Alpha Portfolio Service Brochure
Our privacy statement explains what information we collect from you, how we use any information, who we may share it with and why, your rights about the information you have given to us and the way we protect your privacy.
Alpha Portfolio Management Ltd (Alpha) is committed to protecting your private information and we will keep your personal data confidential unless we are required to disclose it by law or regulation. Please note R C Brown Investment Management (RCBIM) acts as Data Controller and Data Processor for this information.
The General Data Protection Regulation (GDPR) comes into force on 25th May 2018 and is the most significant piece of European privacy legislation in the last twenty years. It is the most stringent data protection regulation in the world covering personal data. It strengthens the rights that EU individuals have over their data and, because it is a regulation not a directive, creates a more uniform data protection law across Europe. GDPR extends to the whole of the EU and will likely continue to apply in the UK beyond Brexit.
Personal data is any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Identifiers include a wide range of information, reference numbers, online information and includes electronic and hard copy information and automated and manual systems.
The law permits the use of personal data for restricted legal purposes as follows
a) Contractual – to fulfil our contract with you – it is necessary to provide the service you have requested
b) Legal Duty – to meet our legal or regulatory obligations e.g. under the Financial Services and Markets Act and the rules of the Financial Conduct Authority
c) Legitimate Interests – when Alpha has a business or commercial reason to use your information which does not unfairly use this information against your best interests
d) Consent – clear unambiguous and informed consent to holding your personal data
e) Vital Interest – to protect life
f) Public task
Alpha uses personal data, as permitted, under the legal bases a – c above to provide services and comply with regulatory requirements. This is to ensure you are fully informed of Alpha’s services and service developments.
If Alpha were to hold your personal data for other purposes, it will seek your affirmative consent in advance and give an explanation of why it wants to hold the information and for what specific purpose.
If you do not wish us to collect and use your personal information in this way, and inform us of your wishes, we will not use your personal data. However, it might mean that we will be unable to provide you with our services.
Alpha complies with our obligations in taking information and system security seriously at all times.
We have stringent controls in place to help protect personal data and to minimise loss or damage through accident, negligence of deliberate actions. Our employees receive annual training to help protect sensitive or confidential information.
Our security controls are in line with industry standards, alongside our own internal policies and procedures to effectively manage risks to the confidentiality, integrity and availability of your information.
We will keep your personal information for as long as you are a client of Alpha. After our relationship with you has ceased, we may keep your data for up to 7 years to meet our legal or regulatory obligations or if we have a technical issue.
Under GDPR, Data Subjects (i.e. you) have the following rights in relation to how Alpha uses your information. They are:
Right to be informed
o You have the right to be informed about the collection and use of your data, why and who we share it with – we do this in our Privacy Statement.
Right of access
o You have a right of access to your personal information, if you would like to receive a copy of the personal information we hold for you, you make a data subject access to our Privacy Officer – details below.
Right to rectification
o You have the right to have your personal data rectified if it is inaccurate or incomplete You can ask for your information to be deleted or removed if there is not a compelling reason for Alpha to continue to have it.
Right to restrict processing
o You have the right to request to block or suppress the processing of personal information for certain reasons. If your request meets the necessary conditions for restriction it means that we are still permitted to keep your personal data – but only to ensure that we don’t use it in the future for those reasons you have restricted.
Right to data portability
o You have the right to ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy to transfer the personal information we hold to another company in a safe and secure way. E.g. if you were moving your account to a different investment manager.
Right to object
o You have the right to object to Alpha processing your personal information where: it’s based on legitimate interest of the performance of a task in the public interest/exercise of official authority (including profiling), if we did direct marketing and if we were using scientific/historical research and statistics.
Rights related to automatic decision making including profiling
o Alpha does not currently use any automatic decision making or profiling processes.
This privacy statement applies to the personal data held by Alpha and the Alpha website.
1 The Square,
Bristol BS1 6DG
Tel: 0117 203 3460
Email: info @ alpha-pm.co.uk
© Alpha Portfolio Management 2018. All Rights Reserved
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