‡ In these countries please contact our distributor

Privacy Statement - Shareholders


This privacy notice applies to you if you are an individual and you are either a current or former shareholder of Smith & Nephew plc, or otherwise you currently have, or have previously had, an interest in the shares of Smith & Nephew plc, whether that interest is legal or beneficial.

This privacy notice explains what personal data we collect about you and what we do with it. It also explains your rights in respect of your personal data and it informs you what to do if you have any questions or complaints about our use of your personal data.


The controller of your personal data that is collected and processed for the purposes explained in this privacy notice is Smith & Nephew plc.

The data controller’s representative for the purposes of this privacy notice is Smith & Nephew plc’s Company Secretary, who can be contacted using the contact details set out at the end of this notice.


We collect certain personal data about you, including:

  • your name;
  • your address;
  • 您过去或现在的股份股份和/或现在的股份股份的详细信息,无论您以法律所有者的身份持有或持有这些股份,还是拥有或拥有或有利于它们的利益;
  • 详细信息您过去的行使或打算在将来进行行使,您与Smith&Nephew Plc的股票有关的投票权;
  • your bank or building society account details into which dividends and other income or capital returns on your shares have in the past, or should in the future, be paid;
  • your contact details, such as email addresses and telephone numbers, where you have provided these to us;
  • 您的图像,通过视觉录制设备捕获的图像;和
  • your voice, where this is captured by audio recording equipment.

We collect this information in a variety of ways, including:

  • by you providing it to us, either voluntarily or at our request or demand;
  • if you are also an employee of a Smith & Nephew Group company, by your employer providing certain of these details to us;
  • by third parties acting on your behalf providing certain of these details to us, such as stock brokers and other agents through whom you may have acquired or disposed of your shares or interest in shares;
  • 在您对股票方面行使权利的地方,包括您参加股东大会的出席和投票,或者通过铸造代理投票,无论是用纸质表单还是通过CREST系统提交电子说明;
  • from third parties who perform services on our behalf, such as our registrars who assist us with maintenance of our share registers and with the conduct of our general meetings;
  • 通过在视觉和/或录音设备上捕获您的图像和/或您的声音,例如,如果您参加此类场所,如果您参加此类会议,请在我们的场所,在我们的股东大会上进行的任何录音以及进行任何录音如果您参加此类演讲,其他演讲给股东。

What do we do with your personal data, and on what basis?

We collect and process personal data about you for the following purposes:

  • Legal and regulatory compliance: to comply with laws and regulations to which Smith & Nephew plc is subject, including those that require us to keep records and file returns about the shareholdings in Smith & Nephew plc, pay you amounts due on your shares, send you information about Smith & Nephew plc and comply with disclosure requirements imposed or enforced by governmental authorities and regulatory agencies, including law enforcement agencies and tax authorities.
  • Contractual compliance: to comply with our contract(s) with you, as set out in the memorandum and articles of association of Smith & Nephew plc and/or in any share scheme or plan trust deed or rules, including giving you the information and communicating with you in the ways referred to therein.
  • Managing our relationship with you: to enable us to otherwise manage our relationship with you, including by meeting with you, communicating with you and answering questions you ask of us.
  • Other legal purposes: to enable us to enforce or defend our legal rights, including by bringing or defending legal claims that may be made by or against Smith & Nephew plc in relation to your shareholdings or interests in shares.
  • Safety and security: to seek to ensure the safety and security of attendees at our general meetings and at presentations to shareholders, and to keep records of those events.
  • Dissemination of information: to disseminate information about Smith & Nephew plc’s business, strategy and financial results.

我们处理你的个人资料,因为我们有北方联盟党l obligations to do so and because it is necessary to perform our contract(s) with you as a shareholder and/or holder of interests in shares in Smith & Nephew plc. Otherwise we process your personal data on the basis of our legitimate interests, which are to achieve those purposes referred to above that do not relate to complying with a legal obligation or performing our contract with you.

Where we process your personal data only on the basis of our legitimate interest, you have the right to object to that use. However, we do not have to stop processing personal data where we have compelling grounds that override your interests, or where we need to process your personal data in order to establish, exercise or defend legal claims. If you have any objections please contact Smith & Nephew plc’s Company Secretary (details below).

Where we use your personal data because we have a legal obligation to do so or to perform a contract with you, there is no right to object.

What if we have obtained your consent to use your personal data?

If we obtain your consent for any use of your personal data (which is likely to be for a purpose that is not described in this privacy notice), you may withdraw that consent at any time and we will give you further information in any consent form by which we obtain your consent on how to withdraw your consent.

What are our obligations to collect and your obligations to provide personal data?


If you do not provide us with the information necessary to enable us to comply with our legal obligations, you may not be recognised as a shareholder of Smith & Nephew plc and/or you may not be entitled to exercise or enjoy your rights attaching to your shares in Smith & Nephew plc and/or we may not be able to fulfil our other obligations to you.

Who will we share your personal data with?


我们可能会与Smith&Nephew Plc的子公司共享您的个人数据,例如,他们协助我们遵守对您的法律义务和/或管理与您的关系。

We may also share your personal data with third party suppliers and service providers to Smith & Nephew plc and its subsidiaries, for example professional advisors and third parties who are used by us to perform processing activities, such as software service providers and payment service providers.

The Smith & Nephew plc subsidiaries and/or third parties who process your personal data on our behalf may do so in countries outside the European Economic Area (EEA) that are not deemed to provide a similar level of protection for individuals’ rights in relation to their personal data as in the EEA. Where that is the case we have entered into appropriate contracts with those Smith & Nephew plc subsidiaries and third parties based on the standard contractual clauses approved by the European Commission, a copy of which can be found here:,这样您的个人数据应得到与EEA中处理时相同的保护水平。

For how long will we process your personal data?

只要您持有股票或Smith&Nephew Plc的股份权益,我们将处理您的个人数据。

We will also retain your personal data after you cease to hold shares or an interest in shares in Smith & Nephew plc for so as long as necessary to deal with any outstanding matters relating to your holding or interest, including where legal claims have arisen or might arise.

We may also retain your personal data where it is comprised in business data which evidences your holding or interest, such as where your name or other information about you appears in business records or reports for as long as we need to keep that evidence for our business purposes, which is likely to be at least six (6) years from creation of that evidence or longer where there are legal requirements to hold such evidence for longer.

In respect of your personal data which is contained in our statutory registers, we will retain this personal data for an indefinite period.

What rights do you have in relation to your personal data?


  • access your personal data;
  • request the rectification or erasure of your personal data;
  • request restrictions on the processing of your personal data; and
  • object to our processing of your personal data.

你也可以在某些情况下,有权利to receive a copy of your personal data in a portable format e.g. Microsoft Excel. This right is limited to personal data that you have provided to us and is processed on the basis of your consent or your contract(s) with us. It does not cover personal data that we process on other grounds.

Please contact Smith & Nephew plc’s Company Secretary if you wish to exercise any of these rights.

What should you do if you have any questions or complaints?

如果您对我们如何处理您的个人数据有任何疑问或投诉,则应联系Smith&Nephew Plc的公司秘书:

  • Address: Company Secretary, Smith & Nephew plc, 15 Adam Street, London, WC2N 6LA


You also have the right to complain to the UK Information Commissioner’s Office about how we process your personal data. You can do this by contacting them on their helpline on 0303 123 1113 or +44 1625 545 700 if calling from outside of the UK.

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