Privacy Statement

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.

Introduction

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.

Background

The General Data Protection Regulation (GDPR) came into force with effect from Monday 28th 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.

What the new regulation means:

  • You now have greater control over your personal data
  • You can control who is permitted to contact you, how and what for
  • You can change your mind at any time
  • Data protection is enhanced with strong financial penalties for breaches of data security

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.

Use of personal data

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.

Examples of personal data collected by Alpha

  • We collect information about you when you enquire about or sign up to one of our services:
  • Your name, address, date of birth and contact details
  • Other people e.g. joint applicants or beneficiaries
  • Your bank details
  • Financial Position, status and history
  • Personal information on education, work, retirement plans, life ambitions
  • Financial responsibilities and dependents
  • National Identifiers e.g. HMRC reference, National Insurance number
  • Tax status
  • Documents in different formats or copies of them e.g. passport, bank statements
  • Special Types of data of a sensitive nature if relevant to Alpha’s services e.g. health matters where relevant to your planning and investment horizon and expectations
  • Contact details re meetings, phones calls, emails and letters
  • Via cookies when you visit our website
  • Transaction data
  • Children, e.g. where a child is named as a beneficiary on the account taken out by a parent or guardian on their behalf. In these cases, we will collect only the information required to identify the child (name, age and gender)

Sources of personal data

  • We may collect information directly from you and a variety of sources, including:
  • Alpha forms e.g. client application forms, Risk Profile Questionnaires for a service
  • Phone conversations with us
  • Emails or letters that you send to us
  • Meetings with a member of our team or your advisers
  • Our online services such as websites, including social media and mobile phone applications
  • Job applicants and our current and former employees
  • Please note that if you have a financial adviser, the adviser on your behalf could provide us you’re your personal information.

 

Disclosure of personal data

  • We may share your personal information with RCBIM and with a limited number of other organisations, where necessary to provide Alpha’s services to you and where required by regulation or law:
  • Agents and advisers who we use to help run your accounts and services, e.g. Pershing Securities for portfolio management clients
  • HM Revenue & Customs
  • Our regulators e.g. Financial Conduct Authority (FCA), and the Information Commissioner’s Office for the UK (ICO)
  • UK Financial Compensation Scheme
  • Law enforcement agencies, credit and identity check agencies for the prevention and detection of crime
  • Independent Financial Advisers
  • Organisations you ask us to share your data with
  • We never sell your details to other organisations or individuals. We will process your information lawfully and keep your information safe and secure.
  • We may also share your information if the corporate structure of business changes in the future, for example:
  • We may choose to sell, transfer or merge parts of our business, or our assets.

Processing personal data

  • All your information is processed within the UK, and the European Economic Area (EEA).
  • We will only send your data outside the EEA to:
    • Follow your instructions
    • Comply with legal requirements
    • Work with our agents and advisers used to provide our services to you
  • If the data is transferred outside the UK and the EEA it will only be to countries that provide equivalent data privacy laws or are part of international privacy standards organisations to enforce equivalent privacy standards e.g. the Privacy Shield framework between the EEA and USA.

 

Protection of personal data

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.

 

Personal data retention

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.

 

Your Rights

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.

Website

This privacy statement applies to the personal data held by Alpha and the Alpha website.

It does not cover links to other sites. Once you have accessed another website via one of our links you will be subject to the security and privacy policy of that site.

 

Telephone Calls

All telephone calls to and from Alpha are recorded, in accordance with regulatory requirements and the call records are subject to the requirements of this Privacy policy.

 

Compliance and privacy officer

Neil Whelan,
1 The Square,
Temple Quay,
Bristol BS1 6DG
Tel: 0117 203 3460
Email: info @ alpha-pm.co.uk

We will review and update our policy within the regulations in force, from time to time, continued access to our service indicates your agreement to any changes. If our privacy policy, we will place an updated version on this page of our website.

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