Wilmington Trust

This Visitor Privacy Notice concerns the collection and use of your personal information when you visit the offices and/or facilities of group companies or affiliates of Wilmington Trust (UK) Limited (collectively, "Wilmington Trust", "us" and "we") in the United Kingdom and the European Union.

This Visitor Privacy Notice applies to all visitors to our offices and/or facilities.

If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Visitor Privacy Notice.

What information we collect and how we collect it

Wilmington Trust will collect, process and retain information about you that you provide voluntarily, that we collect automatically, and that we obtain from third-party sources, such as your employer or your employee contact at Wilmington Trust.

The personal data we collect from you will vary depending on the type of office or facility you are visiting, and/or the country in which it is located. However, in general, if you visit our facilities the personal data that we process will include:

• Identity and contact details, such as name, address, telephone number, vehicle registration number, photo ID;
  
  
• CCTV footage and images obtained whilst in attendance at Wilmington Trust's premises and facilities;
  
  
• Location information within our buildings, including without limitation access logs from card readers and other access control devices at our premises;
  
  
• Online identifiers through your access and use of the Wilmington Trust networks including our visitor Wifi. This information includes your IP address, MAC address, device IDs, usage information (such as time, duration and location where you used our networks) and administrative information (for example where you need assistance or help with technical difficulties).

How we use your information

We process your personal information to: pre-register and register visitors to our premises; grant you access to Wifi or our networks and for security reasons including for the protection of yourself, our staff and our property. In addition, where you are visiting our premises for an event or meeting and we are providing catering, we may collect information such as your dietary requirements or allergies.

Although we generally do not collect special category personal data from you, where appropriate, we may collect information from you such as physical disabilities or other medical or health information in order to improve your visit to our premises and make adjustments for you.

We process this personal information to the extent necessary for our legitimate interests in protecting our offices and our confidential information against unauthorized access. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person (e.g. for the purposes of contacting emergency services in the event of an accident at our facilities). Where we collect any special category personal data from you, we will only do so with your consent.

How we share your information

We only disclose your personal data for the purposes described in this Visitor Privacy Notice and with the following categories of recipients:

• To our group companies, to the extent that such information is relevant to fulfilling the purpose of your visit to us.
  
  
• To third-party service providers and partners, to the extent that we use any external parties to process personal information for us for purposes described in this Visitor Privacy Notice, for example to manage events or provide catering services to us.
  
  
• To any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

To the extent that any personal information is transferred outside of the United Kingdom or the European Economic Area we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Visitor Privacy Notice. These include implementing the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies, which require all our group companies to protect personal data they process from the United Kingdom and the EEA in accordance with UK and EU data protection law.

We rely on similar appropriate safeguards with any third-party service providers and partners and may also rely on representations from third parties that appropriate safeguards are in place through their compliance with approved data transfer frameworks. Further details can be provided on request.

Data retention

We retain your personal data in line with our retention policies and only where we have a legitimate reason for doing so. For visitors to our site we retain your visitor record for the period required by law.

We will keep CCTV footage and images from our premises in accordance with regulatory requirements, but generally this is no longer than 30 days (unless an incident occurs – such as a suspected crime or security breach – which requires us to keep footage and images relevant to the incident for a longer period of time).

Your data protection rights

For visitors to our United Kingdom and EEA offices you have the following data protection rights:

• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below. 
  
  
• In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
  
  
• ·You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
  
  
• Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  
  
• You have the right to complain to a data protection authority about our collection and use of your personal information.  For more information, please contact your local data protection authority.

Updates to this Visitor Privacy Notice

We may update this Visitor Privacy Notice from time to time in response to changing legal, technical or business developments. A Visitor Privacy Notice will be available to you each time you visit our premises. You will be able to see when this Visitor Privacy Notice was last updated by checking the "Last updated" date displayed at the top of this Visitor Privacy Notice.

How to contact us

If you have any queries relating to this Visitor Privacy Notice please direct these to gdpr@wilmingtontrust.com