Privacy notice for former investors

Baillie Gifford is committed to protecting the privacy and security of personal information entrusted to us. This privacy notice is intended for individuals who previously invested directly with us through our Investment Trust ISAs, Share Plans or Children’s Savings Plans.

This notice describes how we as a "Data Controller", process personal information about you once your account is closed, in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. It applies to all processing of personal data relating to former direct individual investors, and supersedes any other similar notices or information provided to you at the time you supplied your personal data.

This privacy notice is not intended for individuals who subscribe to our marketing, invest directly with us in our range of OEICs, or for our business contacts.

• If you subscribe to our marketing, please see the marketing recipients privacy notice.
• If you invest in an OEIC, please see the OEIC investors privacy notice.
• If you are a business contact, please see the business contacts privacy notice.
• If you are a candidate for recruitment, please see the candidates privacy notice.

The kind of information we hold about you

We may collect, store, and use the following categories of personal information about you:

• personal details such as name, title, date of birth, addresses, telephone numbers and email addresses;
• identification and verification information and documents, such as signatures, passports, driving licences, birth/marriage certificates and tax/credit references;
• financial and transactional information relating to your investments and your instructions regarding these.

All telephone calls to our client relations team are recorded for training and monitoring purposes. If you provide us with additional information about you, in particular by telephone or email, we may for regulatory reasons be required to collect and store the record as a whole.

We ask that you do not disclose any information to us if you are uncomfortable for it to be stored on our systems to comply with our regulatory obligations.

How is your personal information collected?

We collected personal information about our (former) individual investors directly from them. We collected other information about you from third parties in the course of carrying out our anti-money laundering/anti-fraud obligations. We may also have collected additional personal information in the course of our relationship as a necessity of the services being provided.

How we use information about you

We will use your personal information to:

• respond to any enquiries you have regarding the account you previously held with us - we will do so for as long as we are required to retain your data for regulatory reasons;
• meet our other compliance and regulatory duties, for example to retain certain records after the closure of your account with us.

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law or regulation.

Data sharing and third party processors

We may need to share your personal data with third parties, including other entities within the Baillie Gifford group and the former administrator of our Investment Trust Share Plans/ISAs and Children’s Savings Plans (DST), if you or we have a query about an account that was held. If you request copies of our Investment Trust reports and accounts, we will share your personal data with the registrar (Computershare) to arrange this. Where we share your personal data with another party performing services for us (not for you), we require those third parties to respect the security of your personal data and to treat it in accordance with the law.

A list of our current third party service providers is provided at the end of this notice.

When might we share your personal information with other entities in the group?

We will share your personal data with other entities in our group only in so far as necessary to provide the products, services or information you have requested or contracted from us, or to answer your enquiries relating to these.

Data Security

We have put in place measures to protect the security of your information. Details of these measures are included in group-wide policies which cover the following:

• management and organisation of information security;
• classification of data which includes data handling rules;
• staff training on responsibilities connected to information security and data protection, and the reporting of any information security incidents;
• physical and environmental security; and
• systems security, including backups, virus protection and access controls.

Our policies and controls are based on the international standard for information security, ISO27001, to which we have been certified since 2010. We are committed to implementing, maintaining and continually improving an information security management system in accordance with that standard. Our approach supports the enhancement of information security controls and our information governance framework is overseen by our Chief Information Security Officer. That framework includes a cross functional senior management group supported by expert external advice to oversee an effective information security strategy. We also have a rigorous third party oversight programme designed to maintain the confidentiality, integrity and availability of your data when it is processed by other organisations on our behalf.

Data Retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or regulatory requirements.

You will appreciate that as a regulated business, there are record retention obligations on us. As a result, where necessary, we will retain your personal data in order to comply with these obligations.

Your records will be retained for seven years after the closure of your account with us, at which point they will be securely deleted from our systems.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

In certain circumstances, by law you have the right to:

• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

You can exercise these rights by contacting trustenquiries@bailliegifford.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).

Your Rights Under the California Consumer Privacy Act (CCPA)

In addition to the above rights, California residents have the right to instruct a business to stop selling their personal information. Baillie Gifford does not sell your personal information in exchange for any monetary consideration. In some cases, data obtained from cookies is shared with third parties and may be considered a “sale of personal information” under the CCPA. However, Baillie Gifford disables such cookies by default and sharing will therefore only occur where you have enabled them.

Data Protection Officer

If you have any questions about this privacy notice, please contact trustenquiries@bailliegifford.com. If you are unhappy with how we handle your personal information, please contact the Data Protection Officer at DataProtection@bailliegifford.com. If we do not resolve your concerns to your satisfaction, you have the right to make a complaint to the Information Commissioner's Office (ICO), the U.K. data protection regulator.

Changes to this Privacy Notice

We may update this privacy notice from time to time and will communicate such updates through our website. We will not do so where we believe this would materially impact your rights and freedoms; in those circumstances we will expressly notify you. We may also notify you in other ways from time to time about the processing of your personal information.

Third party providers who may currently process your personal data on behalf of Baillie Gifford

Corporate Mailing Solutions (CMS) - a mailing house used to send postal mailings on Baillie Gifford’s behalf. Only personal details necessary to fulfil any postal communication will be sent to CMS.

DST - DST Financial Services Europe Limited and DST Financial Services International Limited previously performed the administration function for our Investment Trust Share Plans/ISAs and Children’s Savings Plans on behalf of Baillie Gifford.

GBG Group - the firm used by Baillie Gifford to establish a former client's current address where that client has changed address and not informed Baillie Gifford.

MessagePad - a firm appointed by Baillie Gifford to take messages from clients when calls volumes are high and outwith office hours.

Please note that the above list is subject to change.