1. Personal data you supply to the firm in circumstances where you apply for a job at the firm either directly or via a third party recruiter
2. Information you supply MP and its Investor Relations team as a prospective investor.
The policy describes how MP collects, uses and processes your personal data, and how, in doing so, it complies with its legal obligations to you. Your privacy is important to MP, and the firm is committed to protecting and safeguarding your data privacy rights.
The EU General Data Protection Regulation (Regulation (EU) 2016/679) (together with applicable implementing laws, “GDPR”) is applicable to the processing of personal data by MP and various undertakings appointed by it.
Identity and contact details of data controller
Monterone Partners LLP
22 Manchester Square
London W1U 3PT
Please contact a representative of MP Compliance with any queries or concerns regarding the handling of your personal data: firstname.lastname@example.org
What kind of personal data does MP collect?
Candidate data: In order to assess you for employment opportunities, MP needs to process certain information about you. MP only asks for details that will genuinely help to assist in this process, such as your name, age, gender, contact details, education details, employment history, emergency contacts, immigration status, financial information (where we need to carry out financial background checks) social security number as well as verbal and written references. Where appropriate and in accordance with local laws and requirements, we may also collect information related to your health and any criminal convictions.
Prospective investor data: In order to provide you with information about MP and its funds and associated investment opportunities it may be necessary for MP to process certain personal information such as names, telephone numbers and email addresses and any personal identification documents you supply in order to confirm your identity.
How does MP collect Personal Data?
MP may collect personal data through a range of means. These may include:
How does MP use your personal data?
Candidate data: Your personal details are used by MP to help us (a) assess your suitability for roles that you have applied for either directly or via a recruiter (b) carry out background checks, verification and referencing on you as a candidate (c) to carry out MP’s obligations relating to any potential contracts entered into between MP and you; and (d) to comply with legal or regulatory obligations applicable to MP.
The provision and processing of your personal data is necessary for MP in the context of your potential employment. Without the ability to process your personal data, MP would not be able to assess you for employment at the firm and therefore MP has a legitimate interest in processing our personal data as part of its pre-employment screening.
Prospective investor data: information about prospective investors is used by MP (a) for the purposes of discussing and reviewing potential investments in MP funds (b) assessing an investor’s appropriateness to invest in the fund as an unregulated collective investment scheme (c) to carry out MP’s obligations relating to contracts to be entered into between MP funds and you; (d) for the general administration of potential investments into the MP funds; and (e) to comply with legal or regulatory obligations applicable to MP.
In order to ensure MP provides you with efficient investor relations service and access to information about MP and its funds, MP will store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of conversations, meetings and investor preferences. The provision and processing of your personal data is necessary for MP in the context of your potential interest in the fund. Without the ability to process your personal data, MP would not be able to assess you as suitable to invest in the fund and therefore MP has a legitimate interest in processing your personal data as part of its investor screening activities.
Who does MP share your personal data with?
Candidate data: Your personal data will be shared internally with any of MP’s group companies for the purposes of candidate selection and appointment. Your personal data will also be shared with inter alia third party suppliers who provide screening and testing services to the firm as well as legal, tax and HR advisers and third party recruiters. If references are sought MP will also share your personal data with previous employers and referees.
Prospective investor data: MP will share personal data on prospective investors with inter alia the fund boards, administrators to the funds, legal, tax and accounting advisers as well as third party financial intermediaries in certain instances.
Personal data will only be disclosed by MP to a third party in circumstances where that third party
has agreed to respect the security of personal data and treat it in accordance with applicable law. Third parties to whom any personal data may be disclosed will be permitted to use personal data only as described in this policy and they will only be permitted to process personal data for specified purposes and otherwise in accordance with the instructions of MP.
Transfer of Personal Data outside the European Economic Area
MP may transfer and/or process your personal data outside the European Economic Area (the “EEA”).
If MP transfers personal data outside the EEA, it will seek to ensure a similar degree of protection is afforded by ensuring that personal data is transferred only to persons in countries outside the EEA in one of the following circumstances.
How does MP safeguard your data?
MP has in place security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These security measures include procedures to deal with any suspected personal data breach. MP will notify any affected person and any applicable regulator of any personal data breach in circumstances where they are required to do so by applicable law.
How long does MP retain your personal data for?
Candidate data: If your candidature does not proceed to employment with, or hiring by, MP it will retain your personal details for a period of six months after the position you may be suitable for is filled. After that point MP’s policy is to delete your personal data from its systems unless MP believes in good faith that the law or other regulation requires MP to preserve it (for example, because of our obligations to tax authorities or in connection with any anticipated litigation) or if MP considers that you may be suitable for an alternative role for which it is hiring. If you do receive an offer of employment with MP, further details shall be provided to you in or around the time of your hire, regarding how your personal data may be used for the purposes of your employment.
Prospective investor data: In order to comply with legal and regulatory obligations regarding the proper classification and identification of potential investors in funds which are unregulated collective investment schemes your personal details will be retained by MP for a period of seven years after the last contact with you. After that point MP will delete your personal data from its systems unless MP believes in good faith that the law or other regulation requires MP to preserve it (for example, because of MP’s obligations to tax authorities or in connection with any anticipated litigation).
In some circumstances, MP may decide to retain anonymized personal data for research or statistical purposes, in which case such information may be retained and utilised indefinitely without further notice.
How can you access, amend or take back the personal data that you have given to MP?
You have various rights in relation to your personal data. To get in touch about these, please email email@example.com. MP will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that MP will keep a record of your communications to help it resolve any issues which you raise.
You have the right to obtain information regarding the processing of your personal data and request access to any personal data concerning you that MP is processing. Whilst MP takes efforts to ensure that all personal data that it processes is accurate and up-to-date, you may ask MP to rectify any inaccurate or incomplete personal data concerning you and MP will do so without undue delay.
You have the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that MP may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, MP may need to retain personal data to comply with a legal obligation. You may, in certain circumstances, request that MP erase your personal data. You may also request that MP restricts, or you object to, MP’s processing of your personal data if certain criteria apply. Please note that there may be circumstances where you ask us to erase your personal data, or where you object to or request we restrict, our processing of your personal data, but we are legally entitled to retain it. You have the right in certain circumstances to data portability. This means that, in those circumstances, you have the right to receive from MP any personal data concerning you in a structured, commonly used and machine-readable format, and may request that MP transmit it directly to another data controller, where technically feasible. Please note that this right only applies to personal data which you have provided directly to MP. Should you have any concerns about how MP processes your personal data you should contact MP at the email address above. You also have the right to lodge a complaint with the Information Commissioner’s Office if you think that any of your rights have been infringed by us.
Incidental personal data processed via email
In the process of providing our investor relations service and information about MP and its funds, MP may receive certain personal data, such as the name, address, email and/or telephone number of a financial adviser or other contact of prospective investors. In such circumstances, the personal data of that contact may be retained on a general contact database that is maintained by MP, or in MP’s email storage system, for as long as is necessary to process the personal data for the purpose for which MP is using it, or to comply with our legal obligations. Such personal data will only be processed by MP’s employees in compliance with MP’s data protection and data security policies and procedures.
Monitoring of communications
We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (ii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.