Privacy Policy

Resolute Group consists of the operating businesses of Resolute. The Group has elected to have its data obligations regulated by the Information Commissioner’s Office (‘ICO’) (https://ico.org.uk) with regards to our treatment of all data received and processed by all of Resolute’s companies. We are registered with the ICO through Resolute Asset Management LLP. This registration covers the uses of personal information set out in this Privacy Policy. If we receive your personal information then we are the controller of that data, which may be collected:

  1. through our website,
  2. when you apply to become our employee,
  3. when you become our employee, or
  4. when you become our client.

Resolute respects your privacy and is committed to protecting your personal data, as well as in general keeping all information collected confidential.

We will not lend or sell your information to third parties.

This Privacy Policy explains how we collect and use your personal data and tells you about your privacy rights and how the law protects you.

Contact details

Resolute Asset Management LLP
4th Floor, Alpha House
24A Lime Street
London EC3M 7HS
www.resoluteassetmanagement.com

As Resolute has fewer than 250 employees, is not a public authority and does not have core activities consisting of large scale processing of special categories of data or requiring large scale, systematic monitoring of individuals we are not legally obligated to appoint a Data Protection Officer, however, we do have a Data Governance Officer, responsible for handling all data protection and privacy related issues. Her details are as follows:

Corinna Lyritzi
+44(0) 20 77337 2230
Corinna.lyritzi@res-am.com

All client information is confidential. It will remain so.

The General Data Protection Regulation (GDPR) and other laws relating to data protection and data privacy apply to personal information. This is primarily information about our employees and potential employees. There will also be some personal data in client information we will collect from time to time. Our policy is to treat all personal data to the same high standard as follows:

What information do we collect about you and why?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We will only use your personal data when the law allows us to.

We may collect, use, store and transfer different kinds of personal data about you on the basis that it is in our legitimate interests to do so in order to carry out our business (and your interests and fundamental rights do not override those interests), or to perform a contract with you, or to comply with legal or regulatory obligations, for example in order to comply with KYC/AML checks. We will collect personal information including identity data, contact data, financial data and technical data.

We may sometimes collect information relating to your health (this is known as a Special Category of Personal Data) where this is necessary to help us provide a service to you (for example if you need particular access assistance), or for insurance purposes, or in order to protect your vital interests, such as keeping on record emergency contact details. By submitting such data to us voluntarily, you will be consenting to us using that data for the purpose of responding to and complying with your request, or for the purpose of notifying your emergency contact in the case of an emergency.

How long do we keep this information?

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, 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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.

If you are or were a Resolute employee or client, we will keep most of your information for the duration of your relationship with us and up to 7 years after such relationship ends, solely to comply with legal requirements such as tax records. Where required by a specific law or regulation, we may keep the specified information for the legally required period.

Who do we share your information with?

Our data is also managed by external providers such as internet companies and software companies. We share data only as far as legally permitted to do so and only as strictly necessary. Within Resolute your information is processed and accessed only by specific individuals who provide HR, IT and system administration services and also undertake leadership reporting, as well as the partners and other senior members of Resolute. External third parties may include:

  • Our IT providers and service providers in order to provide IT and system administration services;
  • Our appointed professional advisers including auditors, accountants, lawyers, bankers, insurers who provide consultancy, banking, legal, insurance and accounting services, to the extent that they may require access to the information to provide advice;
  • HM Revenue & Customs, regulators such as the Financial Conduct Authority, the Information Commissioner’s Office and other relevant tax and regulatory authorities based in the United Kingdom and the other EU countries of our respective offices who require reporting of processing activities in certain circumstances;
  • Fraud prevention agencies and other organisations to allow us to undertake the relevant checks;
  • If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
  • Relevant authorities to investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law.

We require all our employees and third parties to respect the security of all personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside the European Economic Area (EEA). Where we do so, we will ensure that we do this in accordance with current data protection laws by only transferring it to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.

In the future we may choose to sell, transfer, or merge parts of our business or our assets. We may seek to acquire other businesses or merge with them. In such case, we may share your information with such new owners (third parties). Should such a change happen to our business, then we will ensure the new owners use your personal data in the same way as set out in this privacy policy.

Your rights

You have certain rights under data protection laws in respect of the personal data we hold relating to you. You are entitled to a copy of the information we hold about you in a portable format or otherwise, to request access to, correction, erasure, or restriction of processing to the personal information we hold about you, and to object to processing or automated decision making. You also have the right to withdraw your consent, where you have given this. Please note that the application of these rights vary according to the legal basis used to process your data. In certain circumstances we are required to retain copies of information we hold about you by other regulations. In this instance we will not be able to erase or modify your data.

Please see the Definitions below for more information on your rights; details can also be found on the ICO’s Website. If you wish to exercise any of the rights set out above, please contact our Data Governance Officer by calling us on +44 (0) 20 7337 2230 or emailing us at corinna.lyritzi@res-am.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we reserve the right to charge a reasonable fee if your request is clearly repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You have the right to make a complaint about the way in which we handle your personal data at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Data security

We ensure all our third party providers of services or data processing have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Changes to this Privacy Policy and your duty to inform us of changes to your information

This Privacy Policy was last updated on Thursday 24 May, 2018. We may update this Privacy Policy from time to time. When we do so we will notify you of any significant changes.

It is important that the personal data we hold about you is accurate and current. We would be grateful if you would keep us informed if your personal data changes during your relationship with us.

Third party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

Definitions

1. Legal basis for our use of your data

  • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

2. Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; © where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.