Data Protection

DATA PROTECTION NOTICE

Canada Life Investments* (referred to as ‘Canada Life’, ‘we’, ‘us’ or ‘our’ in this DPN) takes its privacy obligations very seriously. Any personal data provided to us, as data controller, by directors, company secretaries, partners, members, trustees, sole traders, shareholders or beneficial owners or other individuals within businesses or other individuals who have provided their personal information in connection with the products and services provided by us to, or to us by, a business or an individual (including but not limited to employees, suppliers, tenants, borrowers and issuers) (referred to as ‘you’ or ‘your’ in this DPN), will be treated in accordance with the Data Protection Act (as amended).

USING PERSONAL INFORMATION

We use personal information to undertake activities relating to the sales, marketing, setting up, evaluation, verification, and administration of our products and services.  These products and services include but are not limited to:

  • making commercial loans available;
  • investing in debt and securities (including equities and fixed income securities); and/or
  • acting as a landlord and providing services in that capacity,

so that we can provide investment solutions including equity, fixed income, real estate and collective vehicles.

This includes processing applications to acquire or obtain the products and services that we offer and handling any claims that arise from those contractual arrangements or enforcement of our rights thereunder. For the majority of our business we will rely on the performance of our contractual arrangements or compliance with a legal obligation with you as the legal basis for processing. We may rely on our legitimate interests to process your personal data. When we do, we will demonstrate compelling legitimate grounds for doing so. 

We use personal data for limited marketing purposes to institutional investors, professional investors and professional advisers but we will not make your personal information available to third parties for the purpose of direct marketing unless you have confirmed your consent to this.

We may obtain information from you from our website, from one of our partners (or the means identified below in the sharing personal information section of this notice) or from you directly (for example, if you contact us by telephone, in writing by post or email or in person).  Telephone calls may be recorded for training and monitoring purposes, and to comply with applicable law and regulations. We collect information through “Cookies” to improve your experience of our website but not for the purposes of sales and marketing.  If you would like to know more about how we use Cookies and other similar technologies please click here for our cookie policy.

SHARING PERSONAL INFORMATION

We share personal information only on the basis of the purposes for which it was collected. This notice is intended to illustrate the instances where data may be shared. However, we will share your data only for the limited and compatible purposes for which it was originally obtained:

  • with other Canada Life group companies including those outside the European Economic Area (EEA);
  • with any of our partners which provide certain fund, custodian, depositary and corporate administration services and related products, such as Link Fund Solutions;
  • with our regulators, supervisory authorities and other government agencies, including without limitation Her Majesty’s Revenue and Customs (HMRC), the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA);
  • in order to prevent, detect or investigate financial crime including fraud or other criminal activity such as money laundering, we may share your data with third parties (including private investigators), organisations (including fraud prevention agencies and databases), public bodies (including the police) and associations and credit reference agencies;
  • in the context of a lending relationship with other lenders or finance parties involved in the relationship;
  • in the context of our relationship with our landlords, tenants, borrowers and suppliers (where necessary to the relationship, for example for monitoring compliance with the loan terms or headlease terms);
  • with third party agents, suppliers, operators, managers, sub-contractors, service providers and advisers who act on our behalf to help us administer our products and services including but not limited to such as firms that:
    • undertake property valuations or provide specialist property consultancy advice;
    • manage our property portfolio;
    • provide us with legal or audit advice;
    • debt recovery services;
    • insolvency services;
    • security services (including providers of databases to prevent financial crime, telephone interception services, building access systems, closed circuit television services, automatic number plate recognition services or other surveillance services);
    • event management services; and
    • providers of systems that manage and store data;
  • to facilitate actual or proposed sales, transfers, assignments, mergers or other dispositions of parts or the whole of our business, or our assets and to facilitate acquisitions of businesses or other assets, subject to customary obligations to keep such information confidential and secure;
  • in any circumstances if permitted or required to do so by law or regulation, where required by any court of competent jurisdiction (or any competent judicial body, tribunal or arbitral body of any kind) or to comply with a judicial proceeding or legal process; and/or
  • if we have your consent to do so.

Where you provide us with information about another person, you are responsible for ensuring that: (i) you have told the individual about Canada Life; (ii) that you have told the individual how we may use their personal information, as set out in this DPN; and you have that individual’s permission to provide that personal information to us and for us to process it, as set out in this DPN.

INTERNATIONAL TRANSFERS

Given the global nature of our business, we use third party suppliers and outsourced services (including cloud based services), which can require transfers of personal information outside of the EEA. In doing so, we ensure that there are appropriate contractual arrangements and we will choose only those organisations with strict controls in place, via appropriate organisational and technical measures in place to protect your personal information.

We will only transfer data outside of the EEA with an appropriate legal basis. Although this list may change from time to time, we may transfer personal data to the following countries outside of the EEA:

  • Canada;
  • Hong Kong (branch);
  • the USA
  • Jersey;
  • Isle of Man
  • Bermuda; and/or
  • Barbados. 

RETENTION OF YOUR PERSONAL DATA

We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim under any of our products or services, or where we are required to keep your personal data due to legal or regulatory reasons.

FINANCIAL CRIME PREVENTION AND DETECTION

In order to prevent and detect financial crime it may be necessary to:

  • Share information about you with other organisations (including private investigators) and public bodies (including the police).
  • Check and / or file your details with fraud prevention agencies and databases.
  • If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example when:
    • Checking details on applications for credit and credit-related or other facilities.
    • Managing credit and credit-related accounts or facilities.
    • Recovering debt.
  • We and other organisations may access and use information recorded by fraud prevention agencies from other countries.

OUR LEGAL GROUNDS FOR USING YOUR INFORMATION

For processing personal data and special categories of personal data

Legal ground

Details

Performance of our contract with you

For the majority of our activities, we will rely on the performance of our contractual arrangements with you.

Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.

Compliance with a legal obligation

Processing is necessary for compliance with a legal obligation to which we are subject.

Protection of vital interests of you or another person

Processing is necessary in order to protect the vital interests of you or of another natural person.

In the public interest

Processing is necessary for the performance of a task carried out in the public interest. 

For our legitimate business interests

Exceptionally, we may rely on our legitimate interests to process your personal data. When we do so, we will demonstrate compelling legitimate grounds for doing so. This includes sending you information about relevant products and events for the purposes of marketing to institutional investors, professional investors and professional advisers.

Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data, in particular of children.

For processing special categories of personal data

Your explicit consent (optional)

You have given your explicit consent to the processing of those personal data for one or more specified purposes.

You are free to withdraw your consent, by contacting our Data Protection contact.

Your explicit consent (necessary)

You have given your explicit consent to the processing of those personal data for one or more specified purposes.

You are free to withdraw your consent by contacting our Data Protection contact. However withdrawal of this consent may impact our ability to provide these products and services.

Protection of vital interests of you or another person, where you are unable to consent

Processing is necessary to protect the vital interests of you or of another natural person where you are physically or legally incapable of giving consent. 

For legal claims

Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity

In the substantial public interest

Processing is necessary for reasons of substantial public interest, on the basis of EU or UK law. 

 

YOUR RIGHTS AND CONTACT DETAILS OF THE INFORMATION COMMISSIONER'S OFFICE (ICO)

You may have the right to require us to:

  • provide you with further details on the use we make of your personal information or your special categories of data;
  • provide you with a copy of the personal information that you have provided to us or which we hold;
  • update any inaccuracies in the personal information we hold;
  • delete any special category of data or personal information for which we no longer have lawful grounds to use;
  • cease processing of your personal information that is based on consent, by withdrawing your consent to that particular processing;
  • cease any processing based on legitimate interests grounds, unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your personal information whilst a complaint is being investigated.

In certain circumstances, we may need to restrict the rights listed above in order to safeguard the public interest (e.g. the prevention or detection of crime) or our interests (e.g. the maintenance of our legal responsibilities).

DATA PROTECTION OFFCIER (DPO)

If you have any questions, or complaints, in relation to our use of your personal information, you should first contact our DPO, on the details below: 

Canada Life Place, Potters Bar, Hertfordshire, EN6 5BA or by email at:   dpo@canadalife.co.uk.

In the unlikely event that you are dissatisfied with our response, you have the right to take the matter up with the Information Commissioner’s Office (ICO), whose address is:

England

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow, Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Email: casework@ico.org.uk

Scotland

Information Commissioner's Office

45 Melville Street

Edinburgh EH3 7HL

Tel: 0303 123 115

Email: scotland@ico.org.uk

Wales

Information Commissioner's Office

2nd Floor

Churchill House

Churchill Way

Cardiff, CF10 2HH

Tel: 029 2067 8400

Email: wales@ico.org.uk

Northern Ireland

Information Commissioner's Office

3rd Floor

14 Cromac Place

Belfast BT7 2JB

Tel: 0303 123 1114 (local rate) or 028 9027 8757 (national rate)

Email: ni@ico.org.uk

This DPN is dated 24/05/18. Any future updates will be made available as described above

*Canada Life Investments is the brand for investment management activities undertaken by Canada Life Asset Management Limited, Canada Life Limited and Canada Life European Real Estate Limited. Canada Life Asset Management Limited (no. 03846821), Canada Life Limited (no.00973271) and Canada Life European Real Estate Limited (no. 03846823) are all registered in England and the registered office for all three entities is Canada Life Place, Potters Bar, Hertfordshire EN6 5BA. 

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