Who We Are
Williams Investment Management LLP is a Data Controller registered in accordance with the Data Protection (Charges and Information) Regulations 2018. References to ‘we’, ‘our’ and ‘us’ are all references to Williams Investment Management LLP.
We undertake at all times to comply with the provisions of General Data Protection Regulation and keep confidential all personal data processed for the purposes of our services. Our nominated Information Security Officer is Emma Kilburn.
About Your Personal Data
To provide services to you, we need to collect certain personal information. We may also be required by law, or as a consequence of any contractual relationship we have, to collect your personal information. If you do not provide this information to us, it may prevent or delay us fulfilling our obligations or performing services.
When you use our services, we may use the following types of information about you:
- information you give us, that we acquire, or that we already hold about you, including but not limited to; income, assets owned, employment status, nationality, contact details, phone numbers you use to call us from.
- information about other people with whom you have a financial relationship
- information available in public records, such as the Electoral Register and any information about you that is openly available on the internet
If you voluntarily provide us with any special categories of personal data (for example about your health), we may process this information as needed to assist you or carry out your requests. We will only process this information when we have your consent or we are otherwise allowed to by law.
How We Process Your Personal Information
When we use your personal information, the law says we must be able to show that we have a lawful ground for doing so. Lawful grounds can include:
- when we have a legal obligation,
- when it is necessary to carry out a contract with you or to take steps to enter into a contract with you,
- when it is in our legitimate interest.
When we process personal information on the basis that it is in our legitimate interests to do so we will have undertaken an assessment to ensure our processing is transparent, proportionate and does not unfairly prejudice your interests.
Our Legitimate Interests are:
- To provide the services required
- Meeting our contractual and legal obligations in the most effective way we can
- To comply with a wide range of regulatory obligations to ensure our clients and our business are protected
- To enable us to understand your needs and manage your account in an efficient way
- To ensure we are acting responsibly
- To ensure we invest in a way that is and remains suitable for your circumstances.
With Whom Do We Share Your Personal Information?
When we use your personal information in the ways detailed above we may need to share it with other organisations/individuals as detailed below:
- our settlement agents
- service providers including technology providers
- HM Revenue & Customs or other government or regulatory authorities, when we are required or requested to disclose personal information to them. Some of these government agencies or regulated authorities may be located outside the UK.
- third parties that introduced you to us and/or have a relationship with you
- our nominated banks if necessary for immediate payments
- to any other parties connected to your account including (but not limited to), power of attorney, deputy, individuals who are given third party authority on all or some of your account
Please note that recipients of your personal information may also use it for their own purposes where they have lawful ground to do so. Please check the terms of their privacy statement for how they will use the information.
Transfers of Data To Outside The EEA
We may need to transfer your personal information outside the European Economic Area (‘EEA’) including to the United States. If this is the case we will ensure appropriate safeguards are in place to protect your personal information in the same way as it would be if it was being processed in the EEA.
How Long Will We Keep the Data For?
The length of time we will retain your information will depend on how long our relationship lasts. We will retain your personal information whilst you have a relationship with us. We will retain the information for a minimum of 10 years after your relationship ends to allow us to respond to any questions or complaints and to maintain evidence we have treated you fairly.
We may also keep the information for longer than 10 years after our relationship ends, where necessary for legal or regulatory requirements, where the information is required regarding any ongoing or outstanding claims or legal action, or if we can’t delete the information for technical reasons (in which case we will take appropriate measures to protect the information from further processing or use and will only process for those purposes).
You or your appointed agent have the right to inspect all records relating to you and your transactions through us and where appropriate have them corrected or deleted. The ‘right to be forgotten’ and the right to object to processing means you can request that we delete or stop using your information when there is no reason for its continued processing. As a financial firm obliged to comply with various legal and regulatory requirements there is a wide range of reasons we retain your information. However, if you think we are processing your information without a compelling reason then we can review this. All such requests for information, correction or deletion must be referred to the Information Security Officer at Williams Investment Management LLP. We will not make a charge for responding to such requests.
If you are unhappy with how or why we have used your personal information please contact Robert Ash who is a Partner of the firm and Head of Compliance. You also have a legal right to complain to the Information Commissioner’s Office and you can find out more at their website www.ico.org.uk