This Privacy Notice (this Notice) is intended to ensure that you are aware of what personal data Attestor Limited (Attestor, we, us, our) with a registered address at 7 Seymour Street, London W1H 7JW holds in relation to you, and how we use that data as data controller.
For the purposes of this Notice, Group Company means a company which is a Subsidiary or Holding Company of Attestor or any Subsidiary of such Holding Company from time to time (and for this purpose Subsidiary and Holding Company have the meanings given to them respectively in section 1159 of the Companies Act 2006); and/or any funds managed by Attestor and any Subsidiary or Holding Company thereof.
Please read the following carefully to understand our use of your personal data.
This Notice applies to all external third party individuals with whom we deal in connection with our business.
It applies to all personal data collected, maintained, transmitted, stored, retained, or otherwise used (i.e. processed) by us regardless of the media on which that personal data is stored. We may update this Notice at any time and, if we do, we will post an updated copy of this Notice on our website.
What is Personal Data?
"Personal Data" is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information.
We only hold personal data about you if you are:
- a client, the representative of a client, or the beneficial owner of a client;
- your information is in documents or correspondence obtained by us in the ordinary course of business;
- you provide services to us, or you represent an organisation that provides services to us;
- you represent a regulator or government body that has dealings with us;
- you contact us for any reason; or
- you visit our premises or website.
The types of personal data we might hold about you include:
- contact information relating to you including your name, business or other address, contact details, including email address and telephone numbers
- your job title and position within the organisation within which you work;
Attestor collects this information in a variety of ways. For example, data might be collected through communications between us and you/the organisation for whom you work, or when you provide us with contact information.
Data will be stored in a range of different places, including in our IT systems.
Purpose and Basis for Processing
Attestor needs to process data to perform our contractual and legal obligations with the organisation for whom you work and pursuing our (or another Group Company’s) legitimate interests in the context of a customer/service provider relationship (in particular to provide the services that we (or another Group Company) have agreed to provide to the organisation for whom you work), for our (or another Group Company’s) marketing purposes or to comply with applicable legislation.
We may, from time to time ask for your consent to use your personal data for a specific purpose. You have the right to withdraw your consent to that processing at any time. This can be done through the means that we provide for you, or by emailing us at Jodie.Blenkharn@attestorcapital.com.
Attestor does not use any automated decision-making or automated profiling in relation to personal data that we process.
Where you do not provide us with your Personal Data
If you do not provide us with your personal data we may not be able to provide the organisation for whom you work with some or all of the services which we have agreed to provide.
Security and Storage of Personal Data
We securely store your personal data in a centralised database, with controlled access to such database. Access to personal data in both electronic and paper form is restricted to employees who have a legitimate and justifiable reason to view such data, such as personnel in the information technology, legal, finance, regulatory and compliance and accounting departments.
Recipients of Your Personal Data
We may disclose your personal data to a Group Company for the following reasons: in order for other Group Companies to provide services to the organisation for whom you work, to run global processes, carry out group-wide reporting or for marketing purposes.
It may be necessary from time to time for us to disclose personal data to the following third parties or agents:
- regulatory bodies to whom we are obliged or required to disclose information including the Financial Conduct Authority (FCA)or other regulatory authorities and the courts;
- legal practitioners;
- potential purchasers or bidders;
- relevant government departments and agencies; and
- other support service providers necessary to assist Attestor with the above.
We will inform you in advance if we intend to further process or disclose your personal data for a purpose other than the purposes set out above. We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied.
Transfer of Personal Data outside the UK
The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK, for the purposes described above. Due to the global nature of our business, your personal data may be disclosed to Group Companies outside the UK. It may also be processed by personnel operating outside the UK who work for us or for one of our suppliers who act on our behalf. We will ensure appropriate safeguards are in place to protect the privacy and integrity of your personal data in such circumstances.
If you would like further details of how your personal information is protected when transferred from one country to another then please email us at Jodie.Blenkharn@attestorcapital.com.
Your data will be stored and retained to the extent necessary to enable Attestor to comply with any legal obligations or for the exercise or defence of legal claims. Our retention practices are reviewed and updated from time to time in line with legal requirements and best practice. In summary, our current practices are:
- as a general principle, we intend to hold your personal data for a period of 6 years from the date on which we acquire such personal data from you;
- details necessary to respond to FCA enquiries will be held for 7 years; and
- data required by HMRC will be held for 7 years from the end of the tax year.
Your Data Protection Rights
You have several rights in relation to your personal data. You have a right to:
- access a copy of your personal data held by Attestor on request;
- request rectification of your personal data if it is inaccurate or incomplete;
- request deletion of your personal data;
- restrict our processing of your personal data;
- move (or port) personal data which is automated;
- object to the processing of your data where our legal basis for processing your data is our legitimate interests; and
- not to be subject to a decision based on automated processing, including profiling which has legal or similar significant effects.
Please note that some of these rights might be subject to limitations or exceptions.
If you would like to exercise any of your data protection rights, please contact Jodie Blenkharn at Jodie.Blenkharn@attestorcapital.com. You are not required to pay any charge for exercising your rights. We will respond to your request as soon as practicable and in any event not more than one month after receipt of your request. We may request proof of identification to verify your request.
If you believe that Attestor has not complied with your data protection rights, you can lodge a complaint with the Information Commissioner’s Office (ICO). The ICO’s address is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. The ICO's helpline number is: 0303 123 1113. The ICO's website is at: https://www.ico.org.uk.
If you require any further clarification regarding this Notice, please contact Jodie Blenkharn or Jessica Tuck, who may be contacted at Jodie.Blenkharn@attestorcapital.com / Jessica.Tuck@attestorcapital.com.