Legal and Privacy
About this site
PTL is a trading style of PTL Governance Limited (“PTL”).
These pages contain general information only. Nothing in these pages constitutes legal advice. You should consult a suitably qualified lawyer on any specific legal problem or matter.
This website contains general information based on English law and, although we endeavour to ensure that the content is accurate and up to date, users should seek appropriate advice before taking or refraining from taking any action. The contents of this website site should not be construed as advice and PTL disclaims any and all liability in relation to its use. PTL makes no warranties, representations or undertakings about: any of the content of this website (including, without limitation, any as to the quality, accuracy, completeness or fitness for any particular purpose of such content); or any content of any other website referred to or accessed by hypertext link through this website (a “third party site”). PTL does not endorse or approve the content of any third party site, nor will PTL have any liability in connection with any of them (including, but not limited to, liability arising out of any allegation that the content of any third party site infringes any law or the rights of any person or entity).
The contents of these pages are © PTL Governance Limited 2010. You may download to a local hard disk and print extracts from this web site for any non-commercial purpose. You may also copy materials on this site to third parties provided that any such copy is accurate and not misleading, is provided free of charge, acknowledges PTL as its source and prominently features both this limited right to copy and the https://www.ptluk.com web address. You may provide a link (but not a framed link) to this website from any other business information or business service website, but not (save with our prior written agreement) in any way which creates the impression that we are associated with or have approved such other site. Apart from this, you may not reproduce or store any part of this website on any other website without our prior consent.
Anti Money Laundering
The Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007.
The Money Laundering Regulations 2007 (in force from 15 December 2007) and the Proceeds of Crime Act 2002 impose a number of obligations in the United Kingdom as part of the UK Government’s measures to combat money laundering and the financing of terrorism.
The combined effect of this legislation is to provide a stringent and comprehensive system of client identification procedures, record keeping and mandatory reporting. When first taking your instructions we are required to identify both our client and (if relevant) the ultimate beneficial owner of our client, and to verify that identity in a number of ways. We may need your assistance to satisfy these requirements. Without compliance with these obligations we will not be able to act for you.
Legislation in the UK may also place us under a legal obligation, in certain circumstances, to disclose confidential information we have about you and your affairs to law enforcement authorities. Our obligations are not optional and we cannot override or avoid them. We will, of course, ensure that we only report information that we are obliged to report as a matter of law. We may not be able to inform you of the report we have made unless and until permitted to do so by the law enforcement authorities.
Privacy Notice for PTL Governance Limited
PTL Governance Limited (“PTL”) may collect certain information when you use our services and we may collect additional information automatically about your visit to www.ptluk.com (the “Site”). This Privacy Notice (“Notice”) describes how PTL, collect and use your Personal Data in accordance with the EU General Data Protection Regulation (“GDPR”).
PTL is the Data Controller in relation to your Personal Data and is committed to protecting the privacy rights of individuals, including your rights.
Data Protection Manager
PTL is not required under the GDPR to appoint a Data Protection Officer. Following a detailed analysis it does not consider it appropriate to do so. However PTL has appointed a Data Protection Manager (“DPM”), a Client Director, who is responsible for overseeing PTL’s compliance with the GDPR and other applicable data protection regulations.
David Brown, the DPM can be contacted
Postal: PTL, 47 Castle Street, Reading, RG1 7SR
How do we collect your personal data?
We may obtain your Personal Data from you directly including through your use of this website. We may also obtain your Personal Data from a third-party source, for example, we may collect information from our clients/our clients’ personnel, agents and advisors, law firms/advisors which represent you, the company for whom you work, other organisations/persons with whom you have dealings, trustees of pension schemes of which you are a member, credit reporting agencies, and publicly available records.
If you provide information to us about someone else (such as one of your associates, directors or employees, or someone with whom you have business dealings) you must ensure that you are entitled to disclose that information to us and that, without our taking any further steps, we may process that information in accordance with this Notice.
This Notice does not cover pension scheme membership personal data where PTL acts as trustee. Members should refer to the Privacy Notice issued by the trustees of their pension scheme for further details.
What information do PTL collect?
We may collect and use different types of Personal Data about you, which will vary in type and detail depending on the circumstances and purpose of processing. The information collected may include some of the following (this list is not exhaustive):
Personal Data about you:
- your name and position;
- your address (post and/or e-mail);
- your gender and occupation;
- your interests; and
- other information relevant to client surveys and/or service offers
Personal Data to identify you:
- photographs and video;
- passport and/or driving license details;
- electronic signatures;
Personal Data to process payment:
- bank account details;
- HMRC numbers and references (where applicable);
Personal Data to monitor use of our website:
- IP address
- traffic and location information
- other communication information
Why do PTL collect your Personal Data?
We need to collect and use your Personal Data for the purpose of running our business. The information collected via this site and your use of the services may be processed so that PTL may:
- send you information which it thinks may be of interest to you;
- provide our contracted service providers, such as our public relations company, with information about our clients;
- pass your details to accountants, consultants and other professionals, for the purpose of obtaining professional advice and complying with PTL’s contractual obligations;
- to identify clients and comply with our anti money laundering requirements.
We may also process your Personal Data for effective business management purposes which may involve the use of your Personal Data in the following (non-exhaustive) ways:
- to engage and contact suppliers;
- to carry out internal reviews, investigations, audits;
- to conduct business reporting and analytics;
- to help measure performance and improve our services;
- for regulatory and legislative compliance and related reporting; and
- for the prevention and detection of crime.
What is PTL’s legal basis for processing your personal data?
Under the GDPR, PTL must identify a lawful basis for processing your Personal Data which may vary according to the type of Personal Data processed and the individual to whom it relates.
Performance of a contract with you (where applicable):
PTL is entitled to process the Personal Data it requires in order to fulfil its obligations under its contract with you. This will be the relevant legal basis if you are an individual client or supplier/other individual with a direct contractual relationship with PTL.
Legitimate interests of PTL or a third-party:
PTL processes some of your Personal Data on the basis that it is in its legitimate interests and/or the legitimate interests of a third-party to do so. This will primarily concern the processing of Personal Data that is necessary to provide professional trustee advice and services to our clients. PTL legitimate business interest in such instances is the proper performance of its function as a provider of trustee services.
PTL may also process your Personal Data on the basis that it is necessary for its legitimate business interests in the effective management and running of PTL which may include, but is not limited to; engaging suppliers and supplier personnel; ensuring that its systems and premises are secure and running efficiently; for regulatory and legislative compliance, and related auditing and reporting; for insurance purposes; and to facilitate, make and receive payments.
PTL does not consider that the processing of your Personal Data, on the basis that it is within PTL’s legitimate interests, is unwarranted because of any prejudicial effect on your rights and freedoms of your legitimate interests.
Special Category Data
If PTL processes your Personal Data or Special Category Personal Data relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, health data, biometric data or sexual orientation, we will obtain your explicit consent to those activities unless this is not required by law, or the information is required to protect your health in an emergency. Where we are processing Personal Data based on your consent, you have the right to withdraw that consent at any time.
Compliance with a legal obligation to which PTL is subject
In certain circumstances, PTL must process your Personal Data in order to comply with its legal obligations. This might include, but is not limited to, Personal Data required: for tax and accounting purposes; for conflict checking purposes; and for PTL to fulfil its compliance and other obligations under relevant legislation/regulation.
How do we protect your Personal Data?
PTL is committed to keeping the information which you provide to us secure.
We have security arrangements in place to guard against unauthorised access, improper use, alteration, destruction or accidental loss of your Personal Data. We take appropriate organisational and technical security measures and have rules and procedures in place to ensure that any Personal Data we hold is not accessed by anyone unauthorised to access it. We have in place, and abide by, a specific information security policy about the security standards used to protect your Personal Data.
When we use third-party organisations to process your Personal Data on our behalf, they must also have appropriate security arrangements, must comply with our contractual requirements and instructions and must ensure compliance with the GDPR and any other relevant data protection legislation.
PTL’s data protection policy requires each client pension scheme for whom PTL acts as Trustee to have its own data protection policy and privacy statement.
Is your Personal Data transferred to ‘Third Countries’?
We may transfer your personal information to ‘third country’ (those outside the European Economic Area (EEA)) for the purposes set out in this Notice. In addition to the security arrangements mentioned above in relation to our engagement of third-party organisations, where such transfers are required we will ensure that your Personal Data is adequately protected, for example, by using a contract for the transfer which contains specific data protection provisions that have been adopted by the European Commission or a relevant data protection authority.
How long will PTL retain your Personal Data for?
PTL will retain personal data for no longer than necessary.
It is our policy to retain your Personal Data for the length of time required for the specific purposes for which it is processed by PTL and which are set out in this Notice. However, we may be obliged to keep your Personal Data for a longer period, for example, in order to ensure we have effective back-up systems. In such cases, we will ensure that your Personal Data will continue to be treated in accordance with this Notice, restrict access to any archived Personal Data and ensure that all Personal Data is held securely and kept confidential.
Pensions Schemes where PTL is a former Trustee
In respect of pension schemes for which PTL is a former Trustee, as well as recognising the need to retain information for pension schemes which have been wound up, the legitimate interests of PTL include the ability to refer to data in the event of litigation, claims or complaints.
In this context, in the absence of acceptable access to information, data will be held by PTL in accordance with out Terms of Business after PTL have ceased to be a Trustee.
What are your Rights?
The GDPR generally affords individuals a right to access their Personal Data, and to rectify it or port it elsewhere. Individuals may request to see the information that is held about them to check its accuracy. For some Personal Data, individuals also have the right to object to PTL’s processing or to request that the data is erased. There are exceptions to the rights of individuals which may limit your rights in some circumstances.
We have specific procedures in place in relation to Subject Access Requests (“SARs”) that you may be entitled to make. Put simply, a SAR is a request made by you which requires us to provide you with details of your Personal Data which we hold and process and a description of how we process it. Any questions or requests should be put in writing to David Brown, the DPM.
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Site, and the websites visited just before and just after our Site. As with any website operator, PTL may analyse our website logs to improve the value of our Site. We may also use an external service to provide real-time reporting to us and our authorised agents of browser accesses to our Site. This reporting includes page views, unique views, unique visitors, repeat visitors, frequency of visits, and peak-volume traffic periods. We do not use this service to gather, request, record, require, collect or track any Internet users’ personally identifiable information.
We may use Google analytics (or another provider of analytic tools from time to time). You can opt out of Google analytics cookies across all web sites by using a simple add-on from Google. This is available from the following link: https://tools.google.com/dlpage/gaoptout.”
Most browsers allow you to adjust your cookie settings. If you want to know how to adjust your cookie settings, please use the help menu on your browser. However, switching off cookies may restrict your use of our Site. To find out more about cookies, visit www.allaboutcookies.org
Third Party Websites
How to make a Complaint
If you are unhappy with the information provided in this Notice or have concerns about the way in which PTL processes your Personal Data you may in the first instance contact David Brown, the DPM, and if you remain dissatisfied then you may apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk
PTL can be contacted at:
47 Castle Street