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Privacy Notice for Shareholders

PRIVACY NOTICE FOR SHAREHOLDERS

We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect and use during and after the period you hold shares in us. This notice explains how we comply with the law on data protection and what your rights are.

This notice applies to our current and former shareholders and to individuals who are representatives of our shareholders. This notice does not form part of any contract relating to the shares you hold.

References to we, our or us in this privacy notice are to WH Smith PLC (being WH Smith PLC incorporated in England and Wales with Registered Number: 05202036 Registered Office: Greenbridge Road, Swindon, Wiltshire SN3 3RX).

We have appointed a Data Protection Officer to oversee our compliance with data protection laws and they have overall responsibility for data protection compliance in our organisation. Contact details are set out in the "Contacting us" section at the end of this privacy notice.

For the purposes of this privacy notice the controller is WH Smith PLC.

In this privacy notice you can find out more about:

• what personal information we use in relation to registered shareholders
• how we collect, use and share personal information within WH Smith and with our business partners
• your rights in relation to any personal information we hold about you
• how you can contact us with any questions you may have about privacy
This privacy notice extends to the share registry services which are carried out by Computershare Investor Services PLC ("Computershare"). We have appointed Computershare under the rules of the Companies Act to manage our register of shareholders. Computershare's role as registrar includes keeping an up-to-date record of shares held by shareholders, administration of dividends, managing share transfers, issuing share certificates and supporting other regulatory functions. In carrying out registry services, Computershare processes personal information about you as a shareholder on our behalf.

If you use any of the apps and engagement tools which Computershare (on our behalf) make available to our shareholders (for example the Computershare Investor Centre, Share Dealing Site, Proxy Voting Site and Employee Share Plans site) ("Online Services"), you should be aware of the additional privacy notices which Computershare make available for the relevant Online Service. This privacy notice supplements, but does not override, those notices. 

This privacy notice is separate from and not intended to override the terms of any contract we have with you or your rights under data protection laws.
We will amend this privacy notice from time to time to keep it up to date with current legal requirements and the way we operate our business. Please regularly check these pages for the latest version. 

WHAT PERSONAL INFORMATION WE COLLECT WHEN YOU BECOME A REGISTERED SHAREHOLDER


WH Smith PLC will collect and use personal information such as your name, contact details, the votes you cast and the Reference Number attributed to you by us as a WH Smith shareholder. We collect this personal information when you provide details to us directly or through your agent, stock broker or share plan administrator, for example, on shareholder application forms or stock transfer forms. We also collect personal information when you register for or use any of the Online Services or our websites.
We use your personal information (with the support of our registrar, Computershare):
• to manage your shareholding interest in WH Smith
• to allow you to exercise your rights as a shareholder
• to keep our shareholder register up-to-date (for example where you move address or change your name)
• to contact you with shareholder related information, including important information about dividend distributions, shareholder resolutions, reports and meetings, including details of our Annual General Meeting
• to address any queries you raise with us.
We encourage you to use the Computershare Investor Centre website to manage the information we provide to you as it provides a secure online platform to help you manage your shareholdings and communication preferences. The Investor Centre website uses cookies.  For further information about cookies and how they are used by Computershare please refer to their website.
Respecting privacy rights
We are committed to collecting and using personal information in accordance with applicable data protection laws.
Wherever we collect or use personal information, we will make sure we do this for a valid legal reason. This will be for at least one of the following purposes:
• to manage your shareholder rights and our obligations to you as a shareholder, in accordance with our Articles of Association and applicable laws;
• to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities;
• to operate and improve our business and keep our shareholders informed about our products and services;
• for any other purposes we identify as relevant to further our business interests but never at the expense of your privacy rights

How we share your personal information

We share personal information with a number of trusted third parties who work with us to help deliver our services, in order to fulfil our legal obligations or at your request. Such third parties include:
• Computershare, as our Registrar, who manages our share register;
• other members of WH Smith Group, as necessary to operate our business;
• payment providers who help us manage dividend and other payments to our shareholders;
• solicitors and professional service firms who provide us with legal support in relation to our services or any litigation;
• service providers who help operate our IT and back office systems;
• regulators who regulate how we operate, these include the Financial Conduct Authority, the London Stock Exchange, HMRC and the Information Commissioner's Office;
In addition to the above, we will share your personal information
• if the law requires or permits disclosure, or there is a duty to the public to share or disclose your personal information e.g. for the purpose of verifying shareholdings or contacting shareholders about matters relating to the company, their shareholding or a related exercise of rights;
• with any third party at your request or with your consent;
• with any individual or company to whom we propose to transfer our obligations and rights in relation to the administration of our share register; and
• with any other person that requires access to or receipt of your personal information in connection with or as a result of any agreement we may have with or concerning you, or our arrangements with you.

Working with regulators and fraud prevention and detection agencies


We may use your personal information to help us to detect and prevent fraud, fight financial crime and meet our regulatory responsibilities. This may involve checking public registers (e.g. the electoral roll or registers of county court judgments, bankruptcy orders or repossessions), conducting online searches from websites and other information sharing platforms and using databases managed by credit reference agencies and other reputable organisations. This will help us verify your identity and carry out tracing exercises. We may also share your information and undertake searches with third party organisations such as public bodies, credit reference agencies, fraud prevention agencies and our regulators (which include the FCA, and ICO).
If you give us false or inaccurate information and we suspect fraud, we will record this to prevent further fraud and money laundering.

Retaining personal information in our systems


We generally only keep personal information for as long as is reasonably required for the reasons explained in this privacy notice. We do keep certain records - which may include personal information - for more extended periods e.g. after you have sold your shareholding, if we need to do this to meet legal, regulatory, tax or accounting needs.
It is important to ensure that the personal information we hold about you is accurate and up‐to‐date, and you should let us know if anything changes, for example if you move home or change your phone number or email address. You can contact our registrar Computershare at The Pavilions, Bridgwater Road, Bristol BS99 6ZZ or via the Computershare Investor Services website at http://www.investorcentre.co.uk
. Protecting personal information outside the UK
Some of the organisations we share information with may be located outside of the European Economic Area ("EEA"). We will always take steps to ensure that any transfer of information outside the EEA is carefully managed to protect your privacy rights:
• transfers within the WH Smith Group will be covered by an agreement entered into by members of the WH Smith Group (an intra-group agreement) which contractually obliges each member to ensure that your personal information receives an adequate and consistent level of protection wherever it is transferred within the Group;
• where we transfer your data to non-WH Smith Group members or other companies providing us with a service, we will obtain contractual commitments and assurances from them to protect your personal information;
• we will only transfer personal information to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights; and
• any requests for information we receive from law enforcement or regulators will be carefully validated before personal information is disclosed.
You have a right to ask us for more information about the safeguards we have put in place as mentioned above. To learn more, please see below.
YOUR RIGHTS
You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• the right to object to certain automated decision making processes using your personal information.

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information where we know we are dealing with the right individual.
We may not always be able to do what you have asked, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the "Contacting us" section below. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for‐the‐public/

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If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email support@whsmith.co.uk or write to the Data Protection Officer at Greenbridge Road, Swindon, Wiltshire SN3 3LD.