1. Who are Link Asset Services?
Link Asset Services (“Link”) is a trading name of companies which offer a range of services, principally shareholder, treasury management, banking, debt, fund and corporate administration services. Please refer to the “Legal and Regulatory Status” page on the Link Asset Services website (https://www.linkassetservices.com/) for more details on the trading companies in the Link Asset Services division. All of the companies are wholly owned subsidiaries of Link Administration Holdings Limited (“Link Group”). For more information on Link Group, please visit www.linkgroup.com.
3. What personal information do we collect and why do we collect your information?
We are required by law to obtain “know your client” information as detailed in our terms of engagement for our Services, and this includes certain personal information including information contained in a formal identification document or social security or other unique reference relating to you.
We may receive about you from a third party source in connection with our Services. For example, we may carry out electronic verification checks or screening and/or may receive information about you from a public source or a third party in order to verify your identity or check whether you are a politically exposed person, or subject to any financial sanction or as may otherwise be required by law or regulation. Such electronic checks may involve making automatic decisions about you.
4. How we use your personal information?
We will use the information we hold about you for the following purposes:
Where it is necessary to comply with a LEGAL OBLIGATION
We may use, store and share your information where we are under a legal obligation to do so. This may include use of your information:
- to verify your identity (including electronic checks or screening);
- in connection with any legal obligation on us to report any fraud or other criminal activity (including money laundering or tax avoidance schemes).
In connection with this we may collect information about your political opinions and/or any criminal activity. We may use this information in the substantial public interest in the detection or prevention of unlawful acts or in protecting the public against dishonesty, or for on suspicion of terrorist financing and money laundering. Any information of this type will be subject to appropriate safeguards to with regards to security and to ensure your rights as a data subject are protected.
Where we have a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes.
- for the detection and prevention of fraud and other criminal activities;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a client;
- to comply with a request from you in connection with the exercise of your rights;
- assess and improve our service to customers through recordings of any calls; and
- management of queries, complaints, or claims.
5. Who we share personal information with?
We will only disclose your personal information in accordance with applicable laws and regulations. We may disclose your information to the following third parties:
- any person with legal or regulatory power over us (such as the Financial Conduct Authority, HMRC, the police or the National Crime Agency or the Serious Fraud Office that may require disclosure on legal grounds;
- service providers engaged by us to help us run our business and perform the Services. Such service providers may include, for example, cloud or archive storage providers (engaged by us to provide electronic or physical storage facilities for our business data and your information), or providers of software or other IT resources;
- any member of the Link Group which means our subsidiaries, our ultimate holding company and its subsidiaries (from time to time) as necessary to perform any Services to you.
Some of these third parties (including Link Group subsidiaries and service providers) may be outside of the European Economic Area (EEA). If we transfer your information outside of the EEA in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this policy. This steps include imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy of the relevant documents.
6. How do we keep your information secure?
We store the information you provide about yourself in a secure database and take appropriate security measures to protect such information from unauthorised access. For example, we have adopted internal data protection procedures and trained our staff on them with a view to preventing breaches of security. Where we make available to you any online portal or web-hosted platform to provide any Services to you, all exchanges of information between you and any such portal or platform go through encrypted channels in order to prevent interception of your information. Public access to your information via and any portal or platform is protected by a login using your user ID and password. You should ensure that these are kept secret and not divulged to other people.
You recognise that that your use of our website is entirely at your own risk. As Link websites are grouped to the internet, which is inherently insecure, Link cannot guarantee the information you supply will not be intercepted while being transmitted over the internet. Accordingly, Link has no responsibility or liability for the security of personal information transmitted via our website.
7. How long will we store your information for?
We generally hold your personal data on our systems for as long is necessary to provide our Services and for regulatory compliance. We must keep “Know your Client” information for 5 years after completion of our Services.
8. Your rights
- Right of access – you have the right to know if we are using your information and, if so, the right to access it and information about how we are using it.
- Right of rectification – you have the right to require us to rectify any errors in the information we hold about you.
- Right to erasure – you have the right to require us to delete your information if our continued use is not justified.
- Right to restrict processing - in some circumstances, although you may not be entitled to require us to erase your information, but may be entitled to limit the purposes for which we can use your information.
- Right of data portability – you have the right to require us to provide you with a copy of your information in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours).
- Right to contest a decision made by automated means (such as electronic screening and verification).
9. Following links from our websites
Our website may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
Please note that this policy will be reviewed and may be changed from time to time so please check the page on our website at https://www.linkassetservices.com/privacy-policy/cpc/london occasionally to ensure that you’re happy with any changes. This policy was last updated on 8 May 2018.
If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Officer. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law you can complain to the supervisory authority in the UK responsible for the implementation and enforcement data protection law: the Information Commissioner’s Office (the “ICO”). You have the right to complain to the ICO about our collection and use of your information. You can contact the ICO via their website – https://ico.org.uk/concerns/ - or by calling their helpline – 0303 123 1113.