Privacy notice

This privacy notice sets out the basis on which we will use any personal information we collect about you, or you provide to us.

CCLA Investment Management Limited and/or CCLA Fund Managers Limited (together, ‘CCLA’, ‘us’, ‘we’, ‘our’) will be the Data Controller of the personal data you provide to us. CCLA Investment Management Limited will be the Data Controller whenever CCLA Investment Management Limited provides investment management, fund management and fund administration services to you and CCLA Fund Managers Limited will be the Data Controller whenever CCLA Fund Managers Limited provides fund management services to you. Each of those CCLA companies is an independent Data Controller registered with the Information Commissioner's Office (under registration numbers Z4866812 and ZA069296).

Our contact information 

Name: CCLA Investment Management
Address: 1 Angel Lane, London, EC4R 3AB
Phone number: 020 7849 6000
Email: clientservices@ccla.co.uk

What data do we process about you?

We may obtain or request personal data, including:

• Identity data (e.g. name and title)
• Verification data (e.g. passport)
• Contact data (e.g. address, email, telephone number)
• Location data (e.g. location ID when accessing our website)
• CCTV data (i.e. if you visit our offices)
• Call data (e.g. recordings of CCLA calls)
• Profile data (e.g. username and password)
• Marketing and communications data (e.g. advertising preferences)
• Technical data (e.g. login details, browser type, operating system)
• Survey responses (e.g. name and email)

The purposes for which we use your personal information

We need to process your personal data to: 

• provide you with the products and services detailed in your contract (as is necessary for the performance of that contract); 
• comply with any legal or regulatory requirement or request in the UK or elsewhere and to fulfil our obligations under any tax reporting requirement
• confirm your identity and carry out background checks, including as part of our checks to prevent fraud and other crimes (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate interests). When we use credit reference agencies to do this, the agency may record that a search has been made. 
• prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights (as is necessary for our legitimate interests); and
• to provide marketing and communications information where you have given consent.
• to collate and understand survey responses.

How we collect your personal information

We collect your personal information as required for our services both directly and indirectly. 

Directly can be through your engagement with our team, by using our website or responding to a survey. 

Indirectly may be receiving information about you from external sources when we carry out anti-money laundering (‘AML’) and other background checks from other professional organisations. For example, we receive credit history and other AML information from Experian Limited. 

Use of your personal information for marketing purposes

We will inform you about CCLA’s products and services where you have provided marketing and communications consent. This information is not shared with third parties and you can unsubscribe at any time via phone, email or online.

How we keep your personal information secure (including when it is transferred outside the UK)

All the personal data held by or on behalf of CCLA is processed and held on servers located in the UK, or there are contractual requirements in place with suppliers to meet our data protection expectations. CCLA takes all appropriate technical and organisational measures to ensure the effective and secure processing of your personal data. Where we use third parties to process information on our behalf, we ensure that there are agreements in place to provide the same data security standards that we have at CCLA – and that there is a suitable lawful basis for any transfer of personal information outside the UK. You can obtain more details of the protection given to your personal information (including when it is transferred overseas) by contacting CCLA’s Data Protection Adviser using the contact details below.

Who we share your personal information with

We may share your personal information with third party agents and contractors as required to provide our services as follows: 

• with those who provide administrative and operational services to us (for example HSBC, SEI and FNZ)
• in order to verify your identity in accordance with UK money laundering requirements. This may include credit reference agencies
• where we are required to do so by law, regulation or a court order
• with fraud and law enforcement agencies if you give us false or inaccurate information, we suspect a fraud or you have made us aware that you suspect fraud
• with HMRC or other tax or revenue authorities or the FCA.

What are your privacy rights?

You have a number of rights in respect of your personal information under UK data protection laws, including the right:

• to request access to, and copies of, the personal information that we hold about you
• to require us to correct the personal information we hold about you if it is incorrect
• to require us to erase your personal information, in certain circumstances
• to require us to restrict our data processing activities, in certain circumstances
• to require us to transfer the information you gave us from one organisation to another
• where our processing is based on your consent, the right to withdraw that consent (without affecting the lawfulness of our processing based on consent before its withdrawal)
• where the processing is carried out by automated means, to receive from us the personal information we hold about you which you have provided to us, in a reasonable format specified by you (including for the purpose of you transmitting that personal information to another data controller)
• to object, on grounds relating to your situation, to any of our processing activities where you feel this has a disproportionate impact on your rights.

Please note that these rights are not absolute and we may be entitled or obliged to refuse requests where exceptions apply. If you wish to exercise any of these rights, please contact us using the contact details below.

How long we keep your personal information

We have specific retention periods depending on the type of personal data we have and the purposes for processing your data. For example, if you are a customer, we are required under UK law to keep your basic personal data (name, address, contact details) for a minimum of seven years after the end of our relationship with you, at which time it will be destroyed. We will keep your data for the minimum length of time necessary. 

Questions and complaints

If you wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Adviser who will investigate the matter.

If you are not satisfied with our response or if you believe we are processing your personal data unfairly or unlawfully, you can complain to the Information Commissioner’s Office. The ICO’s contact details are available online at: https://ico.org.uk/

Our Data Protection Adviser is Joy Doran and you can contact her by email at: joy.doran@ccla.co.uk or by post: CCLA (attn: Joy Doran), One Angel Lane, London, EC4R 3AB.

November 2024