Shareholder Privacy Notice
We are committed to protecting and respecting your privacy. This Privacy Notice applies to you if you are an individual and are a current or former registered shareholder of John Laing Group plc. It describes what Personal Data we collect, how it is used and what your rights are in relation to that Personal Data.
References to “we”, “our” or “us” in this Privacy Notice mean John Laing Group plc, a company incorporated under the laws of England and Wales with registered offices at 1 Kingsway, London, WC2B 6AN, United Kingdom.
For the purposes of applicable data protection laws, we are the “controller” in respect of Personal Data we hold about you as a shareholder.
1. How we collect your Personal Data
For the purpose of this Privacy Notice, “Personal Data” is any information relating to an identified living person or a living person who can be identified, directly or indirectly, from that information by means reasonably likely to be used by us.
We process your Personal Data, which includes:
- contact details;
- bank account details;
- details of shares held;
- shareholder reference number;
- voting instructions; and
- corporate action elections.
We have engaged Equiniti Limited as our share registrar. Equiniti Limited and other Equiniti Group entities (“Equiniti”) maintain the John Laing Group plc shareholder register and process shareholders’ Personal Data on our behalf.
Your Personal Data is collected when you provide it to us, to Equiniti or to other third parties engaged to carry out services on our behalf, for example when you provide your details via Equiniti’s website.
2. How we use your Personal Data
We will use your Personal Data for the following purposes:
- to manage your shareholding in John Laing Group plc and keep your record on the shareholder register up-to-date;
- to make shareholder communications and shareholder meeting materials available to you, such as the Annual Report and the Notice of Annual General Meeting;
- to pay dividends to you;
- to allow you to exercise your rights as a shareholder, such as the right to vote at shareholder meetings; and
- to respond to any correspondence you send to us.
Your Personal Data is processed on the basis of at least one legitimate ground, which may be, depending on the purposes of the processing: (i) the performance of a contract with you; (ii) compliance with our legal obligations; or (iii) our legitimate interests (which include those purposes set out above) or the legitimate interests of the third parties with whom we may share your Personal Data.
3. How we may share your Personal Data
In connection with the above purposes, we may share your Personal Data with:
- Equiniti, our share registrar;
- Orient Capital, whom we have engaged to provide certain services, such as sending shareholder notices to you on our behalf;
- other third-party agents or service providers whom we may appoint from time to time; and
- any of our employees or officers, for example our company secretarial and investor relations teams.
We may also disclose your Personal Data to third parties in other circumstances, in particular:
- in response to a request from governmental and quasi-governmental bodies and regulators;
- if we are under a duty to disclose or share your Personal Data to comply with any legal obligation, or enforce and/or protect the rights, property, or safety of us, our customers, or others;
- if we (or a member of our group) sell or buy any business or assets, in which case we (or the relevant member of our group) will disclose your Personal Data to the prospective seller or buyer of such business or assets;
- in connection with any ongoing or prospective legal proceedings; or
- if we have your consent to make the disclosure.
If your Personal Data is transferred outside the European Economic Area (EEA), this will be on the basis of an appropriate transfer mechanism, such as an agreement based on the standard contractual clauses approved by the European Commission.
4. How long we keep your Personal Data
Your Personal Data will be destroyed or erased from our systems, or anonymised so that it cannot be linked back to you, when it is no longer required for the purposes set out above. Typically, your Personal Data will be retained for a period of up to 12 years following your last entry on the share register. However, we may retain your Personal Data to the extent necessary to comply with applicable laws, regulations and rules.
5. Your rights in relation to your Personal Data
You have various rights under data protection law regarding the processing of your Personal Data, including rights in certain circumstances to:
- request access to Personal Data we hold about you and details of our processing of your Personal Data;
- request us to correct inaccurate Personal Data and complete any incomplete Personal Data;
- request us to delete Personal Data in certain circumstances, such as when it is no longer necessary for us to hold it;
- receive your Personal Data in a format suitable for transmission to a third party;
- object to and/or restrict the processing of your Personal Data (including profiling) on certain grounds;
- object to the processing of your Personal Data for direct marketing;
- object to any decision about you based solely on automated processing (including any profiling) that produces legal effects or otherwise significantly affects you; and
- lodge a complaint with the UK Information Commissioner’s Office.
You can make a request to us in relation to these rights at any time by contacting us using the details provided below. We will respond to these requests in accordance with, and subject to the exemptions stipulated in, applicable data protection laws.
6. Changes to this Privacy Notice
Any changes we make to this Privacy Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently for any updates or changes to it.
7. How to contact us
If you have any queries regarding this Privacy Notice, or our use of Personal Data, you can contact us at any time via email at email@example.com by phone at 020 7901 3200, or by post at 1 Kingsway, London WC2B 6AN.