We process the personal information of directors and office holders of BAE Systems plc and group subsidiary companies, directors and office holders of joint venture companies (where we hold the secretaryship and/or manage the statutory registers). We may also hold a record of directors/officers who serve or served on boards of other legal entities in which BAE Systems has or has had an interest.
This notice should be read in conjunction with the Overview.
What processing activities do you undertake that include my personal information?
We administer and manage your relationship with the company of which you are a director or officer and maintain the general records necessary to do so.
This includes the administrative and management activities that we undertake with respect to governance requirements, for example:
- Maintaining BAE Systems plc and group companies’ statutory registers and those of certain joint venture companies
- Managing compliance with overseas registrations and government agency requirements, including foreign ownership and control submissions
- Complying with statutory reporting requirements
- Archiving and managing your directorship/office record, as appropriate
- Creating and administrating minutes of meetings
What categories of personal information are included in these processing activities?
If you are a director or officer of a BAE Systems joint venture company for which BAE Systems does not (or did not) hold the secretaryship and/or does not (or did not) maintain the statutory registers, then we will hold a record of your name only.
For certain overseas jurisdictions, we may need to process additional identity information, such as your father’s name. If necessary, the requirement will be explained to you and the information requested from you.
What is the reason for these processing activities?
We use your personal information to manage our relationship with you and to administer your board membership, directorships, or office holding.
What are the legal grounds you rely on to carry these out?
This processing is necessary for the compliance with legal obligations to which the Company and its joint ventures are subject.
This processing is also necessary for the purpose of the legitimate interests pursued by the Company and its joint ventures.
(See “What are the legal grounds for processing personal information?” in the Overview section.)
What are the 'legitimate interests' referred to above?
The Company considers that it has a legitimate interest in operating its business and managing the information of its directors, board members and office holders and those of its joint ventures.
This includes:
- Complying with statutory reporting requirements and compliance obligations for overseas registrations and government agencies, including foreign ownership and control submissions.
- Supporting the business and commercial interests of the Group and its joint ventures by providing information on directors and other officers of individual legal entities where required in documentation including (a) bid support; (b) delegated authority and (c) business or trading registrations.
- Maintaining a central group record of directors and officers of legal entities in which BAE Systems has an interest (including joint venture companies, whether or not we hold the statutory register/secretaryship, and legal entities in which we have invested).
To the extent that you did not get this personal information from me, how did you collect this information?
Some of this personal information will come from internal sources, including the HR team and share plan administrators (see “Where do you get my personal information from?” in the Overview section).
We may receive information from other sources as set out in this Notice (see “Where do you get my personal information from?” in the Overview section). If you are a director or officer of a joint venture company, we may receive your personal information from the joint venture company.
Who do you share this personal information with?
Your personal information is shared internally, as set out in this Notice (see “When do you share my personal information with others?” in the Overview section). This would usually include Business Unit and Functional legal counsels, and Group Business Development, for Overseas legal entities, and Group Finance. For joint ventures, this would include the joint venture itself.
In addition, some of your personal information will be shared externally with company registries (such as Companies House in the UK), foreign governments, legal advisers, auditors, Company Secretarial providers, notaries and as otherwise set out in this Notice (see “When do you share my personal information with others?” in the Overview section).