Privacy Policy

General Data Protection Regulations: The General Data Protection Regulations (GDPR) is the new regulation being brought into the EU to introduce greater control over the use of personal data. The underlying principles of GDPR are similar to existing Data Protection legislation. However, the GDPR contains more specific requirements for the use and protection of personal data than existing legislation.

Under the GDPR, personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural personal is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

We are required to notify you with the following information regarding the processing of personal information relating to you.

Who we are: The Sovereign Group and its subsidiaries (“Sovereign”) are a “data controller” of the personal information we hold for the purpose of the GDPR and may process your personal data. A full list of data controllers can be found at the bottom of our Contact Us page.

Sovereign offer corporate, family office and retirement planning services. More information relating to the services offered can be found here.

Purpose of processing your data: Sovereign will process your data for the following purposes:

  • In the performance of the contract we have entered into with you;
  • It is in our legitimate interest to process your personal data;
  • When we collect and use certain special categories of personal data with your express consent; and
  • Where we need to comply with a legal obligation.
Information that we collect: Personal data is defined in the GDPR as any information relating to an identified or identifiable natural person. The following non-exhaustive list includes the types of personal data that we may collect about you and, in some circumstances, your spouse, civil partner, partner or dependants:

  • full name, address and contact details;
  • date of birth;
  • gender;
  • marital (or relationship) status;
  • National Insurance Number / Tax Identification Number;
  • passport number;
  • details of bank account;
  • The source of your wealth.
Categories of personal data:
  • Information and documentation relating to your identity, location, family, employment background and financial details;
  • Recorded telephone calls;
  • We may obtain some of this information from your advisors or agents if we hold your permission to do so; and
  • Information may also be obtained from sources available in the public domain.
Telephone call recording: Sovereign or its affiliates (SAM) have a legal obligation to record telephone calls in certain circumstances and use a secure telephone calls logging software to record, store and archive those telephone calls. The calls are recorded for training, quality, and regulatory purposes.
Consequences of non-provision of your personal data: Sovereign would not be able to continue with its contractual agreement with you.
Recipients of your personal data: From time to time and if you instruct us to do so, we may share your data with:

  • Other Sovereign offices across the world;
  • Professional advisors such as lawyers, accountants, financial advisors;
  • Other financial institutions such as banks, insurance and investment companies;
  • Tax authorities and regulators for reporting purposes; and
  • Third party risk intelligence agencies for the purpose of KYC screening and due diligence.
We may disclose your personal information in some cases to governmental agencies or entities, regulatory authorities or other persons in line with any applicable law, regulations, court order or official request. For example, your data may be shared with these entities where Sovereign would be expected to cooperate in the event of a criminal investigation.
Will your data be transferred inside/outside of the EU? Only in the circumstances described above.
How will it be protected whilst in transit and where can I obtain further details? Data will be encrypted and/or password protected.

Further details can be obtained from

How long will the data be retained? In accordance with jurisdictional legislation.
Your rights:
  • To be informed about how we use your personal data;
  • To access your data;
  • To have your data rectified promptly if it is inaccurate or incomplete;
  • To have your data erased in specific circumstances;
  • To restrict processing;
  • To object to processing of your data;
  • To portability of your data so that you can obtain and reuse your data; and
  • To prevent automated decision making and profiling.
Withdrawing consent: If you wish to withdraw your Consent to process data, you can do so in writing, but such a withdrawal may affect the way in which we deal with you and/or any related entities.

Please note that we are contractually obliged to retain certain information in accordance with legislation.

Complaints: If you wish to make a complaint, please contact Sovereign’s DPO ( or, if you prefer to complain to a higher authority, please contact your local data protection commissioner.
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Definitions: Data Subject is a living individual to whom personal data relates.


Personal Data means any operation or set of operations which is performed on personal data or on sets of personal data.


Consent of the Data Subject means any freely given, specific, informed and unambiguous indication of the Data Subject’s wishes.


Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.