Privacy policy

Moore Stephens Channel Islands Privacy Notice
 
Introduction
In this Privacy Notice, where we refer to "Moore Stephens" (or "we"/"us"/"our)", we mean each of:
  • Moore Stephens Audit and Assurance (Guernsey) Limited
  • Moore Stephens Fiduciaries (Guernsey) Limited 
  • MSTC (Jersey) Limited
  • Moore Stephens Audit and Assurance (Jersey) Limited
  • MS Fund Services (Jersey) Limited
  • MS Services (Jersey) Limited
  • Moore Stephens Services (Guernsey) Limited 
We may collect information from you through your use of this website, when you request information from us or engage with any of our services, or as a result of your relationship with one or more of our employees or otherwise in the course of our business. References in this notice to “your information” are to personal information that you provide to us or which we otherwise gather in the course of operating our business. 
 
Some of the information we collect and process will be personal data, and the purpose of this notice is to explain how we use your information and your personal data.

About us

Moore Stephens Channel Islands is an accountancy, advisory and fiduciary firm and includes audit and assurance, accounting and business support, wealth management, trust and corporate services and fund administration services.  The firm provides professional support to a broad range of individuals and entrepreneurs, large organisations and complex international businesses. 
 
We are also part of the Moore Global Network, which has 30,000 people across more than 260 independent firms and 110 countries. Its privacy notice is available here.

The information we collect about You
 
We may collect various types of your information about you, including:
  • your personal identification information (which may include your name and passport information, your IP address and information relating to claims, court cases and convictions, politically exposed person (PEP) status, information available in the public domain and such other information as may be necessary for us to provide our services and to complete our CDD process and discharge our AML/CFT obligations)
  • your contact information (which may include postal address and e-mail address and your home and mobile telephone numbers)
  • your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have)
  • your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold)
  • financial information, sources of wealth and your investment and assets (which may include details of your current, previous and prospective investments, assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history)
  • information about client matters which may include a wide range of personal information which may include (but may not be limited to) information about your employment, health, family issues and relationships and your regulatory status
  • we may also collect and process information regarding people connected to you, either by way of professional (or other) association or by way of family relationship
Collection of Your information
 
We collect your personal information from the following sources:
  • information which you give to us, such as: 
    • Forms and documents as we may request that are completed in relation to the administration/management of any of our services
    • information gathered through client due diligence carried out as part of our compliance with regulatory requirements
    • any personal information provided by way of correspondence with us by phone, e-mail or otherwise
  • information we receive from third party sources, such as:
    • our clients: in connection with matters upon which we are or may be instructed (for example where you are a counterparty to a transaction or an employee of one of our clients)
    • entities in which you or someone connected to you has an interest
    • your legal and/or financial advisors
    • financial institutions who hold and process your personal information
    • credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements
    • personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act. 
Use of Your information
 
Here we set out the basis upon which we process your information. Please note that we may process your information for more than one lawful basis, depending on the specific purpose for which we are using that information.
 
Performance of a contract

We provide a diverse range of professional services, of which more information can be found here.
 
Many of our services require us to process your information for purposes necessary for the performance of our contract with our clients. For example, this may include processing your information to provide requested bespoke fiduciary support to a private client, or processing your personal information where you are an employee, subcontractor, supplier or customer of our client.
 
Legitimate interests
 
We may process your information for the purposes of our own legitimate interests (and those of third parties) in the effective delivery of information and services to our clients, and in the effective and lawful operation of our businesses, provided that those interests do not override your interests, rights and freedoms as a data subject under applicable data protection law.
 
Examples of such processing activities include:
  • managing our relationship with clients;
  • developing our businesses and services (such as identifying client needs and improvements in service delivery);
  • monitoring the services we provide clients for quality control purposes, which may involve processing your information stored on the relevant professional file;
  • managing risk in relation to client engagements and to the firm generally;
  • maintaining and using IT systems, including security monitoring to identify harmful programs;
  • hosting or facilitating the hosting of events;
  • administering and managing our website and systems and applications. 
Compliance with a legal obligation
 
As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We will process your information as necessary to comply with those obligations.
 
One example of such processing includes anti-money laundering activities such as carrying out searches (using for example, internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations, and to check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).
 
We are also required to keep certain records to demonstrate that our services are provided in compliance with our legal, regulatory and professional obligations.  
 
Where necessary for the establishment, exercise or defence of legal claims
 
In appropriate circumstances, we may need to collect and process your information for the establishment, exercise or defence of legal claims.
 
This may include taking legal advice where appropriate.
 
Consent
 
In certain limited circumstances, we may process your information by consent. Where consent is the only basis upon which your information is processed, you will always have the right to withdraw your consent to processing for such specific purposes.
 
Data retention
 
We retain your information for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, Moore Stephens Jersey’s standard retention period for records and other documentary evidence created in the provision of services is 10 years. 
 
Moore Stephens Guernsey implement a standard retention period of 6 years except for those documents that require a longer or permanent period. 
 
These standard periods may be disapplied in appropriate circumstances.
 
Should you have any queries with respect to retention periods please see “Contacts” section toward the end of this privacy notice. 
 
We periodically review our data retention policies, and we reserve the right to amend the above retention periods without notice.
 
Data Security
 
We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
 
We have put in place appropriate security measures to prevent your information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This is not only in accordance with our obligations under data protection law, but also in accordance with our regulatory obligations of confidentiality.
 
Data transfers
 
We will share your information with third parties where we are required by law, where it is necessary to administer our relationships between clients, or where we have another lawful reason for so doing.
 
We are part of a global network of firms and accordingly your information may be transferred to other member firms of the Moore Global Network.
 
This may result in your information being transferred outside the countries where we and our clients are located. This includes to countries outside Jersey, Guernsey and/or the European Economic Area (EEA) and to countries that do not have laws that provide specific protection for your information.
 
Whenever we transfer your personal data out of the EEA we ensure that it is protected to an equivalent level – for example:
  • By transferring the information to countries that have been deemed to provide an adequate level of protection for personal data by appropriate authorities in the EEA, the UK, the Bailiwick of Jersey, or the Bailiwick of Guernsey
  • By utilising standard contractual clauses approved by a competent authority. 
We will also share your information with third party service providers. For example, we use third parties to provide:
  • our cloud services, and to operate and manage these services;
  • anti-money laundering and sanctions screening services;
  • archiving services;
  • business management software;
  • telecommunications services;
  • information technology services;
  • marketing assistance;
  • professional advisory services (including our auditors);
  • administration services;
  • banking services;
  • investment services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your information. We only permit our third-party service providers to process your information for specified purposes and in accordance with our instructions.
 
We may also share your information with:
  • Other entities in the Moore Global Network and their employees, contractors and agents
  • Professional advisers (to us and to others including our clients) including lawyers, bankers, auditors and insurers
  • Regulators and other authorities based in Jersey and Guernsey
  • Our clients in connection with the products and services we provide and for the purposes of maintaining and managing our relationship with our client;
  • Any third parties as required in order to establish, exercise, defend or to protect legal claims
  • Competent regulatory, prosecuting, tax or governmental authorities, courts or other tribunals upon their request or as required by law
  • Any third parties to the extent such disclosure is required under law or to enable products and services to be provided to our clients or where our legitimate interests require it. 
Your Rights
 
You have the following rights (which are subject to certain exceptions) in respect of the personal data about you that we process:
  • the right to access your personal data
  • the right to "port" your personal data
  • the right to rectify your personal data
  • the right to restrict the use of your personal data
  • the right to request that your personal data is erased
  • the right to object to processing of your personal data.
Should you wish to make a complaint regarding the processing of your personal data, please contact us using the contact details below.

You also have the right to lodge a complaint about the processing of your personal data with the Office of the Information Commissioner in Jersey (https://oicjersey.org), The Office of the Data Protection Authority in Guernsey (https://odpa.gg), the Information Commissioners Office in the UK (https://ico.org.uk) or the data protection authority in the EU member state of your usual residence or place of work.
 
Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time. If you wish to exercise any of the rights set out above, please contact: To stop receiving an email from a Moore Stephens marketing list, please click on the unsubscribe link in the relevant email received from us.
 
Inaccurate or amended information
 
Please let us know as soon as possible if any of your personal information changes (including your correspondence details). Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services to you.
 
Changes to this notice
 
We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.
 
This privacy statement was last updated on 22 August 2022.
 
Contacts
 
If there are any questions regarding this notice please email our data protection team at:
 
Moore Stephens Jersey:
dataprotection@moorestephens-jersey.com
 
Moore Stephens Guernsey:
dataprotection@msgsy.com