Manager privacy notice
Last Updated: July 2018
Employees of Current and Prospective Sub-Investment Managers for the AMX Platform
Changes to Data Protection Laws – Privacy Notice
As you will be aware, there have recently been some significant developments in European data protection law. Of particular importance is the adoption of the General Data Protection Regulation (“GDPR”).
In order to comply with our obligations under GDPR, this notice sets out details of how and why Towers Watson Investment Management Limited of 51 Lime Street, London, EC3M 7DQ. (“we”, “us”, “our”) and third parties acting on our behalf collect and process personal information in connection with its engagement with current and prospective sub-investment managers (“Sub-Investment Managers”) for the Asset Management Exchange CCF and the Asset Management Exchange Master ICAV (the “Funds”). This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed and how individuals can exercise their rights in relation to their personal data.
This notice applies to the collection and processing of personal information relating to employees of Sub-Investment Managers. References to “you” and “your” mean the relevant individuals who are the subjects of the personal data to which this notice relates and “your company” means a Sub-Investment Manager with which an individual is associated.
Personal Data that we Process
We collect personal data relating to you in connection with our dealings with you or your company, including your name, signature, email address, and other contact details.
Purposes of Processing
Personal data that you or your company provides in your subscription application form, or that we otherwise obtain in relation to you, will be processed for the following purposes:
- processing your company’s application to become a Sub-Investment Manager in connection with the Funds;
- complying with our legislative and regulatory obligations in connection with our dealings with you or your company;
- for direct marketing purposes, subject to any preferences you communicate to us;
- maintaining appropriate business records;
- statistical analysis and market research;
- internal training and management of personnel;
- to respond to or evaluate any queries or complaints in relation to your company;
- internal and external audits and, where necessary, investigations; and
- establishing, exercising or defending legal claims.
Legal basis for Processing
The legal grounds that we rely on to process your personal data are:
- that this is necessary to comply with our legal obligations;
- that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party to whom we provide your personal data. We will not process your personal data for these purposes if our or the third party’s legitimate interests should be overridden by your own interests or fundamental rights and freedoms. The legitimate interests pursued by us in this regard include:
- promoting our business, and operating as the investment manager in relation to the Funds;
- conducting our business in a responsible and commercially prudent manner and dealing with any disputes that may arise;
- pursuing our corporate and social responsibility objectives;
Recipients of Data
We may disclose your personal data to various recipients in connection with the above purposes, including:
- to the Funds’ Administrator;
- to Towers Watson Investment Management (Ireland) Limited, the Funds’ AIFM;
- to the Funds’ distributors;
- to the Funds’ depositary;
- to auditors, or other competent regulatory authorities and bodies as requested or required by law;
- to other third parties who we engage to provide services to us, such as professional advisers, auditors and IT service providers;
- to other members of our corporate group.
Transfers of data outside the European Economic Area
In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.
Further details of the measures that we have taken in this regard and the territories to which your personal data may be transferred are available by contacting us via one of the methods set out at the end of this notice.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:
- the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
- the right to require us to rectify any inaccuracies in your personal data;
- the right to require us to erase your personal data;
- the right to request that we no longer process your personal data for particular purposes;
- where the legal basis for processing is consent, the right to withdraw your consent at any time;
- the right to object to our use of your personal data or the way in which we process it; and
- in certain circumstances, you have the right to “data portability”, which means that you have the right to receive any personal data that you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.
In order to exercise any of the rights set out above, please contact us via one of the methods set out below.
If you are not happy with the way we have used your information or addressed your rights, you have the right to lodge a complaint with the Information Commissioner’s Office (https://ico.org.uk) or your local supervisory authority.
Should you have any questions in relation to this notice, please contact Towers Watson Investment Management Limited either through our website or by post at 51 Lime Street, London, EC3M 7DQ.