LSPIM is committed to protecting your personal information when you use our services. This notice explains how we collect, retain and process your personal information. Here we set out how the personal information that we collect about you will be used.
For the purposes of data protection legislation, LSPIM is a “controller” meaning that we determine the purpose and means of processing the information we collect from you. If you have any questions concerning LSPIM’s data privacy procedures please contact Rachel Christie at email@example.com.
If you ever have any questions, comments or complaints about this notice, or any of its contents, please contact us via any of the following means and we will be pleased to assist you:
By Post: 349 Bath Street, Glasgow G2 4AA
By Email: firstname.lastname@example.org
By Phone: 0141 248 4155
INFORMATION THAT WE COLLECT
This section details the types of information we collect from you and how we use information about you.
- Information that you provide to us from time to time including through our website, email or post.
- If you contact us by any means, we will keep a record of that correspondence and information that you provide to us in that correspondence.
- Information that you provide when completing surveys or similar research activities, although you do not have to take part in such activities.
- Details of your visits to our website, please see section on Internet Cookies for details.
HOW WE USE YOUR INFORMATION
General uses of information
We use information supplied by you:
- to provide you with email updates and alerts as requested by you;
- to improve the services that we offer;
- to respond to your queries;
- to notify you about any changes to our services and/or our website;
- to comply with legal and regulatory requirements that apply to us; and
- for general statistical analysis.
In terms of the legal bases we rely on to process your information, these are where the processing is necessary:
for the performance of a contract with you for provision of services or to take steps at your request prior to entering into any contract; to comply with our legal obligations; for our legitimate interests in:
- ensuring the quality of the services we provide to you;
- collecting information for marketing purposes;
- communicating with you; and
- statistical analysis; or
- where you have consented to such use.
If you do choose to provide your consent you can withdraw it at any time by contacting us at the above-mentioned email address.
SHARING YOUR INFORMATION
We will not pass your information on to third parties except: we will provide your information to our service providers to allow them to assist us with carrying on and conducting our business functions.
We will provide your information to the following categories of recipients:
- payroll administrators
- company secretary
- asset manager
- investment manager
- information technology and information security providers
- law enforcement agencies and regulators where we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation, or if we reasonably consider that this is necessary to help prevent or detect fraud or other crime or to protect the rights, property, or safety of us, our customers or others;
if we are under a duty to disclose or share your information with HM Revenue & Customs (HMRC) or such government bodies, who may transfer it to the government or the tax authorities in another country where you may be subject to tax; if we (or all or part of our assets) were to be acquired by a third party; if you have consented to any disclosure to a third party.
Our website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please check their privacy notices.
WHERE WE STORE AND USE YOUR INFORMATION
We transfer, use and/or store your personal information outside of the European Economic Area (EEA) and the laws of some of these destination countries may not offer the same standard of protection for personal information as in the UK.
We currently transfer data to the following countries outside of the EEA:
USA, India. We may update this list from time to time and any changes will be communicated to you via an update to this privacy notice.
Transfers to our third-party service providers are to enable them use and store your personal information on our behalf. We will, however, put in place appropriate security procedures in order to protect your personal information. We also ensure that, where your information is transferred to any country outside the EEA this is done using specific legally approved safeguards. You can request further details and a copy of these by contacting us at the above-mentioned email address.
KEEPING YOUR INFORMATION
We will keep your information only for as long as necessary depending on the purpose for which it was provided. Details of retention periods for different aspects of your personal information are available in our retention policy which is available by contacting us at the above stated email address.
When determining the relevant retention periods, we will take into account factors including:
legal obligations under applicable law to retain data for a certain period of time statute of limitations under applicable law(s) (potential) disputes, and
your continued desire to receive communications from us and our ongoing relationship; guidelines issued by relevant supervisory authorities.
We have put in place measures to protect the security of your information. These measures are intended to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Unfortunately, the transmission of information via email is not secure. Therefore, if you use email for communicating with us, we cannot guarantee that it will remain confidential whilst in transit.
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights.
Your rights in connection with personal information.
Under certain circumstances, by law you have the right to:
- Object to the processing of your personal information where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see above).
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party in a machine-readable, commonly used and structured format.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us in writing.
The various rights are not absolute and each is subject to certain exceptions or qualifications.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
In some cases, we may charge a reasonable fee if your request for access to your data is clearly unfounded or excessive, or if you request multiple copies of the information. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to complain
If you wish to request further information about any of the above rights, or if you are unhappy with how we have handled your information, contact us at the above contact details.
If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (“ICO”): https://ico.org.uk/global/contact-us/ 0303 123 1113.
CHANGES TO OUR PRIVACY NOTICE
We keep our privacy notice under regular review and any updates we make in the future will be posted on our website and the most recent version of this “Privacy Notice”. Where appropriate, changes may be notified to you by post or email.