We are committed to ensuring that your privacy whilst using this Website is protected. We will only use the information that we collect about you from this Website lawfully. LGPS Central Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. The GDPR requires organisations to be more transparent and accountable to individuals about how it manage and control their data.
This Privacy Notice, sets out how the LGPS Central Limited manages its data, including who it shares data with and for what purpose it might be used. This namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (EU) 2016/679) (GDPR).
How and from where we may receive personal data
• When you contact or correspond with us (for example, by phone (including during recorded calls), e-mail or otherwise) for any other reason (for example, to request services from us);
• When you use our Website, post comments on our Website or via social media;
• When you report a problem with the Website;
• When you apply for a job through the website
• When you:
o Register to receive information from us;
o Meet with us;
o Attend our events;
o Interact with us at third party events;
o Hand us your business card;
o Subscribe for blog alerts and bulletins;
o Sign up to receive news and updates from us;
o Participate in our surveys & questionnaires etc.;
When you provide us with feedback, opinions and / or comments regarding the Website or our services.
Data from other sources
Like many other businesses, we may receive personal data from many sources. This section seeks to list various places from where we may receive personal data about you.
Data we indirectly gather about you:
• When you use the Website, details of your usage (including the date, time, location or duration of the usage);
• If you visit the Website, certain technical information, for example, the type of device (and its unique device identifier) you use to access the Website, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, mobile network information and platform; and
• Information about your visit to the Website including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), pages you viewed, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Data we may receive from third parties
• Companies that introduce you to us (such as financial advisers)
• Financial advisers
• Investment platforms through which you access our clients (investment companies and funds)
• Investment fund administrators or shareholder/unitholder registrars
• Social networks (e.g. google, twitter – see below for further details and our cookies policy below)
• Public information sources such as Companies House or the Financial Conduct Authority’s Register
• Market researchers/Data providers who collect and provide personal data from many sources for the specific and approved purpose of sharing such data with businesses like ours to help with our internal analysis (including assessing market trends, fund distributions statistics etc).
• Marketing partners engaged to help distribute content on us and our services through any medium
• Agents, consultants and advisers. These can be specialist companies who advise us on ways to develop and improve our services and products. These can also be types of firms that help us to prevent, detect and reports unlawful acts and fraudulent behaviours, in particular with regards to financial crime.
• Government and law enforcement agencies
How we use your information
We’ll only use your information where we have your consent, or we have another lawful reason for using it. Unless we say otherwise below, we’ll use your personal information on the basis that it’s within our legitimate interests in operating and maintaining the site and providing you with site functionality and related services. We use information provided or obtained via this site to:
• Respond to your queries (for example, if you’ve asked a question or submitted a complaint via the site)
• Provide you with information, products or services you have requested or which we feel may interest you, unless you tell us otherwise
• Carry out our obligations from any contracts entered between you and us
• Allow you to participate in any interactive features of the site
• Notify you about changes to the site
• Ensure site content is presented in the most effective manner for the device you’re accessing it from
• Undertake data analytics to learn more about how you and others interact with this site and with our advertising
• Detect and prevent misuse or abuse of this site or our services
We also use information to meet our compliance obligations, to comply with other laws and regulations and to share with regulators and other authorities that LGPS Central Limited are subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering and other financial crimes). We’ll only do this on the basis that it’s needed to comply with a legal obligation, it’s in our legitimate interests and that of others or to prevent or detect unlawful acts.
Disclosure of Personal Data to third parties
We may disclose your Personal Data to other entities within the LGPS Central Limited, for legitimate business purposes (including providing services to you and operating our Sites), in accordance with applicable law.
If we have a legitimate interest in doing so (e.g. to manage risk, verify your identity, to combat fraud, abuse of our site or services), or where you’ve agreed to us doing so.
When you send us an email, we may reply with either to confirm receipt or to answer your question, and we will store your communication and our reply for any future correspondence. Beyond our initial reply, we will never use your email address to send you any unsolicited message or information, nor will we share it with or sell it to anyone else for such use.
When you agree to receive information about our services, newsletters, press releases, and/or new offers, we will use your details to provide you with the information or other services, unless or until you ask us to stop. This will also be the case when you request information or other services from us; again, we will stop on your request or when the information or service is no longer available.
We will never use your email address or other information to provide you with any unsolicited messages or information (unless that is part of the service you are requesting), nor will we share it with or sell, rent or lease it to any third party for such use.
We will retain your data for an initial period of two years. After that point, we will remind you of your ability to amend your mailing preferences but will continue to send communications to you unless you elect to opt-out.
All information you provide to us is stored on secure severs. We will use appropriate technical and organisational measures to safeguard your personal data.
Where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
We maintain (and ensure that anyone we share your personal data with maintains) appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the website or any of our services; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.
How we keep your information secure
We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.
You have several rights in relation to the information that we hold about you. These rights include:
• The right to access information we hold about you and to obtain information about how we process it;
• In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
• In some circumstances, the right to receive certain information you have provided to us in an electronic format and / or request that we transmit it to a third party;
• The right to request that we rectify your information if it’s inaccurate or incomplete;
• In some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;
• The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and / or to refuse that request.
You can exercise your rights by contacting us using the details set out in the ‘More details about your information’ section below. You also have a right to complain to the UK Information Commissioner’s Office by visiting www.ico.org.uk, or to the data protection regulator in the country where you live or work.
We will retain the personal data we receive or collect about you for the period reasonably required for us to use it in accordance with this Privacy and Cookies Policy or in accordance with our legal rights and obligations.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may change this Privacy Notice at any time, however, unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your use of this Website. If we make changes to this Privacy Notice, we will notify you by publication here prior to the changes taking effect.
If, however, we make material changes, or we are going to use users’ personal information in a manner different from that stated at the time of collection, we will notify users via this Website prior to the change becoming effective. Users will have a choice as to whether we use their information in this different manner.
However, if users have opted out of all communication with the Website, or deleted their account, then they will not be contacted, nor will their personal information be used in this new manner.
Information posted by users in online blog updates, public forums and online bulletin boards may be displayed on the Website.
Questions, comments and requests regarding this Privacy Notice should be addressed to LGPS Central Limited, First Floor, i9, Wolverhampton Interchange, Wolverhampton, WV1 1LD or firstname.lastname@example.org .
You have the right to make a complaint at any time to a national Data Protection Supervisory Authority. In the UK, this will be the Information Commissioner’s Office (ICO).