Privacy Notice

Introduction

This is the privacy notice of International Asset Monitor Limited (Guernsey and Jersey) and its subsidiary IAM Partner LLP (London), together trading as “IAM Advisory”.

Who are we?

International Asset Monitor Limited, trading as IAM Advisory, is a registered limited company (no. 17023). The registered address is Louisiana House, South Esplanade, St Peter Port, Guernsey, GY1 1BJ.  You may contact us via our website, by emailing [email protected] or by writing to us at the above address.

IAM Advisory has a registered branch in Jersey and a subsidiary, IAM Partner LLP, in the United Kingdom.

IAM Advisory’s primary activity is to provide an independent and comprehensive service offering advice and support for clients in all material aspects in the management of investment portfolios.  IAM Advisory has a policy of respecting and protecting your privacy and ensuring the confidentiality of the personal information we collect.

This Privacy Notice sets out the basis upon which information is collected about data subjects by us through the use of the IAM Advisory website and the use of the personal information provided to us.

In relation to the information (“personal data”) we have about you (a living “data subject”), you have these rights:

For any personal data to be processed, the data controller must satisfy a lawful condition for processing. The conditions for processing sensitive personal data (“special category data”) are more stringent than for other personal data.  The following are some of the relevant conditions which allow us to process data.

Anti-Money Laundering laws require us to obtain, verify, review and hold data concerning certain persons associated with the portfolios we advise.

Our regulators require us, by law, to make sure the advice we give is suitable for our clients: this means we have to take into account the characteristics and situation of the relevant people. This might include “special category” data.
We may process “special category” data if necessary for the purposes of exercising rights or obligations in connection with employment law.

We also process personal data in order to perform advisory contracts with our clients.

In respect of some data we have a legitimate interest in processing data, such as to keep in touch with you in order to conduct our business.

If we don’t have any other legitimate reason to use your data, we need your consent to process your data or that of children for whom you have parental responsibility.  In the case of special category data this must be explicit.  Where consent is the only lawful basis for using your data you may withdraw your consent.

How we collect personal information

We collect information about you in the following ways:

What information we collect

What we do with your data

We will use the data we collect from you for the following purposes:

How we store your data and keep it safe

IAM Advisory has in place physical, electronic and managerial procedures to safeguard and secure the personal information we collect.  Data is stored securely on our in-house servers. Our external book-keepers (see below) store employee data on their own servers: this does not include special category data.

Retention of data

We keep your data for the duration of any relevant contract and thereafter for the appropriate limitation period, or as required by our regulators.  In most cases this will be ten years for clients, six years for employees and tenants, and six years for employee pension records  after the end of any relationship we have relating to the data. Where personal data has been obtained in the course of establishing a contract for our services, and the contracts is not finalised, the data may be retained for a period of 4 years from date of collection.  Employees and tenants should please see separate Privacy Notice on our website for more details.

Recipients of your data

We do not share personal information with any third parties for marketing purposes.

All of our data is backed-up using the services of an external data services provider.

Our financial records are maintained by an external book-keeper located in Guernsey who may therefore have access to personal data linked to the financial information.

We are required by law to have our accounts audited and as part of this process our auditors, located in Guernsey  have access to and might make copies of some of the data stored, which might incidentally include personal data.

We may also engage from time to time third parties to assist us with in-house IT development, but these persons work in our offices and do not make copies of our data for themselves.

Limited information on employees is supplied to the organisation, based in Guernsey, which hosts our website
These third party providers are therefore processors of personal data of which we are the controller, and they may themselves save data in data farms (the operators of which are thereby considered to be secondary processors)  We are reaching agreements with our primary data processors to ensure that your information is safe and secure and not shared with other organisations.

Transfer of Data outside the Channel Islands and European Economic Area

The European Economic Area (EEA) and Jersey have similar laws which are mutually recognised by Guernsey as providing adequate protection of personal data.  Other jurisdictions may also be recognised as having adequate protection. Your data will not be transferred to third parties in jurisdictions which are not recognised as adequate without an applicable derogation as provided by law.  In any event we will take steps to ensure that appropriate security measures are taken in any such transfer with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

Rights to access, remove or correct personal information

You have the right to request a copy of the information that we hold about you by way of a Data Subject Access Request.  Please note that your Data Subject Access Request must be accompanied by evidence of your identity, so that we can ensure that we are providing the information only to the right person.  For our Data Subject Access Request form, please contact us using the details at the end of this document.

If a member of the public asks for their personal data to be removed from our current record systems, where we do not have a continuing lawful reason for holding it, this will be done within one month of the request being received. The same timescale will apply when we are notified that personal information needs to be corrected or updated.

Use of our website, and cookies

IAM Advisory uses a Google software statistical analysis tool, licensed by Google to our webhost, to create reports on the general location and browsing habits ( for example, which pages visited) of persons viewing ( Visitors to) the IAM Advisory website. Cookies (small text files placed on your computer when you log in to a website) are used by Google Analytics to track user movements to and on the website.  IAM Advisory does not and will not assist or permit any third party to pass information to Google that Google could use or recognise as personally identifiable information. More detail as to how Google Analytics uses data may be found at www.google.com/policies/privacy/partners/

Changes to our privacy notice

This notice will be amended in the light of any relevant changes in legislation or related good practice.  This privacy notice was last updated May 2018.

How to contact us

Please contact us if you have any questions about our privacy policy.  Our contact details are as follows:

Any complaints in connection with data protection may be directed to the Office of the Data Protection Commissioner in Guernsey, to the Office of the Information Commissioner in Jersey and to the Information Commissioner’s Office in the UK.