Companies Act 2014 section 1110B

Identification of shareholders

Section 1110B sets out the rules enabling a traded PLC to identify its shareholders by requesting information from intermediaries in the chain of share custody, and establishes how that information must be handled, transmitted and protected under data protection law.

  • A traded PLC (or its nominated third party) may request shareholder identity information and details of the next intermediary in the custody chain from any intermediary providing services in respect of its shares.
  • An intermediary that holds the requested information must provide it as soon as practicable; if it does not hold the information, it must pass the request along the chain and inform the requester accordingly.
  • Personal data of shareholders may only be processed to the extent necessary to identify shareholders, communicate with them directly, or facilitate shareholder rights and engagement, and must not be retained for more than 12 months after the person ceases to be a shareholder (unless EU law permits a longer period or specific exceptions apply).
  • An intermediary that discloses shareholder identity information in compliance with this section is protected from any claim that such disclosure breaches contractual or legal restrictions on the sharing of information.

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