may disclose your personal data to the prospective buyer / buyers.

Transfers of personal data outside the United Kingdom or the European Economic Area

Retention of personal data

Automated decision-making

Your rights

• the right to obtain information regarding the processing of your personal data and access to the personaldata which we hold about you
• where we process personal data based on consent, the right to withdraw your consent to our processing ofyour personal data at any time;
• the right to request that we rectify your personal data if it is inaccurate or incomplete
• the right to request that we erase your personal data in certain circumstances
• a right to restrict or object to our processing of personal data; and
• the right to data portability.

Contacting us