Privacy Policy

Charles Taylor Privacy Policy

We take care to protect the privacy of our clients, investors and users of these websites. This Policy explains how we process information about website visitors.

Be aware that Charles Taylor is a combination of separate entities and some have their own Privacy Policies which should be read when dealing with a specific entity. For example the Charles Taylor Assistance Privacy Policy; if you cannot find the link to the entity you are dealing with, please contact our Data Protection Officer (DPO) for assistance.

This Privacy Policy sets out how we process Personal Data (that is, data which allow you to be identified, either on its own or with other data available to us or the public). We have set this out for you under “Fair Processing Notice,”.

We set out below our procedures and explains our policy for retention and deletion of Personal Data.

1. CHARLES TAYLOR will keep and maintain Data Inventories, listing the categories of all the Personal Data that it processes, including specifying Special Category Personal Data.

2. CHARLES TAYLOR will keep and maintain a Fair Processing Notice.

3. CHARLES TAYLOR conducts Data Privacy Impact Assessments upon developing new procedures or processes, or entering into new forms of business which involve the processing of Personal Data likely to result in a high risk to the rights and freedoms of natural persons or involving automated decision-making. The CHARLES TAYLOR DPO shall be responsible for any required prior consultation with the ICO . CHARLES TAYLOR will act in accordance with all its legal obligations in respect of Personal Data.

4. CHARLES TAYLOR will give effect to rights to information.

5. Any contracts in which both CHARLES TAYLOR and another entity are joint Data Controllers shall where possible specify their division of responsibilities to maximise the transparency to data subjects, especially regarding their data subject rights.

6. Processing Personal Data for Specified Purposes only

CHARLES TAYLOR maintain the Data Inventories which include:

• for every type and category of Personal Data, the lawful basis (or bases) [consent; contract; legal obligation; vital interests; or legitimate interests] for its processing;
• for every type and category of Special Category Personal Data, the exemption (or exemptions) relied upon from prohibition;
• for every type and category of Personal Data relating to criminal convictions and the like, the provision of applicable data protection law which permits such processing (this type of Personal Data will normally only be processed if CHARLES TAYLOR are advised of, or discover, fraudulent conduct)
• a record of any circumstances in which CHARLES TAYLOR as data controller or processor relies on its own legitimate interests,
• where the processing of Personal Data is for different purposes than the original purposes for which the data was obtained, the new, different, purposes shall be recorded in the Data Inventories.

7. Data Minimisation

CHARLES TAYLOR will only process Personal Data insofar as is reasonably necessary to do so.

CHARLES TAYLOR will review its Data Inventories on a periodical basis, no less than once a year.

8. Data Integrity

CHARLES TAYLOR shall ensure, where reasonably practicable, that all Personal Data it processes shall be accurate and up to date.

CHARLES TAYLOR provides for the right to rectification, which shall be considered without undue delay on receipt of a written request from, or on behalf of, a data subject seeking to rectify (including seeking to amplify) their Personal Data.

9. Data Retention

The CHARLES TAYLOR Data Retention Policy provides details of the period (for which types and categories of) Personal Data shall be retained, and the lawful basis for that retention.

10. Appropriate Technical & Organisational Measures

CHARLES TAYLOR shall take all appropriate technical and organisational measures to keep Personal Data secure and processed only for the authorised purposes.

11. Audit and Review

This Policy shall be reviewed on an annual basis by the CHARLES TAYLOR DPO.

If we change this Policy, we will let you know by publishing the updated version on our website. We aim to protect and respect your privacy, and that intention will carry on in any future changes to this Policy.

This Privacy Policy comes into effect on 1 November 2020 replacing our previous Privacy Policy.

Further details can be found in our Cookie Policy, Terms and Conditions and Fair Processing Policy. For those who work at Charles Taylor, the Charles Taylor Group Privacy Policy is accessible online via Compass. Our other data protection policies are available upon request.

We are committed to processing all personal data fairly, lawfully, and transparently. To make things simpler, Charles Taylor has nominated one data controller, Charles Taylor Ltd, to handle all requests or queries you might have about our processing of your personal data. We have appointed a Data Protection Officer (DPO) to oversee compliance with data protection law. The contact details are:

Emma Hancock, The Minster Building, 21 Mincing Lane, London, EC3R 7AG; dpo@charlestaylor.com.

Last updated November 2020

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