How we use your information
This privacy notice tells you what to expect when IPS Capital LLP (IPS) collects your personal information.
Your rights
The general data protection regime under UK law has been modified to address the EU-GDPR’s removal from domestic applicability. The regulations amended the Data Protection Act (DPA) 2018 and merged it with the EU GDPR requirements to form a new, UK-specific data protection regime that works in a UK context after Brexit. This new regulatory framework for UK data protection is known as UK-GDPR. Under UK-GDPR you have rights as an individual which you can exercise in relation to the information we hold about you.
You can read more about these rights here:
https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
Access to personal information
IPS tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a ‘subject access request’ under the Data Protection Act 1998. If we do hold information about you we will:
- give you a description of it;
- tell you why we are holding it;
- tell you who it could be disclosed to; and
- let you have a copy of the information in a durable form.
To make a request to IPS for any personal information we may hold you need to put the request in writing addressing it to the Data Protection Officer, to the address provided below.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. If we do hold information about you, you can ask us to correct any mistakes by, once again, contacting the Data Protection Officer.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint or make a disclosure to government, regulatory, or law enforcement agencies, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
Further information
You can also get further information on:
- agreements we have with other organisations for sharing information;
- circumstances where we can pass on personal data without consent for example, to prevent and detect crime;
- our instructions to staff on how to collect, use and delete personal data; and
- how we check that the information we hold is accurate and up to date.
Links to other websites
This privacy notice does not cover the privacy notice or policy of any other websites. We encourage you to read the privacy statements on the other websites you visit.
Who this notice applies to
This Privacy Notice applies to information we collect about:
- Visitors to our Website;
- Individuals who subscribe to our Newsletter or other Publications;
- Clients and People who use IPS Services;
- Job Applicants and Current and Former IPS Employees;
- Visitors to our Website
When someone visits www.ipscap.com we use a third-party service, Google Analytics, to collect standard internet log-in information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site.
This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. Our website will only collect personal data when you fill in a contact form; we will only use such personal data to fulfil your request and either call you or write back to you. We will make it clear when we collect personal information and will explain what we intend to do with it, should our existing arrangements change.
Use of Cookies by IPS
We may collect information about your computer, including your IP address, operating system and browser type, for system administration. This is anonymous statistical data about users’ browsing habits.
“Cookies” are small pieces of information sent by a web server to a web browser which enables the server to collect information from the browser. You can find out more about cookies on http://www.allaboutcookies.org/. We may use cookies for a number of purposes, for instance to simplify the logging on process, to help ensure the security and authenticity of registered users and to enable traffic monitoring.
You do not need to allow your browser to accept cookies in order to browse much of the website or to access many of our services. Most browsers allow you to turn off the cookie function. If you want to know how to do this please look at the help menu on your browser.
Search Engine
Our website is powered by ______
Our website does not operate a search or decision facility, thus no user-specific data is collected by either IPS or any third party.
IPS uses Mail Chimp to help maintain the security and performance of the IPS website. To deliver this service it processes the IP addresses of visitors to the IPS website.
For example, we collect anonymous information about users’ activity on our website, for example the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it.
- Individuals who subscribe to our Newsletter or other Publications
We use a third-party provider, Mail Chimp, to deliver our e-newsletters. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Mail Chimp’s privacy notice.
Social Media
We have a Linkedin page, however, profiles of our employees and their content are personally managed by each individual.
Phone Calls
When you call IPS we collect Calling Line Identification (CLI) information. We use this information to help improve its efficiency and effectiveness.
People who Email us
We use Transport Layer Security (TLS) to encrypt and protect email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.
We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the limits of the law.
- Clients and People who use IPS Services
IPS offers investment services to the public. Information on our services can be found at https://www.ipscap.com/#whoweare
We must hold the details of those who have requested our services in order to effectively provide the service and to comply with a long list of statutory and regulatory provisions, including financial crime prevention.
However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, closely related services include third parties that would be essential to the provision of our services, such as Custodians
We also use third party providers of technology whom host cloud and provide IT infrastructure support to IPS. In some cases, they may store personal data for IPS. Similarly, third party providers may support our business by providing external support.
When clients agree to use our services, they can cancel or stop using our services as per the applicable product Terms and Conditions.
- Job Applicants, Current and Former IPS Employees
IPS is the data controller for the information you provide unless otherwise stated. If you have any queries about the process or how we handle your information please contact us at msmith@ipscap.com.
What will we do with the information you provide to us?
All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.
We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for the role you have applied for.
What information do we ask for, and why?
We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary.
The information we ask for is used to assess your suitability for employment. You do not have to provide what we ask for but it might affect your application if you do not.
The application stage
We ask you for your personal details including name and contact details. We will also ask you about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Our recruitment team will have access to all of this information.
You may also be asked to provide equal opportunities information. This is not mandatory information and will not affect your application if you choose not to provide it. This information will not be made available to any staff outside of our recruitment team, including hiring managers, in a way which can identify you. Any information you do provide, will be used only to produce and monitor equal opportunities statistics.
We might ask you to participate in assessments; complete tests or occupational personality profile questionnaires; and/or to attend an interview – or a combination of these. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by IPS.
If you are unsuccessful following assessment for the position you have applied for, we may ask if you would like your details to be retained in our talent pool for a period of six months. If you say yes, we would proactively contact you should any further suitable vacancies arise.
Conditional offer of employment
If we make a conditional offer of employment we will ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We are required to confirm the identity of our staff, their right to work in the United Kingdom and seek assurance as to their trustworthiness, integrity and reliability.
You will be required to provide:
Proof of your identity – you will be asked to attend our office with original documents, we will take copies.
Proof of your qualifications – you will be asked to attend our office with original documents, we will take copies.
You may be asked to complete a criminal records declaration to declare any unspent convictions.
We may require you to complete an application for a Basic Criminal Record check via the Disclosure and Barring Service, or Access NI, which will verify your declaration of unspent convictions.
We will contact your referees, using the details you provide in your application, directly to obtain references
If we make a final offer, we will also ask you for the following:
Bank details – to process salary payments
Emergency contact details – so we know who to contact in case you have an emergency at work
Membership of a Pension scheme – so we can determine whether you are eligible to join the scheme.
Regulatory Approval
Some roles require a higher level of due diligence, meaning regulatory approval by the Financial Conduct Authority may be required. If this is the case, we will be required to submit information via the FCA Connect System.
Conflicts of interest
Members of staff must declare if they have any potential conflicts of interest that may exist or arise in the conduct of their employment, the information will be held on your personnel file.
Use of data processors
Data processors are third parties who provide elements of our recruitment service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Medical Insurance and other Insurance
BUPA provides medical insurance to our employees in the form of a standard employee benefit. If we make you a conditional offer, we will ask that you complete a questionnaire which will help to determine if you have any medical conditions that may need to be disclosed. In some situations, your medical insurance benefit or other insurance benefits, such as death in service insurance, may require you to disclose personal data of family members, in some cases minors, which you may want to include as beneficiaries of the policies.
The information will be included in your Employee file and made available to the relevant insurance providers.
How long is the information retained for?
If you are successful, the information you provide during the application process will be retained by us as part of your employee file for the duration of your employment plus 6 years following the end of your employment. This includes your criminal records declaration, fitness to work, records of any security checks and references.
If you are unsuccessful at any stage of the process, the information you have provided until that point will be retained for 6 months from the closure of the campaign.
Information generated throughout the assessment process, for example interview notes, is retained by us for 6 months following the closure of the recruitment process.
Equal opportunities information is retained for 6 months following the closure of the recruitment process whether you are successful or not.
- Complainants
IPS tries to meet the highest standards when collecting and using personal information. For this reason, we welcome comments on whether our collection or use of information is unfair, misleading or inappropriate; similarly, we are open to considering suggestions for improving our procedures.
If you want to make a complaint about the way we have processed your personal information, you can contact us as per contact details below. When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint if applicable.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide and determine whether a legal or regulatory obligation we may owe to our clients may have been breached. In some cases, we may need to share such data with third parties such as law firms, arbitrators, accountancy and forensic service providers, law enforcement and government agencies such as the Financial Ombudsman Service or the Information Commissioner’s office.
Changes to this privacy notice
This privacy notice was drafted using simple language to provide a general understanding of IPS’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
We keep our privacy notice under regular review. This privacy notice was last updated on 15 May 2018.
How to contact us
If you want to request further information about our privacy policy you should write to:
The Data Protection Officer
IPS Capital LLP
4 Eastcheap,
London
EC3M 1AE