Pillar 3 Disclosures

1. Overview

1.1 Introduction and scope

This document sets out the CCLA Group Pillar 3 disclosures on risk management and capital adequacy as at 31 March 2019. It fulfils the regulatory disclosure requirement of the European Union Capital Requirements Regulation (“CRR”) and the Capital requirements Directive (“CRD”) referred to collectively as CRD IV.

CRD IV created a revised regulatory capital framework and introduced consistent capital adequacy standards across the EU with the aim of seeking to reduce the likelihood of market disruption or consumer loss as a result of prudential failure. It does so by trying to ensure that the financial resources held by a firm are commensurate with the risks associated with its business profile and control environment.

The framework consists of three ‘pillars’:

  • Pillar 1 specifies the minimum capital requirements that a firm is required to hold to cover the risks arising from credit, market and operational risk;
  • Pillar 2 requires an assessment to be made of whether additional capital should be held against risks not captured by Pillar 1. This is achieved though the Individual Capital Adequacy Assessment Process (“ICAAP”); and
  • Pillar 3 requires the disclosure of specific information about the underlying risk management controls and the capital position of the firm.

1.2 Structure of CCLA

CCLA Investment Management Limited (“CCLA IM”) and its wholly owned subsidiary, CCLA Fund Managers Limited (“CCLA FM”), together the CCLA Group (“CCLA”), are authorised and regulated by the Financial Conduct Authority (“FCA”).

CCLA IM is categorised under the FCA rules as a Collective Portfolio Management Investment Firm (“CPMI Firm”), whose activities are simple and primarily not credit related. It is classified as an IFPRU Limited Licence firm. It acts as the manager for a number of Common Funds established under the Church Funds Investment Measure 1958, as the manager of a UCITS, as a discretionary investment manager, and as the delegated investment manager for CCLA FM.

CCLA FM is categorised under the FCA rules as a Collective Portfolio Management Firm (“CPM Firm”). It primarily acts as the AIF Manager for a number of Common Investment Funds established under Charities legislation and falling within the scope of AIFMD. CCLA FM also operates as the Authorised Contractual Scheme (“ACS”) Manager for the CCLA Authorised Contractual Scheme.

The Pillar 3 disclosures have been prepared on a consolidated basis.

1.3 Frequency and Means of Disclosure

The information within the scope of these Pillar 3 disclosures is published on an annual basis and is based on CCLA’s financial position as at its year end, 31st March. The disclosures are required to be published in conjunction with the date of publication of the financial statements. The disclosures have not been audited by CCLA’s external auditors, do not constitute any form of audited financial statement and have been produced solely for the purposes of the Pillar 3 disclosure obligations and are not used by management for any other purpose. The disclosures should not be relied upon in making judgements about CCLA.

CCLA’s Board of Directors are ultimately responsible for the systems and controls and for reviewing the effectiveness of those arrangements. These disclosures have been reviewed and approved by the Board. 

2. Risk Management

2.1 Principles and Risk Governance

CCLA places the highest degree of emphasis and focus on managing the risks faced by its business (“business risks”). It defines business risks as actions or inactions that could adversely affect its ability to achieve its business objectives and thus hinder the implementation of business strategies. An effective system of controls and monitoring measures helps to manage business risks so that the business objectives are achieved.

CCLA has implemented a risk management framework which is structured so as to identify and manage the business risks that CCLA faces as a result of carrying on its investment management business. The policy considers the likelihood of occurrence, the impact on the business and any mitigating systems and controls that are in place.

CCLA’s appetite for risk forms part of the basis against which business and financial decisions are taken. CCLA has a fairly conservative appetite for risk and seeks to manage its risks through effective processes and controls. Senior management determines the business strategy and risk appetite of the company, focussing on the main areas of operational and business risk, and having regard to relevant laws and regulatory requirements. The senior management team meets on a regular basis to discuss key business issues, regulatory capital management, business planning and risk management.

CCLA has identified and assessed its risks and has implemented controls and procedures to manage them appropriately.

The CCLA Board meets on a calendar quarter basis and are provided with relevant information to enable the Directors to understand and assess CCLA’s ongoing risks, risk control functions and capital and liquidity controls.

CCLA has a risk management process which has been embedded within the business. The system is designed to provide a consistent methodology for the identification, assessment, mitigation and reporting of risks and to ensure a high quality of risk management and control in all areas.

The CCLA Board has established several committees to oversee the control functions within the business. An Audit Committee has been established which meets twice a year and is tasked with oversight of CCLA’s control environment. An Executive Committee has also been established who meet regularly and assess the key risks and how these are mitigated through senior management action. An Assurance Committee meets quarterly to review operational activity, compliance monitoring, internal audit and risk assessments.

2.2 Credit Risk

Credit risk is the exposure to loss arising from a counterparty’s failure to meet its contractual obligations, either because of business failure or intentional withholding of amounts due. CCLA’s main credit risk exposure is of custody and administration fees not being collectable, and cash held with banks. Management fees are taken from the client’s accounts and therefore non-payment does not represent a material risk.

A minimal amount of income is derived from invoiced services, primarily generated through financial assessment advice and hiring of facilities, where the credit risk is not material.

CCLA’s principal financial assets, and therefore its primary source of credit risk, are its cash balances. Credit risk occurs through exposure to default of institutional counterparties. This is mitigated by CCLA spreading its cash across several high-quality institutions with high credit ratings which are regularly reviewed. Market transactions are restricted to investments in short-term cash deposits, executed with a deposit fund managed by CCLA. Credit risk exposure is monitored through monthly reports to the Executive Committee which include details of cash amounts placed with counterparties.

CCLA does not have a history of bad debt with suppliers and does not consider such risk material.

2.3 Market Risk

Market risk is the risk that the value of, or income arising from, CCLA’s business activities varies as a result of fluctuations in stock markets, interest rates or exchange rates. Market fluctuations can, however, affect client activity and Assets Under Management (AUM). CCLA’s fee income is directly affected by market movement due to levying fees as a percentage of AUM.  Consequently, market risk is considered to have the greatest potential impact on CCLA’s performance; however, the product range offered is well diversified, therefore maintaining a steady revenue stream.

CCLA does not trade on its own account so exposure to market position risk is limited.

2.4 Liquidity Risk

Liquidity risk is the risk that CCLA cannot meet its liabilities as they fall due. Liquidity requirements arise from day-to-day financial activities including accounts payable and payroll. Cash forecasting is used to minimise cash volatility, while CCLA also retains a substantial cash balance. CCLA’s policy is to ensure that it has liquid cash resources which exceed its capital requirements.

Financial instruments held by CCLA consist of short-term sterling cash deposits designed to ensure that, along with cash held in bank accounts, CCLA has sufficient available funds to meet operational needs. CCLA is confident of settling transactions and being able to continue operations in all foreseeable circumstances.

CCLA utilises strategies and policies to assess and maintain the amounts, types and distribution of liquidity resources required to cover the liquidity risks it is exposed to and the risk that it cannot meet its liabilities as they fall due.

2.5 Operational Risk

Operational risk is the risk of a loss resulting from inadequate or failed internal processes, people and systems or from external events, including legal and regulatory risk. CCLA seeks to mitigate its operational risks to acceptable levels, in accordance with its risk appetite, by maintaining a strong control environment, operating robust policies and procedures throughout the company, ensuring that employees have appropriate skills, competence and training, and by establishing an effective management structure. CCLA carries professional indemnity insurance in excess of the minimum FCA requirement.

CCLA is exposed to a number of operational risks, including:

  • Conduct and regulatory risk;
  • Third-party service provider risk;
  • Information security risk;
  • Fraud risk;
  • Technology risk;
  • Process risk.

A periodic assessment of all risks and controls throughout the business is carried out as part of the operational risk management process.

2.6 Leverage

CCLA does not have any leverage exposure.

2.7 Other Risks

2.7.1 Interest rates

Changes in interest rates do not materially affect CCLA’s earnings, which are primarily linked to performance of AUM and not interest income. Although CCLA does earn interest from the investment of surplus corporate cash, it does not rely on interest income to fund operations and does not have any material debt which would be affected by a change in interest rates. The present value of future cash flows or the underlying value of CCLA’s assets and liabilities would not be materially impacted by a change in interest rates (except in respect of defined benefit pensions, please see below). Any rise or fall in interest rates will affect profit margins but this is not considered to be critical to CCLA’s overall profitability. Therefore, CCLA does not consider interest rate risk to be material.

2.7.2 Pension obligations

CCLA IM, as the employing entity for CCLA, operates defined contribution pension schemes for employees, mainly through the Church of England Pension Builder 2014 Scheme and the CCLA Personal Pension Scheme operated by Legal and General. CCLA IM also has a share of assets and liabilities in the Church of England Defined Benefit Scheme (“DBS”). Action was taken by CCLA to mitigate future exposure to pension risk by closing the DBS to future accrual for all employees from 1st October 2012. The DBS is a multi-employer scheme, for which sufficient information to follow defined benefit pension scheme accounting is not available; accordingly, the net assets or liabilities of the DBS are not required to be shown on CCLA IM’s balance sheet. The DBS is reviewed triennially by an independent actuary to determine if any deficit exists which requires further funding by participating employers. If so, any deficit requiring funding by CCLA IM is recognised in full in CCLA IM’s accounts on production of the actuary’s report.

3. Capital Resources

CCLA’s capital resources are primarily constituted of share capital and retained earnings and therefore are a high quality of capital resource, referred to as Tier 1 capital

FCA Capital Resources

(Consolidated Basis)

As at 31st March 2019

(£’000s)

Ordinary Share Capital

242

Ordinary Share Premium

1,594

Audited Reserves - P&L

25,553

Audited Reserves – Other

1,724

Core Tier 1 Capital (Unadjusted)

29,113

Adjustment for Capitalised IT Software

(1,195)

Total Capital After Deductions

27,918

3.1 Own Funds

As a CPMI Firm and an IFPRU Limited Licence Firm, CCLA IM must maintain, at all times, capital resources equal to or in excess of the base own funds requirement of €125,000.

As a CPM Firm, CCLA FM must maintain, at all times, capital resources equal to or in excess of the base own funds requirement of €125,000.

4. Capital Adequacy

4.1 Individual Capital Adequacy Assessment Process

CCLA’s overall approach to assessing the adequacy of its internal capital is set out in its ICAAP. The ICAAP is an integral part of CCLA’s risk management framework and is reviewed and updated at least annually. In the preparation of its ICAAP, CCLA considers the risks identified in its risk management policy and quantifies the level of capital it needs to cover those risks. CCLA also considers the future plans of the business to determine the impact that any future development or growth of the business might have on the levels of capital it needs to hold. Projections for stress testing, wind-up scenarios and capital planning forecasts are produced and the liquidity impact of the results is assessed.

The major risks to the business were agreed by the Executive Committee and the ICAAP was subsequently formally challenged and approved by the Audit Committee on 8th July 2019 and adopted by the CCLA Board on the same date.

CCLA’s Pillar Two capital requirement as at 31st March 2019 was £3,073,000. In accordance with FCA requirements, CCLA holds sufficient capital resources to cover its Pillar Two capital requirement.

4.2 Capital Requirements

As at 31 March 2019, after audit, the internal capital to be held against CCLA’s Pillar 1 requirement has been calculated as £6,038,000, which represents the Variable Capital Own Funds Requirement (as defined in the FCA’s rules). The Pillar 2 capital requirement has been calculated as £3,073,000.

CCLA’s minimum internal capital requirement is £6,038,000 as the greater of the two.

As at 31 March 2019, after audit, CCLA held, on a consolidated basis, Tier 1 Capital of £27,918,000. Taking account of the capital resource requirement above, there is a surplus of £21,880,000. The CCLA Board therefore considers there is sufficient capital to ensure CCLA can continue to meet its requirements.

5. Remuneration Disclosures

The objective of the FCA’s Remuneration Codes is to ensure that all regulated firms have risk-focussed remuneration policies which are consistent with and promote effective risk management and do not expose the firms to excessive risk. Firms are expected to have robust governance arrangements in place, have established remuneration controls for employees whose professional activities could have a material impact on the firm’s risk profile and disclose relevant information about their remuneration policies and practices.

In accordance with the remuneration disclosure requirements of the CRR, and as further elaborated in the FCA’s ‘General Guidance on Proportionality: The Remuneration Code & Pillar 3 Disclosures on Remuneration’, CCLA IM, as the employing entity, falls within proportionality level 3 and is required to provide the following disclosures in relation to its remuneration policy and practices for staff whose professional activities have a material impact on CCLA’s risk profile.

CCLA IM has established a remuneration policy and a remuneration committee in accordance with the FCA’s Remuneration Codes. The committee is chaired by CCLA IM’s Chairman and is responsible for establishing, implementing and maintaining remuneration policies, procedures and practices that are consistent with and promote sound and effective risk management. In particular, the committee is responsible for ensuring CCLA IM’s compliance with the UK FCA’s Remuneration Codes, as well as compliance with other applicable laws and regulations. To aid in the process, market data on remuneration levels is also received from an independent source.

CCLA IM uses a combination of fixed and variable compensation. The variable element takes into consideration individual performance, performance of the individual’s business unit and CCLA’s overall performance. A performance review is conducted and documented, at least annually, measuring performance against agreed objectives, whilst also considering the employee’s promotion of sound and effective risk management where appropriate.

Those staff members whose professional activities have a material impact on CCLA’s risk profile are classified by CCLA IM as ‘Code Staff’ in respect to the FCA’s Remuneration Codes. During the financial year ended 31 March 2019, the aggregate remuneration of CCLA IM’s Code Staff was £2,841,000. There are no Code Staff in fee or commission earning roles.

 

October 2019

Terms and conditions

Website terms of use policy

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for the CCLA Funds; and
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions (Terms of Use or Terms) on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them.  Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these Terms you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time by updating this page.  We therefore recommend that you check this page periodically to ensure that you understand the Terms which will apply from time to time.

1. About us (CCLA)

1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281.

1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707.

1.4 CCLA FM is a wholly owned subsidiary of CCLA IM. The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing clientservices@ccla.co.uk.

1.5 These Terms apply to the websites for the CCLA Funds. The CCLA Funds are the CBF Funds, the COIF Funds and the Local Authority Funds.

2. The CBF Funds

2.1 The CBF Funds are:

  • CBF Church of England Deposit Fund.

  • CBF Church of England Fixed Interest Securities Fund;

  • CBF Church of England Global Equity Income Fund;

  • CBF Church of England Investment Fund;

  • CBF Church of England Property Fund and;

  • CBF Church of England UK Equity Fund;

2.2 The CBF Funds are established under the Church Funds Investment Measure 1958 and the Trustee Act 2000.The CBF Funds are neither a collective investment scheme (CIS) nor an unregulated CIS for the purposes of FSMA.

2.3 The trustee and operator of the CBF Funds is CBF Funds Trustee Limited (CBFFT), a company limited by guarantee registered in England and Wales with company number 5957490.CBFFT is a charity registered with the Charity Commission of England and Wales under charity number 1116932.

2.4 CBFFT has delegated the investment management, administration, registrar and secretarial functions of the CBF Funds to CCLA IM.

2.5 CBFFT has appointed HSBC Bank plc to oversees its activities in relation to the management and administration of the CBF Funds and to act as custodian in respect of the CBF Funds. HSBC Bank plc is a company incorporated in England and Wales with company number 14259.

The COIF Funds

3.1 The COIF Funds are:

  • COIF Charities Deposit Fund.

  • COIF Charities Ethical Investment Fund;

  • COIF Charities Fixed Interest Fund;

  • COIF Charities Global Equity Income Fund;

  • COIF Charities Investment Fund and;

  • COIF Charities Property Fund;

3.2 The COIF Funds are established under the Charities Act 1993 (now Charities Act 2011).Each COIF Fund is an unregulated CIS for the purposes of FSMA and an alternative investment fund (AIF) for the purposes of the Alternative Investment Fund Managers Directive (Directive 2011/61/EU) (AIFMD).The COIF Funds are also charities registered with the Charity Commission of England and Wales.

3.3 The Manager of the COIF Funds is CCLA FM.CCLA FM has delegated the investment management of the COIF Funds to the Investment Manager, CCLA IM.

3.4 The corporate trustee of the COIF Funds is HSBC Bank plc (company number 14259), which also acts as custodian. HSBC Bank plc is the depositary for the purposes of AIFMD.

4. The Local Authority Funds

4.1 The Local Authority Funds are:

  • The Diversified Income Fund (DIF).

  • The Local Authorities' Property Fund (LAPF and);

  • The Public Sector Deposit Fund (PSDF);

4.2 DIF is a sub-fund of the CCLA Authorised Contractual Scheme, an umbrella non-UCITS retail scheme and authorised contractual scheme (ACS) entered on the Financial Services Register under product reference number 757825. The ACS Manager is CCLA FM which has delegated the investment management function to CCLA IM. The depositary and custodian is HSBC Bank plc (company number 14259).

4.3 LAPF is established under the Trustee Investments Act 1961, and is an unregulated CIS and an AIF for the purposes of AIFMD. The Manager of the LAPF is CCLA FM, which has delegated the investment management function to CCLA IM. The trustee of LAPF is The Local Authorities' Mutual Investment Trust (company number 700132). Investment in the Fund is for Eligible Local Authorities who are Professional Investors only.

4.4 PSDF is a sub-fund of the CCLA Public Sector Investment Fund (PSIF), an umbrella UCITS fund incorporated under the Open-Ended Investment Company Regulations 2001 (SI 2001/1228) in England and Wales and registered with company number IC000839. PSIF is entered on the Financial Services Register under product reference number 527266.PSIF is an umbrella type investment company and a qualifying money market fund (QMMF) (see Term 7.3 below).The authorised corporate director of PSIF is CCLA IM and the depositary is HSBC Bank plc (company number 14259).

5. Who may use this website

5.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors).

  • Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland.

  • Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003.

5.2 Please ensure that you understand whether or not you are an eligible investor in respect of the Funds, investments and investment services referred to on this website.

6. The purpose of this website

6.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice.

6.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

6.3 In using this website you may navigate between different pages which relate to different Funds. Each webpage will clearly identify the Fund to which it relates and bespoke information presented on each webpage will relate to the identified Fund.

7. Risk warning

7.1 The value of the Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

7.2 Please refer to the Funds’ individual scheme particulars or prospectus for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

7.3 In particular, investors and potential investors should be aware that PSDF is a QMMF.PSDF only invests with high quality issuers at a high level of diversification while maintaining a low weight average maturity. These factors mean that PSDF maintains a low level of overall risk. However, a purchase of shares in the PSDF is not the same as making a deposit with a bank or other deposit taking body. The value of the share is not insured or guaranteed and there can be no assurance that a stable net asset value per share is guaranteed. Please refer to the PSIF prospectus for full risk warnings.

7.4 Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision.

8. Complaints and compensation

8.1 We are covered by the Financial Ombudsman Service (FOS) which is an independent service for settling disputes between financial services firms and their clients. The FOS is available to consider complaints from most clients if they cannot be settled through our own complaints procedures. There are certain rules as to eligibility and timing requirements laid down by the FOS which must be complied with.

8.2 PSDF and DIF are authorised funds as set out at Term 4 above. Investments and deposits in PSDF and DIF are therefore covered by the Financial Services Compensation Scheme (FSCS).There are limits on who can claim and the amount of compensation available. Further information about FSCS is available at www.fscs.org.uk.

8.3 The COIF Funds, the CBF Funds and LAPF are not authorised funds and therefore investments and deposits in these Funds are not covered by FSCS. However, unitholders and/or shareholders may be eligible for compensation under the FSCS if CCLA cannot meet its obligations. There are limits on who can claim and the amount of compensation available. Further information about FSCS is available at www.fscs.org.uk.

9. CCLA's liability

9.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA.

9.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

9.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access and we will do our best to protect your information (including personal data). However, we accept no liability in the unlikely event of a breach of our secure computer servers.

9.4 We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website. We will not be liable for any viruses, code, files or programs designed to interrupt, restrict, destroy or otherwise compromise the integrity of the website or any hardware on which it is hosted. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

10. Third party websites

10.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. You will be responsible for complying with the terms and conditions of use for any linked website.

11. Copyright and trade marks

11.1 CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

11.2 You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

11.3 No use of CCLA's name, logos and/or other trademarks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

12. Data protection

12.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes.

12.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you (you may inform CCLA at any time if you do not want to receive such communications); and (vii) as otherwise agreed by you. Failure to provide the personal data requested (or to agree to the above or below uses) may mean that CCLA is unable to provide the services requested.

12.3 CCLA may pass your personal data to any other firm within CCLA but will not pass on any personal data to any other third party except: (i) where, in relation to the performance of its services to you, CCLA sub-contracts part of the services or any support services; (ii) as agreed by you; or (iii) where required to do so for regulatory purposes as set out above.

12.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK and EEA in countries that do not provide the same level of data protection as the UK. In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner.

12.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years.

12.6 By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

12.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request.

13. Cookies

13.1 This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

13.2 When you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

13.3 You can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

13.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit www.allaboutcookies.org.

14. General

14.1 Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

14.2 If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

14.3 These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use.

[MAY 2018]

 

Public sector funds

Public sector funds

I confirm that I have read and accepted the terms of this website and that I am a local authority/public sector client as defined in section 23 of the Local Government Act 2003.