Fedelta Trust Limited (“Fedelta”) is committed to the principles of lawful, fair and transparent processing of personal data, and will only use your personal data in order to administer the product or services you are asking us to provide to you.
Fedelta is a ‘Data Controller’ as recognised by the current Data Protection legislation and is registered with the Information Commissioner in the Isle of Man.
Information on our processing activities and the rights that are provided to you under Data Protection legislation are noted below.
Processing information fairly and lawfully
Fedelta processes your personal data only where:
- We have a legitimate interest to do so; or
- A contract has been entered into that allows us to; or
- It is in the vital interests of you as the data subject; or
- You have given your explicit consent; or
- We are required to by our Regulators; or
- We have received a court order.
We will not process personal data unless one of the above conditions apply.
What data do we collect?
Fedelta will only collect personal data that is essential to administer the product or services that you have asked us to provide and to comply with regulatory and statutory requirements. We believe in providing transparency regarding the data we are collecting and why we are collecting it so that you, as a data subject, can make informed decisions as to whether you want your data to be processed or not.
The data that we collect will be dependent on the product or service that you wish us to provide. This data may include:
- Full name, date of birth, age, national insurance number and/or other governmental identification numbers;
- Personal and/or business contact details, including address, telephone numbers and email addresses;
- Full name, relationship to and contact details of your dependants;
- Financial information (including bank account details);
- Marital status/relationship data (including details of your spouse or partner), as well as the full name, address and date of birth in respect of any person identified in an Expression of Wishes Form or Trust Deed;
- Your employment/retirement status, including employment start date and leave date.
Please note that certain categories of data are classed as sensitive personal data. They include:
- Details of racial or ethnic origin;
- Political opinions;
- Religious or philosophical beliefs;
- Trade Union membership;
- Health and medical information;
- Sex life or orientation;
- Criminal records (including alleged offences, spent convictions or court orders).
In the unlikely event that we may need to obtain information from you that may fall within any of the above special categories of data, we will always obtain your explicit consent before acquiring or processing such information.
Why is your data processed?
We collect the above personal data for the purpose of:
- Creation and ongoing administration of the product or structure relevant to your requirements;
- Investment management or administration on behalf of your relevant structure;
- Fund receipt and distribution purposes, including payment of benefits;
- Dealing with any queries and/or complaints;
- Compliance with legal, regulatory and good governance obligations.
How we process and store your data
Your data will be processed and held securely in physical and / or electronic format.
We may also make your personal data available to other parties (individuals or group companies) who are providing relevant services for one of the above data processing purposes, such as professional or legal advisors, investment administrators or managers, banking institutions or for the preparation of accounts or other financial information, etc.
You should be aware that we may, on occasion, be required to share your data with external providers outside of the Isle of Man or European Economic Area (“EEA”). In territories outside the Isle of Man or EEA, laws and practices relating to the protection of personal data may be weaker than those within the Isle of Man or EEA. We will take all reasonable steps to ensure that your personal data receives the same level of protection as it would had it stayed in the Isle of Man or EEA.
Your personal data may also be released to other external parties if authorised by you, or as required or permitted by law, or to comply with a judicial proceeding, court order, request from a regulator or any other legal process served on the Fedelta group.
Our basis for processing your data
The processing of your personal data is necessary in order for us to administer the trust or company that we have been asked to provide services to.
We will proceed on the basis that, for the purposes set out above, you expressly consent to the processing (including the disclosures and transfers described above) of your personal data by the Trustees, Directors or related third parties as set out above.
We will only retain your personal information during the lifetime of our business relationship with you plus any statutory retention period required.
Fedelta has in place a formal retention policy for the personal data information that we hold. All personal data held past these specified retention periods will be destroyed in accordance with this policy.
As detailed within Data Protection Legislation, each Data Subject is afforded a number of rights. In accordance with these rights Fedelta will, upon request:
- Provide you with all of the data we hold about you, in a machine-readable format;
- Provide you with access to any or all the data that we hold about you, and provide you with details about why we have the data;
- Correct any information about you that you notify us is incorrect;
- Unless we are required to continue doing so by legislation, stop, or where applicable, restrict the processing of data about you;
- Remove all records about you from our systems, providing that there is not a legal reason to retain it. If there is a legal reason we will inform you of it, and provide you with details about how much longer we are required to retain your data for.
You can exercise these rights by contacting the Data Protection Officer at firstname.lastname@example.org.
Please notify us as soon as possible if there has been a change in your details (e.g. if your personal circumstances, home address, nominated beneficiaries etc. change).
Fedelta will only contact individuals who have consented to receiving marketing information, or requested direct communication for marketing purposes, and only in relation to our products and/or services.
Should you no longer wish to receive marketing communications from us:
- an unsubscribe facility is available within the marketing email to allow you to request that no further marketing contact is received by you from Fedelta; or
- you can reply to the individual who has contacted you requesting that no further marketing contact is made to you from Fedelta.
After either of these has occurred, Fedelta will not directly contact you in this regard again unless you provide a subsequent request to start receiving marketing material from us.