Rowan Dartington

Policies

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The policies below include:

 

1. Order Execution Policy (formerly Best Execution Policy)

2. Management of conflicts of interest

3. Complaints policy 

4. Client money notice 

5. Stewardship Code

6. Pillar 3 Disclosures

7. Candidate Privacy Policy

 

1. ORDER EXECUTION POLICY (formerly Best Execution Policy)

Introduction

The EU Markets in Financial Instruments Directive (‘MiFID’) and corresponding rules of the Financial Conduct Authority (‘FCA’) require that investment firms establish an Order Execution Policy and take all sufficient steps to obtain the best possible results for their Clients when executing a Client Order.

This policy outlines all of the sufficient steps taken by Rowan Dartington (‘RD’ or ‘we’ or ‘us’) to ensure that ‘best execution’ is achieved – that is obtaining the best possible results for you when undertaking transactions on your behalf.

We will take steps to achieve the best execution of client orders, subject to different factors which are dependent on the financial instrument and the type of market on which the order is executed.

Client Classification

Our Clients are classified as Retail Clients unless they opt-up to either Professional or Eligible Counterparty status[1], but regardless of classification we will treat all Clients the same for the purposes of achieving best execution, or getting the best possible result for you when carrying out trades. We always aim to achieve best execution on a consistent basis as outlined in this Order Execution Policy.

[1] The definitions of Professional and Eligible Counterparties can be found in the FCA Handbook

Execution Factors

When dealing for you we will consider the following:

  • Your characteristics (including your regulatory Client categorisation as mentioned above)
  • The characteristics of the financial instrument concerned and of your order
  • Where such orders can be carried out (i.e. the ‘execution venues’).

In assessing the most appropriate route to carry out your order we will consider the following criteria which we have ranked in order of importance:

table

*FX – A stand-alone foreign exchange transaction

**OTC – Any security which needs to be traded bilaterally with a counterparty, but not conducted over an exchange.

 

Best Execution Criteria

 

This explains how we would normally behave when placing client orders, but of course, each order will be considered as it arrives and will be processed as market conditions and our experience dictate. 

If you are a Retail Client, the best possible result will normally be determined in terms of the total consideration, being the price of the instrument and the costs of the transaction, those costs being all expenses incurred which are directly related to the execution of the order. However, there may be circumstances in which this is not the primary consideration. Where the instrument is illiquid or the size of the order unusual relative to the normal, then other factors may take precedence, although we will also have to use our judgement in assessing whether particular trading strategies may move the market (incur implicit costs). Alternatively, we may have to execute the order over the course of a number of working days in order to complete it. Likewise, the characteristics of an order may require us to transmit an order to a counterparty to execute on our behalf, rather than dealing directly with that counterparty (for example, orders in securities traded on overseas markets).

When placing Execution only or Advisory deals which have been discussed with Clients, we will be careful to ensure that any quotes given to the Client are current, taking into account changing market conditions.

 

Execution Venues

For each instrument we execute on behalf of Clients, it is our policy on an ongoing basis to consider the variety of trading venues or sources of liquidity available from time to time. This enables us to obtain on a consistent basis the best possible result for the execution of transactions. In satisfying this policy, we may consider the use of one or more of the following venue types:

  • Regulated Markets (e.g. London Stock Exchange or overseas equivalent)
  • Multilateral Trading Facilities (e.g. Non-Exchange Financial Trading Venues)
  • Systematic Internalisers (e.g. Market Makers)
  • Third party investment firms and/or affiliates acting as Market Maker or other liquidity providers
  • Non-EU entities performing similar functions

We regularly assess the execution venues available and may add or delete venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis. An up to date list of significant execution venues is attached in Appendix 1. As Members of the London Stock Exchange (LSE), a very large proportion of our trades in direct securities take place using LSE counterparts. 

The selection of counterparties and trade routing mechanisms is based on an assessment of factors such as market coverage, liquidity access, trading competitiveness and competence and operational capability, it is known as “ex-ante” selection.

Where we believe that best execution can be achieved on Clients’ behalf outside Regulated Markets or Multilateral Trading Facilities, it is our policy to do so. By agreeing to our terms and conditions you are also agreeing to our Order Execution Policy, and as such you are giving your express consent to this requirement.

Exposure to different financial assets can be achieved directly, by purchasing the actual securities, or indirectly, by purchasing a collective investment of these securities. The venue and method chosen will be dependent upon which of the routes is chosen.

In certain financial instruments there may only be one execution venue. Each fund manager is usually the order execution venue for transactions in their own funds, for example. In executing a trade in such circumstances, we will presume that we have provided the best possible result in this respect for these types of instruments.  We will often deal through a trading platform, such as Cofunds, since these intermediaries have access to the widest range of fund venues.  Since there are no competing venues for such trades, our obligation is to submit the required trades to the platform in a timely fashion.

Costs and Charges

We use a variety of different channels and counterparties to execute orders on behalf of Clients and to facilitate the investment of Clients’ portfolios.   RD’s own fees and commissions, where levied, are deducted from client portfolios as determined by the service to which the Client signs up (e.g., custody and execution fees for Execution only business, advisory fees for Advisory business and management fees for Discretionary business).  In addition, Clients will pay taxes (stamp duty) as they accrue, and fund management expenses embedded in the dealing prices of the collective vehicles in which we invest. 

The different channels we use to execute transactions will have different explicit costs associated with them.  But, with the exception of transactions in foreign listed securities, these costs will be absorbed by RD and are not passed on to the Client.

We do not accept any form of non-monetary benefit from routing orders through certain execution venues and do not structure charges or commission in any way that would favour or discriminate unfairly between execution venues. Gifts and hospitality may be permitted but only if they comply with both our Conflicts of Interests Policy and Gifts and Hospitality Policy.  Under FCA rules we are not allowed to receive investment research in exchange for dealing commission paid to brokers.

Order Handling

We are committed to the prompt and fair treatment of all Clients’ orders. As soon as a client order has been accepted or the manager has made a decision to deal on behalf of a discretionary client, the order will be passed immediately to a dealer to be executed as soon as reasonably practicable. However, it is acceptable to postpone execution of an order if this, is considered to be in the Client’s best interests.

Having assessed the relevant criteria and any specific instructions provided by you, we will select the most appropriate venue(s) from those available and execute your order accordingly.

You are able to give us specific instructions regarding the execution of an order, or part of an order and we will execute in accordance with those instructions. 

Warning: Giving specific instructions may prevent us from following our execution policy to obtain the best possible results in respect of your instructions. We will apply our policy to all other aspects of the trade.

Limit Orders

Typically, we will deal ‘at best’, using prices at the prevailing price in the market. However, if you give us an investment instruction at a specified price limit and for a specified size (a ‘limit order’), then it may not always be possible to execute that order under the prevailing market conditions. If we receive clear instructions from you as to how to execute your order, we will not prioritise the execution factors we would usually consider except that we would have to follow market etiquette.

Unless the order is large in scale compared with normal markets, where the limit order is not immediately executed under prevailing market conditions, we are required to make your order public (i.e. show the order to the market) unless you expressly request otherwise.

Order Aggregation

We may combine (or ‘aggregate’) an order for our Clients with orders of other Clients. We would only aggregate a Client order if it was unlikely to work to the overall disadvantage of the Client. However, the effect of aggregation may on some occasions work to the Clients’ disadvantage and may on occasions result in our Clients obtaining a less favourable price than if their order was executed separately.

If an order has been aggregated, but not been allocated in full, then generally the distribution of assets will be allocated on a proportionate basis. In these circumstances, it may be more costly to the Client as we have to fulfil the order over several transactions, each subject to our minimum charges. We do not aggregate client orders with transactions undertaken for our own account.

Review and Monitoring

We will review our execution arrangements and venues on at least an annual basis or whenever a material change occurs that affects our ability to obtain the best possible result for our Client orders. We will inform you of any material changes to our execution arrangements or our Execution Policy. We will also periodically monitor the quality of our execution against the factors detailed in this Policy to identify and, where appropriate, enhance our arrangements.

These procedures include discussions between our traders and counterparties on an order by order basis; information as published by the Execution Venues; the use of Transaction Cost Analysis tools to assess trading performance; and a formal review of counterparty financial strength and operational efficiency.

RD will actively monitor compliance with the Order Execution Policy and annually review the Order Execution Policy against the FCA’s rules and guidance annually, and ad-hoc, driven by regulatory requirements/changes.

The firm has established a Best Execution Committee as part of its governance of the investment process.  This Committee meets monthly, receives and observes upon management information regarding our Best Execution performance, implements corrective actions where required and is responsible for the development and implementation of proper policies and procedures.

General

RD operates on the basis that all Retail Clients would be legitimately relying on the firm to deliver best execution for all transactions, regardless of how they arise.

By signing or agreeing to the declaration in the account opening form, you (or your authorised intermediary) consent to our Order Execution Policy including those sections that require your prior express consent.

Please note that if you do not provide your consent to our Order Execution Policy you may be limiting our ability to execute your orders on the most advantageous terms for you. Accordingly, if you do not consent to this Order Execution Policy we will be unable to open an account for you.

You have the right to request that RD demonstrate to you how we have executed your order in line with this policy.

From 2018, Rowan Dartington publishes execution quality information on its top 5 execution venues and brokers.

Appendix 1

Execution Venues and Counterparties

Execution venues and counterparts table

 

 

Order Execution Policy 2020.pdf

RTS Top 5 Venue Report

RTS 28 Factsheet - Top 5 venue report 2019.pdf

2. MANAGEMENT OF CONFLICTS OF INTEREST 

 

What are conflicts of interest?

A conflict occurs where:

  • our (or any subsidiary /representatives of Rowan Dartington)  interests conflict with the duty owed to you; or
  •  where our duties to another client conflicts with our duty to you

In accordance with the requirements of the FCA (our regulator) we aim to treat you fairly by implementing adequate systems and controls to identify, monitor and manage these risks or any potential risks.

As the fair treatment of our clients is paramount to the ethical standard of Rowan Dartington it is incumbent on our Board and staff to consider and escalate any matter that they consider may conflict with our policies. The Risk Committee will review any new conflicts that have been identified.  

About us

Rowan Dartington provide Wealth Management Services, including investment advice and management as well as dealing and custodian services.  We are part of the St. James’s Place Wealth Management Group.

We have an Independent Financial Adviser (Stafford House Investments) who provide financial planning advice on an independent basis.   A C Mole is also independent financial planning advisers, who are a trading name of Stafford House Investments.  The advice these companies provide may or may not involve referring clients to Rowan Dartington.

Purpose of this information

To explain to you what policies we have in place to manage conflicts and highlight what principle conflicts exist and what is in place to mitigate them.  Should you wish to discuss anything further, please contact your Investment Manager.

FCA Requirements

FCA Principle 8 – ‘A firm must manage conflicts of interest fairly, both between itself and its customers and between a customer and another client’. The SYSC Rules also require us to have adequate systems and controls to manage risks. The new MiFID Rules require us to formally document this. It is not sufficient that we rely solely on disclosure of conflicts in customer agreements etc.

 

Conflicts Inventory

Principal Conflicts

Management Arrangements

Conflict Risk

What we do 

Suitability
i.e. Staff recommend services or transactions which are not appropriate for the client

We have a robust training programme in place for our advice processes to ensure that our Investment Managers and Advisers provide appropriate advice.  Our monitoring programme provides a control mechanism to ensure processes are being consistently deployed and advice is suitable.

 

There are internal policies in place to deal with scenario’s that may cause conflict in advice processes, such as;

  • Commissions receive from third parties;
  • Staff having power of authority over an account i.e. Trustee, Executor, Director or Power of Attorney;
  • Interest payments
All staff are expected to disclose outside business interested.

Dealing and Trading

i.e. our staff may delay investments

We have a best execution policy which Investment Managers and Financial Advisers are expected to adhere to ensure that we act in your best interest.

Rowan Dartington have a transactional monitoring programme to review trades which have been completed to ensure best execution principles have been achieved.

Aggregation of orders

i.e. one client may be treated more favourably than an other

To mitigate this we may combine one client’s orders with another clients order.   The intention is to ensure fairness to all clients when placing particular trades, particularly for discretionary clients.  This could result in a less favourable price or increased trading costs. When undertaking trades of this nature we will ensure our clients best interests are considered.

Placings and new issues

i.e. one client may be treated more favourably than an other

Where we agree to take part in a new issue or placing, we will do this in combination with other client orders.  If the allocation is scaled back it will be applied pro rata across all participating clients.

Sometimes staff may take part in these trades also. Where they do and where the allocation is scaled back, we will scale back staff orders before applying any scaling to our clients.

Personal Account (staff) Dealing (PA)
i.e. Staff may deal on their own account ahead of clients and obtain better prices

All staff and connected parties are expected to comply with our Personal Account Dealing policy.  This requires staff to obtain prior approval for trading.

The prior approval means that checks can be made to ensure that staff do not;

  1. Trade ahead of clients
  2. Trade ahead of any public announcements about the stock being traded

Staff remuneration
i.e. bonus and salary structures may entice staff to act inappropriately when managing client assets

We aim through our remuneration package to consider the long-term interests of our staff.  These are designed to correlate with the interests and financial wellbeing of our clients, so to discourage inappropriate behaviour or excessive trading.

 Therefore, activities are overseen and monitored.
Gifts and Hospitality (Inducements)
i.e. The integrity of either staff or suppliers is compromised by excessive inducements.

We have enforced internal policies, through training and monitoring, to ensure that gifts or hospitality received from or provided to clients, supplier, company and other are not excessive.

Staff are required to disclose where they receive or give gifts or hospitality when they are over a notional value.  Where the triggers are met pre-approval will be required, via our Compliance and Risk Department, to accept or provide a benefit like this.

In all cases, there needs to be a business motive for the gift or hospitality which aim is to enhance the quality of service we provide to you.

We also maintain a register or gifts and hospitality received or provided which is overseen by the Compliance and Risk Department.

Research

i.e. our research team may be un-duly influenced to place stock or funds on to our core lists

Our research team are independent from other teams in the business.  The remuneration package for these staff is designed not to influence their decision making process.

Any additions or deletions from the core list are discussed at either the Asset Allocation Committee or Investment Management Committee before the changes are made to the core list.  This information will not be disclosed to staff ahead of formal announcement of the core stock list changes.

Disclosure

If we are unable to manage a conflict, or where we believe our measures and controls are not sufficient to protect your interest we will disclose the conflict to you.  The aim of this is to allow you to make up your own mind as to whether to continue our business relationship with regard to the service or advice we provide you.

 

3. COMPLAINTS POLICY 

Procedures

We are sorry you have cause to complain to Rowan Dartington.

Our aim is to resolve any client concerns fairly, effectively and promptly.

Rowan Dartington & Co Ltd always aims to provide the highest standard of service to its clients but on occasions we may fall short of this goal leaving clients and potential clients dissatisfied.

When we receive any letter, fax, email, telephone call or personal communication which expresses dissatisfaction about services which we have provided or failed to provide, we will attempt to resolve the matter promptly and fairly. Consumers will also be able to tell us at any point that they don’t want to take their complaint any further.

Where possible, please include the following details with your complaint:

  • Your full name, address, account reference and your telephone number to contact you on;
  • A full description of your complaint and any details you can provide on what you feel would be appropriate in order to resolve your complaint, and;
  • Any relevant documentation you wish us to consider as part of the complaint investigation

If complaining on behalf of another person, you must be authorised to do so and we reserve the right to contact the individual who you are complaining on behalf of to confirm.

How to make a complaint

You can refer your complaint to Rowan Dartington via any form of communication, but where possible, please use the following contact details:

Address: Complaints Team, Rowan Dartington, Temple Point, Redcliffe Way, Bristol, BS1 6NL

Email: complaints@rowan-dartington.co.uk

Telephone: 0117 933 0050

Expressions of Dissatisfaction

Where possible, we will look to resolve the issue by close of business 3 days after receipt of your complaint and we will write out to you confirming resolution. You still have the right to refer your complaint to the Financial Ombudsman Service (details below) and/or the alternative dispute resolution (ADR) service should you not be happy with the outcome.

Acknowledgment of Complaints

Where it is not possible to resolve the issue within 3 business days, our Complaints department will complete an investigation.

If this applies, we aim to issue an acknowledgement to you within 5 business days, detailing our understanding of your concerns and confirming the next steps.

Complaint Resolution

We will collate all the documentary evidence relevant to your complaint and, where applicable, ask for the comments of any individual involved. It may also be necessary for us to contact third parties for information. 

During the investigation

Once we have done this, we will review the evidence, make our assessment and let you know the outcome of our investigation in writing.

  • If we are unable to resolve your complaint within 4 weeks of receipt we will send you a letter explaining why we need more time to complete our investigation and let you know when to expect our response.
  • If our investigation is going to take longer than 8 weeks, we will write to you again to explain why and let you know when we expect to be able to conclude matters. This letter will also inform you of your right to refer your complaint to the Financial Ombudsman Service (see ‘Your Rights’ below), if applicable.

At the end of the investigation

When we have finished our investigation we will write to you with our full response to the concerns you raised.

Our final response will set out;

  • the facts which have been established during the investigation; and
  • any resolution to be offered.

This resolution will consider;

  • Fair compensation for actual or potential financial loss;
  • Any reasonable costs you have claimed;
  • Lost interest which could have accrued since the date on which any possible loss was suffered; and
  • Fair redress for any inconvenience or distress.

Your Rights

If you are not completely happy with the outcome and resolution of your compliant, you have additional rights to independent review or assistance.  These additional rights are set out below:

Financial Ombudsmen Service

You have the right to refer a complaint directly to the Financial Ombudsman Service if we have had an opportunity to consider it and have either:

  • Supplied you with a final response; or
  • 8 weeks have elapsed since we have received your complaint and a final response has not been issued.


More information on the Financial Ombudsmen Service can be found here: http://www.financial-ombudsman.org.uk or you can contact them using the below details:


Address: The Financial Ombudsman Service, Exchange Tower, London, E14 9SR


Email: complaint.info@financial-ombudsman.org.uk


Telephone (from within the UK): 0800 023 4567


Telephone (from outside the UK): +44207 964 0500


We will also issue you with a leaflet providing these details with our formal responses to your complaint.

Time limits for referral to the Ombudsman

In line with current rules, you will have six months from the date of our final reply to refer your complaint to the Financial Ombudsman Service if you remain unhappy with our response.

The Financial Ombudsman Service might not be able to consider your complaint if:

  • What you are complaining about happened more than 6 years ago; and
  • You are complaining more than three years after you realised (or should have realised) there was a problem.

If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and will only be able to do so in very limited circumstances.  For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

Alternative 

If you remain unhappy and do not agree with the Financial Ombudsman’s final decision, you are able to:

  • Utilise an alternative dispute resolution (ADR) entity (this gives you access to an independent professional to review or assist with your complaint); or 
  • Potentially able to take civil action.

More information on ADR can be found on the Citizens Advice website:

www.citizensadvice.org.uk

 

4. CLIENT MONEY NOTICE 

As a firm which is both authorised and regulated by the Financial Conduct Authority (FCA), Rowan Dartington is required to comply with the rules prescribed in the FCA Handbook. The handbook details rules on handling both client assets and client money.

 

Rate change with effect from 1 July 2017

With effect from 1 July 2017, the rate of interest paid by Rowan Dartington on any cash balances held reduced to nil.

 

 

5. THE STEWARDSHIP CODE

This disclosure is currently under review for the FCA’s PS19/13 ‘Proposals to promote shareholder engagement’ and will be updated shortly.

The principal business of Rowan Dartington and Co (“RD”) is discretionary and advisory portfolio management, primarily for retail clients but also, on occasion, for clients who can be classified as “professional” according to UK regulation. 

In this capacity, RD invests on behalf of its clients in a wide range of securities – principally collective vehicles but also directly into the listed shares of UK companies (UK equities). 

The UK Stewardship Code is overseen and published by the Financial Reporting Council (FRC), which is the independent body established to oversee financial reporting, accounting and auditing and corporate governance in the UK.  The Code embodies guidelines for institutional investors to meet their obligations as owners of UK listed corporate securities.

RD primarily manages the assets of retail clients; we have only a small number of institutional or professional clients.  To the extent that we do have professional clients, the FCA requires us to publish the extent to which we are signatories to, or comply with, the UK Stewardship Code. Regulation is silent on our obligations in respect of retail clients but the policy as described below applies to the entirety of our holdings.

The Code

As with the UK Corporate Governance Code, the UK Stewardship Code is not a rigid set of rules. It consists of principles and guidance. The principles are the core of the Code and the way in which they are applied should be the central question for the institutional investor as it determines how to operate according to the Code.

Those organisations that choose not to comply with one of the principles, or not to follow the guidance, should deliver meaningful explanations that enable the reader to understand their approach to stewardship –  this is known as “comply or explain”.   For each of the seven Principles underlying the Code, we explain our approach below.

The Financial Reporting Council (FRC) recognises that not all parts of the Code are relevant to all firms. For example, smaller institutions may judge that some of its principles and guidance are disproportionate in their case. In these circumstances, they should take advantage of the ‘‘comply or explain’’ approach and set out why this is the case.  Of particular importance are the size and complexity of the firm, the nature of the risks and challenges it faces, and the investment objectives of the firm or its clients.

RD is not a signatory to the Code, for reasons which are explained below.

Principle 1: Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.

This explains how we adapt the Code to our everyday activities.

RD is a small financial services organisation which invests on behalf of our varied clients in a wide variety of different asset classes.  Some of those clients invest with us on an advisory or execution-only basis – in respect of those clients, we have no contractual rights to vote those holdings nor to exercise other stewardship activities.  Furthermore, to a large extent, we derive many of those asset exposures via collective vehicles, where the opportunity for direct shareholder involvement, where the asset class permits, is very limited.  Even where we hold on clients’ behalf direct UK equity exposures, for the most part the aggregate size of those holdings is very small and the scope for direct involvement with their governance limited.

Our approach therefore concentrates on the identification of a broad range of quality investment opportunities consistent with clients’ risk profiles and the disposing of those assets when, for whatever reason, they are no longer deemed suitable.

Principle 2: Investors should have a robust policy on managing conflicts of interest in relation to stewardship which should be publicly disclosed.

RD is required by the FCA to comply with the rules governing Conflicts of Interest.  As part of this, a statement of how we manage those conflicts is on our website.  This policy applies to all conflicts of interest, including those in relation to stewardship.

Principle 3: Investors should monitor their investee companies.

It is a critical part of the investment process at RD that we actively monitor the underlying performance of the investment securities in which our clients’ funds are held. 

In the case of direct UK equity securities, this will include regular contact by our Research team with the management of those companies and also prospective investee companies.  This occurs at regular intervals and compliance with the spirit of the UK Corporate Governance Code is a factor which is taken into account when forming an investment view.  If a company is perceived not to be acting in the best interests of shareholders, then we will not invest or consider disinvestment.

With regard to investments in collective vehicles, the level of ongoing monitoring and review of such vehicles is just as rigorous and the managers’ attitude to governance and stewardship is regularly assessed as part of that process. 

Principle 4: Investors should establish clear guidelines on when and how they will escalate their stewardship activities.

Where we have significant direct holdings in equity securities, and we have concerns about the nature of corporate governance or whether management is acting in shareholders’ best interests, then we may consider it fruitful to inform management of that fact.  But because our priority is to act in clients’ best interest, the usual course of action is to disinvest.

Principle 5: Investors should be willing to act collectively with other investors where appropriate.

In circumstances where we believe it would be in clients’ best interests, we are happy to engage with other investors on a case by case basis, while being mindful of our legal and regulatory responsibilities.

Principle 6: Investors should have a clear policy on voting and disclosure of voting activity.

Many of our investments are in collective vehicles where we do not have voting rights in respect of the underlying holdings.  In respect of directly held equity securities, for the most part our holdings are immaterial to the outcome of the vote.  For that reason, our voting activities are usually restricted to Extraordinary General Meetings governing corporate restructurings or other actions, where we have a material interest in the outcome – such events are rare.  However, individual clients are welcome to vote in respect of their own holdings, either in person or by form of proxy, which RD can arrange.

We do not engage in securities lending with client holdings.

Principle 7: Investors should report periodically on their stewardship and voting activities.

It is not our current policy to report routinely to clients on our stewardship and voting activities.  We consider such information to be so generic as to be potentially misleading.  We do not seek independent assurance of stewardship activities or voting performance on the basis that the scale of the firm’s activities would not justify the expense.

 

6. PILLAR 3 DISCLOSURE

 

Pillar 3 - 2019.pdf

7. CANDIDATE PRIVACY NOTICE

About Rowan Dartington

Rowan Dartington and its subsidiaries (Stafford House Investments) are committed to protecting the privacy of its users and we therefore ask that you read this policy in conjunction with providing us with any information about you or any other person (personal information).

Rowan Dartington & Co Ltd (Company No. 2752304) has its registered office at St. James’s Place PLC Head Office: St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom.  Stafford House Investments Ltd is an appointed representative of Rowan Dartington & Co. Ltd, with A C Moles Financial Service being a trading name of Stafford House Investments.

Rowan Dartington is part of the St. James’s Place Wealth Management Group.  Rowan Dartington is a member of the London Stock Exchange and is authorised and regulated by the Financial Conduct Authority (No. 155241).

Our processing of your personal information

Personal information means data which identifies you and relates to you as an individual. Rowan Dartington & Co Ltd and Stafford House Investments will collect, use and store your personal information for a wide variety of reasons in connection with your development towards becoming an employee or Rowan Dartington & Co Ltd or Stafford House Investments (collectively referred to as the ‘Purposes’ in this notice).

In accordance with its obligations Rowan Dartington & Co Ltd and Stafford House Investments Ltd will ensure your personal information is:

  • Processed fairly and lawfully
  • Obtained and processed only for specified and lawful purposes
  • Adequate, relevant and not excessive
  • Accurate and kept up to date
  • Held securely and for no longer than is necessary
  • Not transferred to a country outside of the EEA unless there is an adequate level of protection in place or explicit consent is sought

We will review the nature of information being collected and held from time to time to ensure that these principles are being followed.  Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also act as the data controller of their personal information and will be responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to the content of this notice.

What personal information do we collect?

We have set out below the main categories of personal information which we may process on a day to day basis in connection with the purposes:

  • Name, gender, home address and telephone number, date of birth and marital status
  • Business contact information (including email address and telephone number)
    Identification information including passport, driving license, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters, bank statements and evidence of benefit entitlement
  • Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of an application and/or the application and recruitment process
  • Employment information such as job title, employment history, professional qualifications and accreditations
  • Note of discussions between trainees and Rowan Dartington employees
  • Records of work absences, holidays/paid time off, entitlement and requests, salary history and expectations, performance appraisals, letters of appreciation and commendation, and disciplinary and grievance procedures (including monitoring compliance with and enforcing our policies)
  • Training and development records
  • Information relating to performance of tasks and activities to be achieved via the programme
  • Notes of discussions with Rowan Dartington employees
  • Payment information
  • Emergency contact information
  • Voicemails, emails, correspondence, documents and other work product and communications created, stored or transmitted our networks, applications, devices, computers or communications equipment
  • Date of termination, reason for termination
  • Fitness and propriety information necessary for regulatory approval
  • Personal information which you otherwise voluntarily provide, for example when using your Rowan Dartington email account

Personal information provided by you may be mandatorily required for us to administer our relationship and/or to comply with statutory requirements relating to immigration or taxation.  Failure to provide mandatory personal information may affect our ability to accomplish the purposes stated in this Notice and potentially affect your training and development.

The list set out above is not exhaustive and there may be other personal information which Rowan Dartington collects, stores and uses in the context of the relationship.  We will update this Notice from time to time to reflect any notable changes in the categories of personal information which we process.

Most of the personal information which we process will be collected from you directly.  In limited circumstances your personal information may be provided by third parties, such as former employers, official bodies (such as regulators or criminal record bureaus) or medical professionals.

For the purposes of our background checking carried out as part of our selection process we will also gather data from publicly available sources as the electoral roll, court judgements, insolvency registers, internet search engines and social media sites and/or engage a third party to conduct electronic ID checks, sanctions and politically exposed person checks.

What do we use your personal information for?

Rowan Dartington uses your personal information for a variety of purposes in connection with your training and development as summarised above.  Most of this processing takes place to enable Rowan Dartington to perform its obligations under your contract and/or to comply with its legal obligations and we have set out below the main purposes for which personal information is processed:

  • Processing your application to join Rowan Dartington
  • Processing your application for examination registration
  • Processing, recording and storing your academic achievements including notification of results
  • Administration of your contract with Rowan Dartington, including remuneration agreements
  • For giving references about you if requested to do so by any third party
  • To establish your training and development needs
  • For the setting up and arrangement of any pension, private healthcare or similar arrangements which may be arranged by Rowan Dartington on your behalf
  • For legal, regulatory and compliance purposes (which may lead to disclosure to regulatory bodies or HMRC)
  • To establish contact in the case of an emergency (e.g. next of kin)
  • For the contact of credit reference agencies in connection with your application and whilst any loans provided to you by Rowan Dartington remain outstanding
  • The day to day management of tasks and responsibilities
  • To manage performance, including the conduct of regular reviews
  • Obtaining Financial Conduct Authority approval where necessary
  • Corporate travel and other reimbursable expenses (if applicable)
  • Conflicts of interest reporting
  • To address disciplinary and grievance issues
  • To protect our confidential and proprietary information and intellectual property
  • To monitor the proper use of our IT systems
  • To prevent fraud against the company and its clients
  • For succession planning

In addition, Rowan Dartington will process your personal information in pursuit of its legitimate interests provided this does not unduly impact your privacy rights; in these cases, we have specified below the processing and the nature of the legitimate interest in question:

  • In connection with the prospective transfer or sale of a business or group company, we may share personal information as part of the due diligence process and/or to facilitate a smooth transfer.  In these cases, the information we share will be anonymised wherever possible, and it will be a condition that the recipient holds the information securely, use it only for the prescribed purposes and deletes/returns the information if the transfer or sale does not go ahead.
  • In specific cases Rowan Dartington as part of the St James’s Place Group of companies will carry out psychometric or job-related evaluations in order to facilitate development discussions and/or to evaluate you for potential alternative roles. Additional information about how your personal information is processed in the context of these evaluations will be available at the time of completion of any such valuation.

The details set out above are not exhaustive and Rowan Dartington may undertake additional processing of personal information in connection with the relationship.  Rowan Dartington will update this notice from time to time to reflect any notable changes in the purposes for which it processes your personal information.

When we will share your personal information?

  • Financial institutions and other payment providers
  • Benefits providers
  • Background vetting specialists
  • Occupational health providers and other medical professionals
  • HMRC and/or any other applicable government body
  • Accountants, lawyers and other professional advisors
  • The Financial Conduct Authority and/or the Prudential Regulation Authority and/or any other applicable regulatory body
  • St James’s Place Group of Companies
  • Third party training providers

Wherever possible, personal information is shared under the terms of a written agreement between Rowan Dartington and the third party which includes appropriate security measures to protect the personal information in line with this notice and our obligations.  The third parties are permitted to use the personal information only for the purposes which we have identified, and not for their own purposes, and they are not permitted to further share the data without our express permission.

What special category information do we process?

Certain categories of data are considered ‘special categories of personal information’ and are subject to additional safeguards. Rowan Dartington limits the special categories of personal information which it processes as follows:

Health Information

Rowan Dartington will process information about your physical or mental health in compliance with its legal and contractual obligations, in particular (i) to administer company and/or state sick pay; (ii) to facilitate the provision of benefits, such as private medical insurance; (iii) to comply with obligations owed to disabled candidates; (iv) to comply with health and safety obligations; and (v) to maintain a sickness absence record.

Criminal Record checks

We will conduct a criminal record check, which is called a Disclosure and Barring Service (DBS) check.

We will always treat special category information as confidential and it will only be shared internally where there is a specific and legitimate purpose to do so. We have implemented appropriate physical, technical and organisational security measures designed to secure your personal information against accidental loss and unauthorised access, use, alteration or disclosure.

Special category information will typically be retained during an individual’s relationship with Rowan Dartington & Co Ltd or Stafford House and its subsidiaries.  Following the termination of an individual’s relationship with Rowan Dartington, we will typically retain health information for 12 months subject to any exceptional circumstances and/or to comply with particular laws or regulations.

How long do we keep personal information for?

Rowan Dartington’s policy is to retain personal information only for as long as needed to fulfil the purpose(s) for which it was collected, or otherwise as required under applicable laws and regulations.

Under some circumstances we may anonymise your personal information so that it can no longer be associated with you.  We reserve the right to retain and use such anonymous data for any legitimate business purpose without further notice.

Is my data secure?

We take the security of your data very seriously and have systems, procedures and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed and is not accessed by anyone other than employees in the performance of their duties.

We also have procedures in place to deal with any known or suspected personal data breaches and will our regulator and/or you if we are legally required to do so.

Cookies

This Rowan Dartington website uses Cookies (small text files that are stored on your computer or in your browser) to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users.  The website does not store or capture personal information about you when you visit it, it merely records traffic information about all of our visitors collectively, for example the number of visits the website receives.  In order to respect our visitors’ rights of privacy, this information is anonymous, and no individual visitor can be identified from it.

You can disable and delete cookies by changing the appropriate setting within your browser’s ‘Help’, ‘Tools’ or ‘Settings’ menu.  Please note that by disabling Cookies you may not benefit from some of the features of our site.  You can find out more about deleting or controlling cookies by visiting aboutcookies.org.

Automated Profiling

Rowan Dartington & Co. Ltd does not rely on automated profiling for recruitment decisions.  If this changes, we will contact you and give you the opportunity to object.

Your rights

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in ways set out in this notice.  Please contact us at any time using the details below in the contact us section if you wish to exercise any of these rights.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request, for example when we have our own legal obligations, but we will write to you to let you know.

The right to access your personal information

You are entitled to a copy of the personal information we hold about you and certain details of how we use it.

We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures, which may mean that we will require proof of identity from your prior to disclosing such information.

We will usually provide your personal information to you in writing unless you request otherwise.  Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.

If you would like to request a copy of the information we hold, please do so in writing to:

Data Protection Specialist
Compliance & Risk
Rowan Dartington & Co. Ltd
Colston Tower
Colston Street
Bristol
BS1 4RD

The right to rectification

Please help us to keep your personal information accurate and up to date.  If you believe there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.

The right to restriction of processing

In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.

The right to withdraw consent

Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.

The right to erasure

You are entitled to request your personal information to be deleted in circumstances such as where we no longer need your personal information for the purpose we originally collected it.  When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.

The right to object to direct marketing

You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time. You can do this either by clicking on the "unsubscribe" button in any email that we send to you or by contacting us using the details set out in the contacting us section.

Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you.

 The right to data portability

In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.

When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request

 If you fail to provide us with personal data

You are under no statutory or contractual obligation to provide data to Rowan Dartington & Co. Ltd during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

If your application is successful, it will be a condition of any job offer that you provide evidence of your right to work in the UK and satisfactory references.

You are under no obligation to provide information for equal opportunities monitoring purposes and there are no consequences for your application if you choose not to provide such information.

The right to lodge a complaint with the Information Commissioner’s Office (ICO)

If you believe we have breached data protection laws when using your personal information, you have a right to complain to the ICO.

You can visit the ICO’s website at https://ico.org.uk/ for more information.  Please note lodging a complaint will not affect any other legal rights or remedies that you have.

Contacting us

If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our Data Protection Specialist at Rowan Dartington & Co. Ltd, Compliance and Risk, Colston Tower, Colston Street, Bristol, BS1 4RD or compliance@rowan-dartington.co.uk

Updates to this notice

From time to time we may need to make changes to this notice, for example, as a result of changes to the law, technologies or other developments.  We will provide you with the most up to date notice and you can check our website periodically to view it.

This notice was last updated on 23rd September 2019.