Privacy policy

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 provides investment management services to you and CCLA Fund Managers Limited will be the Data Controller whenever CCLA 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, 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);

  • to comply with any court order, or request from or referral to an appropriate authority, including the FCA (as is necessary for compliance with our legal obligations); and

  • 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 on our website.

How we keep your personal information secure (including when it is transferred outside the EEA). All the personal data CCLA hold is processed by our UK based staff 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 for the purposes of providing services to us (for example, with HSBC as third-party administrators).

What are your privacy rights? You have a number of rights in respect of your personal information under UK and European 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); and

  • 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 six 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: jackie.fox@ccla.co.uk or by post:

CCLA (attn: Jackie Fox)
Senator House
85 Queen Victoria Street
London
EC4V 4ET

January 2021