Asset Investment Management Ltd - Data Protection – Privacy Statement May 2018
We confirm that, when processing data on your behalf, we will comply with the relevant provisions of the Data Protection Act 1998 and the General Data Protection Regulation (GDPR - Regulation (EU) 2016/679)
Your personal information is very important to us. We will endeavour to take all due care to protect this information. We would like to highlight certain points relating to your information that you should be aware of. Some services are provided to Asset Investment Management Limited by third parties (such as processing business or obtaining compliance or regulatory advice), which warrant the disclosure of more than just your basic contact details. You agree that personal information held by Asset Investment Management Limited may be disclosed on a confidential basis, and in accordance with the Data Protection Act 1998, to any such third parties. You also agree that this information may be transferred electronically, e.g. by email and you agree that Asset Investment Management Limited, or any such third party, may contact you in future by any means of communication which we consider appropriate at the time.
To enable us to provide the services we have agreed and for other related purposes – including updating and enhancing customer records, analysis for management purposes and statutory returns, crime prevention and legal & regulatory compliance – we may obtain, use, process and disclose personal data about you.
In the EU’s General Data Protection Regulation (GDPR), Personal Data is defined as “…any information relating to an identified or identifiable natural person ("data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.”
How we use your information
· We will collect information from you that we feel is necessary for us to provide a comprehensive financial planning and investment service to you. You may decline to give all information in which case the outcome could be less than optimal; in such cases we will almost certainly choose not to act for you at all.
· Information will be stored both on paper copies and electronically. We will retain such data as is necessary to support the basis for any investment recommendations made. If you do not want us to make recommendations then you can ask for us to remove your data from our systems and destroy any paper copies.
· After recommendations have been made and taken up by you we must keep copies of all correspondence for an indefinite period as we may be required to answer a complaint at any time in the future.
Why do we need to collect and store personal data?
In order for us to do any of the above, we must collect and store your data firstly for correspondence purposes. We will ensure that the information collected will only be used for its intended purpose and does not constitute an invasion of your privacy. Asset Investment Management Ltd may wish to contact you for marketing purposes, however we would contact you for additional consent for that purpose if not already given.
Will we share your personal data with anyone else?
Product Providers and Investment Management companies may administer policies and plans you have with them and provide other services, from locations in countries outside Europe that do not always have the same standard of Data Protection laws as the UK. However, they are required to put controls in place to ensure that your information is adequately protected and they undertake to be bound by the obligations under the Data Protection Act even when your personal information is processed outside Europe.
We may need to pass your details onto third parties who provide investment services as Asset Investment Management Ltd act solely as an intermediary and financial adviser, not as a product provider.
Any third parties who we do pass your details onto are obliged to store your details securely and only process them if responding to implementation of investment or financial planning on our behalf. When the time comes that they no longer require your personal data, they will dispose of this accordingly and in line with our company policy. If we wish to pass your personal data to a third party, we will only do so with your explicit consent (e.g. you have signed an application form for services from a third party) unless we are legally obliged to do so otherwise.
How will we use the personal data we collect about you?
Processing data constitutes as collecting, storing and using. We will process this data in accordance with the GDPR. We will do our utmost to keep your information accurate and up to date and not keep it longer than is necessary. Asset Investment Management Ltd may issue occasional reminders to all customers to keep their contact details up to date and will update them accordingly.
Please be advised that there is information that we are required to keep in accordance with the law, such as information needed for tax and audit purposes. Personal data may be held for longer than these periods, however this will depend on the individual needs of the company.
Under what circumstances will we contact you?
We will only contact you when necessary, or when you have requested that we do so. We do not mean at any point to be intrusive or ask for unnecessary information. We will do our best to ensure that the information we hold is as secure as possible to minimise the risk of unauthorised access or disclosure.
Can you find out about the personal data that we hold about you?
If you want to see what personal data we hold on you and how it is processed, you may contact us to request this. This is known as a Data Subject Access Request (DSAR) and you must request this in writing (either by post or email), providing the necessary identification before any information is released. If Asset Investment Management Ltd do store any of your personal data, you may request information on the following:
· Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
· Contact details of the GDPR owner, where applicable.
· The purpose of the processing as well as the legal basis for processing.
· If the processing is based on the legitimate interests of Asset Investment Management Ltd or a third party, information about those interests.
· The categories of personal data collected, stored and processed.
· Recipient(s) or categories of recipients that the data is/will be disclosed to.
· If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
· How long the data will be stored.
· Details of your rights to correct, erase, restrict or object to such processing.
· Information about your right to withdraw consent at any time.
· How to lodge a complaint with the supervisory authority.
· Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
· The source of personal data if it wasn’t collected directly from you.
· Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will you need to provide in order to access this?
Asset Investment Management Ltd will accept the following forms of ID when information on your personal data is requested:-
Passport; Photo Driving Licence; Utility Bill (from the last three months).
Contact details of the GDPR Owner
If you wish to submit a DSAR, or have any questions regarding this privacy statement, you must do so in writing using the following information.
Asset Investment Management Ltd
Drayton Old Lodge