This privacy notice sets out the basis on which any personal information we collect about you or you provide to us will be used by us.
CCLA Investment Management Limited and/or CCLA Fund Managers Limited (together, ‘CCLA’, ‘us’, ‘we’, ‘our’) will be the Data Controller of the personal data you provide to us. CCLA Investment Management Limited will be the Data Controller whenever CCLA Investment Management Limited provides investment management, fund management and fund administration services to you and CCLA Fund Managers Limited will be the Data Controller whenever CCLA Fund Managers Limited provides fund management services to you. Each of those CCLA companies is an independent Data Controller registered with the Information Commissioner’s Office (under registration numbers Z4866812 and ZA069296).
How we collect your personal information
Information you provide to us – you may provide us with personal information when you meet with us to discuss our services, or afterwards if you receive our services, and/or when you are corresponding with us by post, telephone, email or otherwise.
We will typically only collect basic personal information from you which will include, for example, your name, postal address, email address, telephone number, banking details, passport and/or driving licence details (for identification purposes, as required by our regulator, the Financial Conduct Authority (FCA).
Information from other sources
We may also receive information about you from external sources when we carry out anti-money laundering (AML) and other background checks from other professional organisations. For example, we receive credit history and other AML information from Experian Limited.
The purposes for which we use your personal information.
We need to process your personal data to:
provide you with the products and services detailed in your contract (as is necessary for the performance of that contract)
comply with any legal or regulatory requirement or request in the UK or elsewhere and to fulfil our obligations under any tax reporting requirement
confirm your identity and carry out background checks, including as part of our checks to prevent fraud and other crimes (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests). When we use credit reference agencies to do this, the agency may record that a search has been made
prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights (as is necessary for our legitimate interests)
to communicate with you, including to provide you with information about other products and services we offer that are similar to those that you have already engaged us to provide or enquired about, provided that you have not told us that you do not wish to receive this information (as is necessary for our legitimate interests in promoting and growing our business and, in respect of contacting you for marketing purposes, where we have your consent).
Use of your personal information for marketing purposes
Unless you object to this, we will use your name and email address to inform you about CCLA’s products and services which are similar to those you have already received or shown interest in. This information is not shared with third parties and you can unsubscribe at any time via phone, email or online.
How we keep your personal information secure (including when it is transferred outside the UK)
All the personal data held by or on behalf of CCLA is processed and held on servers located in the UK. CCLA takes all appropriate technical and organisational measures to ensure the effective and secure processing of your personal data. Where we use third parties to process information on our behalf, we ensure that there are robust agreements in place to provide the same data security standards that we have at CCLA – and that there is a suitable lawful basis for any transfer of personal information outside the UK. You can obtain more details of the protection given to your personal information (including when it is transferred overseas) by contacting CCLA’s Data Protection Adviser using the contact details below.
Who we share your personal information with
We may share your personal information with third-party agents and contractors as detailed below:
with those who provide administrative and operational services to us (for example HSBC and FNZ)
in order to verify your identity in accordance with UK money laundering requirements. This may include credit reference agencies
where we are required to do so by law, regulation or a court order
with fraud and law enforcement agencies if you give us false or inaccurate information, we suspect a fraud or you have made us aware that you suspect fraud
- with HMRC or other tax or revenue authorities or the FCA.
What are your privacy rights?
You have a number of rights in respect of your personal information under UK data protection laws, including the right:
to request access to, and copies of, the personal information that we hold about you
to require us to correct the personal information we hold about you if it is incorrect
to require us to erase your personal information, in certain circumstances
to require us to restrict our data processing activities, in certain circumstances
where our processing is based on your consent, the right to withdraw that consent (without affecting the lawfulness of our processing based on consent before its withdrawal)
where the processing is carried out by automated means, to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you (including for the purpose of you transmitting that personal information to another data controller)
to object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights.
Please note that these rights are not absolute and we may be entitled or obliged to refuse requests where exceptions apply. If you wish to exercise any of these rights, please contact us using the contact details below.
How long we keep your personal information
If you are a customer, we are required under UK law to keep your basic personal data (name, address, contact details) for a minimum of seven years after the end of our relationship with you, at which time it will be destroyed. If you have given us permission to hold your contact details for marketing purposes, it will be kept until you notify us that you no longer wish to receive marketing information from us.
Questions and complaints
If you wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Adviser who will investigate the matter.
If you are not satisfied with our response or if you believe we are processing your personal data unfairly or unlawfully, you can complain to the Information Commissioner’s Office. The ICO’s contact details are available online at https://ico.org.uk.
Our Data Protection Adviser is Jackie Fox and you can contact her by email at: firstname.lastname@example.org or by post:
CCLA (attention of Jackie Fox)
One Angel Lane
Approved by the directors of CCLA Investment Management Limited on 17 January 2023 and by the directors of CCLA Fund Managers Limited on 17 January 2023.
See our other policies
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