The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Pembrey Asset Management is a data controller. This means we decide how your personal data is processed and for what purposes. Pembrey Asset Management’s Data Protection Co-ordinator, who is responsible for ensuring our compliance with the GDPR, is:
Pembrey Asset Management Ltd
20 North Audley Street
+44 (0)783 121 3885
All staff are aware of their responsibilities in collecting, using and sharing data.
We use personal data for the following purposes:
With reference to the categories of personal data described in the definitions section, we process the following categories of your data.
Personal information (such as name, address, date of birth)
Passport data including passport number
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your personal data:
More information on lawful processing can be found on the ICO website.
Your personal data will be treated as strictly confidential, and will be shared only with our staff as needed
However, we should point out that the Internet is not a totally secure medium and you should acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data, except to the extent we are required to accept such responsibility by law.
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes
Much of our data is required for lawful purposes but where our data collection is optional or permission based you are under no statutory or contractual requirement or obligation to provide us with your personal data.
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
Please note that we may sometimes transfer your personal data to countries outside the European Economic Area (“EEA”) that may not have the same level of protection as countries within the EEA. If we intend to do this, then, where practical and appropriate, before doing so we will put contractual arrangements in place to ensure the adequate protection of your data and we shall endeavour to ensure that any such contractual arrangements comply with the standards required by the Information Commissioner.
We do not use any form of automated decision making in our business.
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Controller Ian Griffiths : firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
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