Shareholder Privacy Notice

Our share registry services are carried by Equiniti Limited (Equiniti).  DWF has appointed Equiniti (Share Registrar) under the rules of the UK's Companies Act 2006, to manage our register of shareholders.  The main duties of our Share Registrar include keeping an up-to-date record of shares held by shareholders, administration of AGMs, voting instructions, shareholder payments and dividends, managing share transfers, responding to complaints and enquiries, issuing share certificates and supporting other regulatory and listing functions.  Our Share Registrar processes personal information about you as a shareholder on DWF's behalf.  This privacy notice therefore extends to our Share Registrar and the activities it conducts on our behalf.

Our Share Registrar may also make available for your use as a shareholder certain apps and engagement tools such as the Equiniti Investor Centre, Share Dealing Site, Proxy Voting Site and Employee Share Plans Site (Engagement Tools). When you utilise these Engagement Tools, additional privacy notices that relate to them will apply. Please note that this privacy notice is intended to supplement, not override, those separate privacy notices.

DWF will collect and use your personal information when you supply details either directly or through your agent, stockbroker or share plan administrator.

We also collect your personal information when you register or use any of the Engagement Tools.

Personal information we typically collect from you in order to register you as a shareholder of DWF (such as on your shareholder application form) and for ongoing administration and management of your shareholding (such as stock transfer forms) include the following:

• your personal details (e.g. name);
• you contact details (e.g. phone number, email address, postal addressor mobile number);
• details of categories and classes of shares you hold;
• details about any disability you may have if you have told us about it in order to deliver services to you (for example if you opt to receive your shareholder documents in alternative/ accessible formats);
• information about votes you cast and the any unique reference number given to you as a DWF shareholder;
• any personal details that you provide to us through your communications with us;
• images and voice recordings of your communications with us for quality control, training, security and regulatory purposes, including your location details i.e. capturing your location when you use a home landline number to contact us;
• your bank or building society account details where you have provided these for the purpose of receipt of dividend payments; and
• a record of your attendance at our general meetings.

We use cookies and similar technologies on our websites.  Our use of cookies allow you to navigate between pages efficiently, remembering your preferences, and improving your online experience by making it more personalised for you.

The wider global group privacy notice for our organisation on our website here together with our Cookies Policy here give you more information on cookies, how and where we use them, and how you can manage them.

We will only use and process your personal information where we have a lawful basis for doing so.  This will be for at least one of the following purposes:

• to manage your shareholding interest in DWF and our obligations to you as a shareholder, in accordance with our Articles of Association and applicable laws;
• to check your identity when you contact us 
• to keep our shareholder register up-to-date (for example when you advise us that you move address or change your name); 
• to allow you to exercise your rights as a shareholder in accordance with our Articles of Association and applicable laws;
• to contact you about shareholder related information for legal, regulatory and servicing purposes including with regard to shareholder payments, dividend distributions, shareholder resolutions, our annual report and accounts, notice of our Annual General Meeting and any other relevant information that relates to your DWF shareholding;
• to address any queries or complaints you raise with us as a shareholder;
• to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;
• to operate and improve our business and keep you informed, as a shareholder, about our products and services; and
• for any other legitimate purposes that are compatible with the original purpose for which your personal information was collected, but never at the expense of your privacy rights.

The legal basis for our processing of your personal information include where that processing:

• is necessary to comply with the law;
• is in accordance with your instructions;
• is necessary to manage your shareholder rights and our obligations to you as a shareholder in accordance with our Articles of Association and applicable law; and
• is in our legitimate interests, such as:
  - to allow us to make sure that the services provided to you as a shareholder are well managed in accordance with applicable laws and regulations;
  - where we need to check your identity and/or the validity of your identification documents so we can protect our business and keep to laws that apply to us; and
  - so we can ensure that your queries or complaints are investigated (for example, so that our shareholders receive a high standard of service and we can prevent complaints from arising in the future).

We will keep your information secure and confidential.  We share your information with a number of trusted third parties so they can assist us in delivering our services to you, to enable us to fulfil our legal obligations or where that information sharing is at your request.  We ensure that we have taken appropriate measures to ensure that your personal information remains protected at all times in accordance with this privacy notice.  We also implement appropriate safeguards with these third parties to ensure that such transfers of your personal information to those third parties are safe, secure and confidential. Such third parties include:

• our Share Registrar (Equiniti) and other parts of the Equiniti group of companies who help deliver the services to you;
• other members of the DWF group as necessary to operate our business (for example, to provide you with services, for internal reporting and where those group members provide services to us). For more information regarding the DWF group, please see our Legal Notices here;
• our service providers and agents (including their sub-contractors) including our auditors, payment providers who help us manage dividend and other payments to our shareholders, our IT and back office systems support providers and credit reference agencies and other reputable organisations when we need to verify your identity;  
• other financial institutions who you ask us to deal with;
• efforts to trace you if we lose contact with you e.g. to reunite you with your assets;
• your advisers (such as lawyers and other professional advisers) who you have authorised to represent you, or any other person you have told us is authorised to give instructions on your behalf (such as under a power of attorney);
• UK and overseas regulators, law enforcement agencies and authorities in connection with their duties including the Financial Conduct Authority, the London Stock Exchange, HMRC and the Information Commissioner's Office;
• UK and overseas regulatory, fraud prevention and detection agencies in order to help us to detect and prevent fraud, fight financial crime and meet our regulatory responsibilities;
• our advisers (such as lawyers and other professional advisers) who provide us with legal support in relation to our services or any litigation;
• any third party after a restructure, sale or acquisition of any DWF group member, as long as that person uses your information for the same purposes you originally provided it for;
• anyone we transfer or delegate our rights or obligations to in relation to the administration and management of our share register;
• any other person that requires access to or receipt of your personal information in connection with or as a result of any agreement we may have with or concerning you, or our arrangements with you; and
• any third party at your request or with your consent.

We will not disclose your personal information to any other third parties for any reason unless:

• we are required to do so by law;
• disclosure is necessary for the purpose of, or in connection with, legal proceedings; public interest reasons or for the prevention and detection of crime
• it is to exercise or defend legal rights; or
• we have your consent to disclose it to them.

We keep your personal information in accordance with our internal retention procedures, which are determined by our legal, regulatory and professional obligations including applicable data protection laws and in accordance with good practice. The retention periods differ depending upon the nature of the personal data we hold and the reasons why we are holding it, and are subject to change.  For example, there are more extended retention periods (e.g. if you claim on our insurance for lost share certificates) under certain legal, tax or accounting requirements or in line with industry guidance.  We are also required to retain an accurate record of your dealings with us, so we can respond to any complaints or challenges from you or others which might be raised later.  We will also retain files if we reasonably believe there is a prospect of litigation.

We will however only keep your personal information for as long as we need to.  When your information is no longer required, we will delete it securely or anonymise it so it cannot be linked back to you.

We review our retention periods for personal data on a regular basis.

When we share personal information with organisations in other jurisdictions outside the UK, we will ensure they agree to apply equivalent levels of protection to personal data as we do.

We achieve this by taking appropriate steps to ensure that such transfers are carefully managed, with the protection of your privacy rights and the upholding of confidentiality being of utmost priority. This includes ensuring any cross-border transfers of your personal information:

• within the DWF group are covered by an agreement entered into by those group members (an intra-group data sharing agreement) that contractually obliges each DWF group member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the DWF group; and
• outside the DWF group, such as to our service providers, are covered by those third parties contractually committing and providing assurances to us regarding the adequate and equivalent protection of your personal information.

We will only transfer your personal information to countries which are recognised as providing an adequate level of protection or where we can be satisfied that alternative arrangements and transfer mechanisms (such as contractual commitments) can be put in place to protect your privacy rights and provide an adequate level of protection for your personal information.  We will always ensure that such transfers are safe and secure.  You can expect equivalent safeguards and protection for the transfer of your personal information to any country outside the UK, whether that be to a country that is considered (under applicable data protection legislation) to be adequate or non-adequate.

You have certain rights relating to your personal data.  These include the right to:

• ask for a copy of the personal data we hold about you;
• ask us to give you (or a third party chosen by you) an electronic copy of the personal data you have given us;
• ask us to correct and update personal data we hold (subject to some exceptions);
• restrict how we use your personal data;
• ask us to delete your personal data (subject to some exceptions); and
• object to particular ways we are using your personal data.

Your ability to exercise these rights will depend on a number of factors, and in some instances we will not be able to agree to your request (for example, if we have a legitimate reason for not doing so or the right doesn't apply to the particular information we hold about you).  If you would like more information on your rights, or want to exercise them, you can do so in the following ways:

• to correct and update your personal data, please contact our Share Registrar (Equiniti) in the first instance if any personal data relating to your shareholding (including name, address or dividend mandate details) is incorrect.  Contact details for our Share Registrar appear in the 'Contact us and how to complain' section below];
• to change your voting preferences or mailing preferences, please contact our Share Registrar (Equiniti) in the first instance. Contact details for our Share Registrar appear in the 'Contact us and how to complain' section below;
• in relation to all other data rights, see the 'Contact us and how to complain' section.

Please note we sometimes require further information from you in order to verify your identity before disclosing, amending or deleting any of your personal information. We do this to ensure we only disclose information where we know we are dealing with the right individual.

In most cases, we will deal with your requests free of charge and within one month of receipt of your request. However, there are exceptions that can allow us to charge a reasonable fee to cover our administration costs and/or extend the time period for dealing with your request by up to a further two months from receipt of your request, such as where your request is complex or repetitive. If an exception applies, we will keep you informed.

If you would like to contact our Share Registrar (Equiniti) please ask to speak to the Equiniti Data Protection Officer when calling via telephone on 0371 384 2030 (in the UK) or +44 121 415 7047 (from overseas) or you can write to:

The Data Protection Officer, Equiniti, Highdown, House Yeoman, Way Worthing, BN99 3HH.

or you can email the Data Protection Officer at Equiniti at DPO@equiniti.com.

If you have any questions about this privacy notice or if you would like more information on your rights, or want to exercise them, you can contact us on +44 (0)333 320 2220 (toll free), email us at GDPR.enquiries@dwf.law (please mark the subject heading of your email "For the attention of the Data Protection Manager") or write to:

The Data Protection Manager
1 Scott Place
2 Hardman Street
Manchester
M3 3AA

If you have a complaint or concern about your privacy or relating to this privacy notice, please contact our Data Protection Manager, whose details appear above.

We hope that you won’t ever need to, but if you do need to complain about our use of your personal information we will ensure at all times that your complaint:

• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect our commercial arrangements.

If you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the data protection authority of the United Kingdom using their website: https://ico.org.uk or the relevant data protection supervising authority in your jurisdiction.

Please note that emails sent to and from DWF can be monitored (we currently use MimeCast) to ensure compliance with internal policies and procedures and to protect our business.

DWF Group plc is the 'data controller' of your personal data.  This means it is responsible for deciding how your personal data can be used.