The purpose of this Data Protection Statement
When we provide our services to you, we will collect information about you and we want to be open and transparent with you as to the types of information we collect about you, why we collect it, how we use it and who we may share it with.
The data controller of your personal data is Cambridge Investments Limited which provides you with a Discretionary Management Model Portfolio Service. Cambridge Investments Limited is registered at Lancaster House, Ackhurst Business Park, Foxhole Road, Chorley, Lancashire PR7 1NY with company number 1370458 (“we”, or “us”, or “our”).
If you have any questions or concerns about the use of your personal data, then please contact us using the contact details provided in the ‘How to contact us’ section at the bottom of this Data Protection Statement.
What type of personal data will be processed and why?
We may ask you to provide personal data by filling in hard copy forms and documents or by corresponding with us by phone, e-mail, and letter or otherwise.
The personal data that we ask you to provide, and the reasons why we ask you to provide it, include:
|Types of personal data||Why we collect it|
Identity details including your name and date of birth.
We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address.
· To carry out money laundering and financial checks and for fraud and crime prevention and detection purposes.
· We will only ever use copies of identity documents for this purpose.
· We collect and process this personal data in order to comply with our legal and regulatory requirements.
|Your contact details including your name, postal and email address.||
· To contact you in order for us to manage, administer and provide our services to you.
· To respond to any correspondence and service-related enquiries you send to us in respect of our services.
· To discuss products or services for which you apply or may be interested in applying for.
· To manage any applications you make for products or services.
· To communicate any updates to you including any changes to our services, the terms and conditions of any services which we have provided to you, any changes to this Data Protection Statement and to our websites.
· To contact you in order to receive your feedback on our services and to participate in related surveys.
|Financial information relating to you, including pension contributions and current value, and details of investments.||
· To evaluate your eligibility for products.
· We collect and process this personal data in order to provide the services to you that you have requested and for our legitimate business interests.
· During our conversations with you about your financial aims and objectives, we are likely to discuss a variety of issues relating to your circumstances (for example your marital status, job title, investment goals and choices and your attitude to risk).
· We discuss this kind of information to enable us to provide you with personalised and accurate advice and to make recommendations that are suitable for your circumstances.
|Details of contact that we have had with you such as referrals and queries.||
· To allow us to provide a professional service to you and to contact you with information about other services of ours that we think you may be interested in.
· We collect and process this personal data for our legitimate business interests.
|Details of services you have received.|
|Customer experience and other feedback and information you provide to us.||
· To review your feedback and experience with us so that we can improve our products and services for you and for our other customers.
· We collect and process this personal data for our legitimate business interests (and we record calls both for quality and training purposes and to comply with our legal and regulatory obligations).
Please see section below entitled “When we record communications” for more information.
|Information about complaints and incidents.|
|Recordings of calls we receive or make.|
|All of the personal data described above.||
· We may disclose your personal data to carefully selected third party firms that we enter into a contract with to assist us in delivering our service to you.
· We may disclose your personal data to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a Court Order, regulatory authority or any other third party with the lawful right to request and receive the personal data we hold about you (including law enforcement agencies and tax authorities).
· We may also use your personal data where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties.
· We collect and process this personal data for our legitimate business interests.
We may obtain some information about you from third party sources, but only where we have checked that these third parties are legally permitted or required to disclose your personal data to us.
When we record communications
We, and persons acting on our behalf, may record and/or monitor communications (including telephone conversations over landlines and mobile phones, emails, instant messaging, chat rooms, fax and other electronic communications) between our staff and you. We only record communications between us in order to comply with our legal and regulatory requirements – as a discretionary portfolio manager, the law requires us to record these communications.
Who might my personal data be shared with?
We may disclose your personal data to the following categories of recipients:
- to providers of products and services in respect of whom you request us to submit applications on your behalf and to receive updates from such providers in order for us to provide our services to you throughout the lifetime of our relationship with you;
- to our suppliers and partners in order for them to help us provide our services to you, this includes;
- the provision, operation and management of portfolio management services on investment platforms.
- our IT systems, back office systems and paperless office systems providers to assist us with providing you with an efficient, modern and professional service; and
- suppliers of regulatory compliance support services who may review our records containing your personal data in order to audit and report to us on our compliance with applicable laws and regulatory requirements.
- to our parent company, which provides us with accountancy and compliance support and shared back-office services and which will only ever process your personal data for these purposes;
- to your Perspective Financial Adviser where they are better-placed to provide you with the required service (for example where you require advice). We will only transfer a copy of your file to that other member with your permission;
- to a prospective buyer (and its agents and advisers) in the event that our parent company intends to sell any part of its business or its assets or if substantially all of its assets are acquired by a third party, in which case your personal data could form part of one of the assets sold, provided that the buyer is informed that it must use your personal data only for the purposes described in this Data Protection Statement – neither we nor our Parent Company will ever rent or sell your personal data other than as part of a business sale;
- to any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary (i) as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC), (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests of those of any other person; and
- to any other person with your consent to the disclosure or where the law requires or permits us to do so.
Legal basis for processing personal data
Our legal basis for collecting and using your personal data will depend on the personal data concerned and the specific context in which we collect it. In respect of the personal data and the purposes for which we may process your personal data which are set out in this Data Protection Statement, we have confirmed the legal basis upon which we collect and process your personal data in the ‘What type of personal data will be processed and why?’ section above.
If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you or with your explicit consent, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
Similarly, if we collect and use your personal data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading below.
International Data Transfers
We will only process your personal data inside the European Economic Area.
Your data protection rights
You have the following data protection rights:
- If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
- In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your explicit consent, please see the “Your consent to us processing your special category personal data” heading below.
- You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We retain personal data we collect from you where we have an ongoing legitimate need to do so, for example:
- to provide you with a product or service you have requested us to provide,
- to perform our contractual obligations to you;
- to comply with applicable legal, tax or accounting requirements;
- to defend or manage any claims or complaints between us, you and any relevant third party including taking legal advice in respect of such claims in order to establish, exercise or defend our legal rights or such claims. This would include complaints and claims which you may bring against us or which are submitted to a court, regulatory authority or ombudsman.
When we have no ongoing legitimate need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
Updates to this Data Protection Statement
We may change or update this Data Protection Statement in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Data Protection Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
How to contact us
If you would like to contact us in relation to this Data Protection Statement or if you have any other questions in respect of our processing of your personal data, please contact The Data Protection Officer by telephone on 01223 365656 by email at email@example.com or by post at Cambridge Investments Limited, Nine Hills Road, Cambridge, CB2 1GE.
Communications about other products or services
We would like to contact you from time to time with details of offers, products, reminders and services which may be of interest to you. Please tick the relevant boxes below if you do not want to receive this information from us:
|Client 1||Tick||Client 2||Tick|
|by email||❒||by email||❒|
|by post||❒||by post||❒|
|by text message||❒||by text message||❒|
|by telephone||❒||by telephone||❒|