Complaints
If you wish to register a complaint in respect of Caledonia Asset Management Ltd please write to or telephone us at the contact details given on this site.
A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request. If you cannot settle your complaint with us, you may be entitled to refer it to the financial ombudsman service at www.financial-ombudsman.org.uk or by contacting them on 0800 023 4567.
Privacy
Caledonia Asset Management Ltd uses Personal Information as part of our business. It forms the basis of our relationship with our customers, our suppliers and our employees. This relationship is particular to those individuals and companies with which we deal. To this end we recognise that that this information should be treated with the respect that those individuals expect. It is the aim of this Privacy Statement to promote privacy of people’s information as one of our goals. We hold data in various forms ranging from paper files through to computer based data.
Privacy Policy
Applies from May 25 2018
Caledonia Asset Management Ltd is committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data we collect from you, or that you or third parties provide to us, will be processed by us. Please read the following carefully to understand our policies and practices regarding your personal data and how we will treat it.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Investment, Pension, Advice or Insurance requirements Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing investment/pension and/or insurance products and the terms and conditions relating to these
Caledonia Asset Management Ltd is a Data Controller and Data Processor in respect of your data.
By becoming or continuing to be a client of the firm, visiting the Caledonia Asset Management or pensionproblems websites, or contacting us through these, you are accepting and consenting to the practices described in this notice.
Your rights in relation to information we may collect from you
Subject to certain limitations on certain rights, you have the following rights in relation to your information. You can:
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to keep in touch with you in the future (including withdrawing any consent in its entirety). Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent at any time before the point in time when you withdraw your consent.
In accordance with UK Data Protection law, you also have the right to lodge a complaint with a supervisory authority. Within the UK, the supervisory authority is the Information Commissioner’s Office (ICO).
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact: Pauline Forbes at 8 Coates Crescent, Edinburgh, EH3 7AL, 0131 225 4488 or [email protected].
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you.
You will usually provide information during the course of our initial meetings or ongoing meetings and conversations with you to establish your circumstances and needs and preferences in relation to financial advice, investment, pensions and insurance. You will provide information to us verbally and in writing, including by email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll or Companies House. Where we receive information from a third party we assume that they have obtained your consent prior to providing us with your information. Note that information from third parties may include situations such as a spouse providing details about their husband or wife.
We may collect and process the following data about you when you engage us for financial planning, financial advice, employee benefit services or investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services:
If visiting our websites you should be aware that our websites use Google Analytics which automatically collects certain information about you when you visit them. This information is provided to us on an anonymised basis. Information collected includes:
- Technical information including your geographic location, browser type, operating system and platform; and
- Information about your visit, including the source of your visit, click path through our sites (including date and time); pages you viewed, searches, length of visits to certain pages.
We may use this information and the combined information for the purposes set out in this Privacy Notice (depending on the types of information we receive).
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your investment, pension and/or insurance advice requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you in relation to the service you received.
On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance, or ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance / investment providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
Sharing Your Personal Data
From time to time Your Personal Data may be shared with:
- Investment Providers/Platforms/Banks/Providers of Financial Services Products/ Insurance providers/Trustees as appropriate to your situation
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, your professional advisers (with your consent)
- We may disclose or share your personal information where we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements.
- We may disclose your personal information to third parties in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- We may disclose or share your personal information where we are required to do so by the courts or to comply with other legal, statutory and/or regulatory obligations including accounting and taxation requirements.
- In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress any business we are conducting for you and to provide you with professional services.
Security of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us.
How long will we keep your Personal Data?
Your personal data will be retained for as long as is necessary to enter into or perform a contract with you; or for compliance with a legal obligation under EU law or the laws of the United Kingdom; or for the establishment, exercise or defence of future legal claims.
Everybody has a right to erasure under the UK Data Protection law. However, given that Caledonia Asset Management Ltd operates within a regulated financial services environment it is unlikely that it will be possible for us to remove all personal data from our systems once a contractual relationship has been entered into as we may be required to provide this either by the Financial Conduct Authority, The Financial Ombudsman service (or their future equivalents) or in the establishment, exercise or defence of future disputes or claims. As such, data provided as part of a contractual relationship is likely to be retained permanently.
This does not impact upon your rights to rights of access, rectification, or portability of personal data. You also have the right to withdraw your consent to the processing of your data at any time.
Where we store your personal data
We store your data on our secure servers in the United Kingdom and retain it for a reasonable period or as long as the law requires. However, your data may be transferred to, stored at, and processed at a destination inside or outside the European Economic Area by our partners or service providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
Links to external websites
Our sites may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your data. Please check these policies before you submit any personal data to these websites.
Cookies and web analytics
Caledonia Asset Management Ltd. uses “cookies” to make parts of our website work and to collect data that helps us understand our visitors better. A cookie is a text file that is placed on your hard disk by our web page server. Cookies cannot be used to run programs or deliver viruses to your computer.
We use cookies because we want to make our website user-friendly, and we are interested in anonymous user behaviour. Our cookies don’t store sensitive or personally identifiable information such as your name or address.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies it should not normally affect your website experience.
Legal Statement
IT IS IMPORTANT THAT YOU READ THIS PAGE. IT CONTAINS IMPORTANT INFORMATION. BY ACCESSING THIS WEBSITE, YOU WILL BE DEEMED TO HAVE AGREED TO WHAT IS SET OUT BELOW.
1. Publisher:
This website is published by Caledonia Asset Management Ltd, 8 Coates Crescent, Edinburgh, EH3 7AL, who are Authorised and Regulated by the Financial Conduct Authority.
2. Information, Not Advice:
This website is for information only and is subject to change without notice. It is not intended to offer advice and is not to be taken as in any way offering advice.
3. Leaving the Website:
After you leave this website (whether knowingly or not), Caledonia Asset Management Ltd is not responsible in any way for any other pages, websites or other thing that you access, and the results of accessing them.
4. Copyright:
Copyright in this website is owned by Caledonia Asset Management Ltd as far as is allowed by United Kingdom law.
The Pensions Problems logo is a registered trademark owned by Caledonia Asset Management Ltd.
Pictures on this site are used under license from Dynamic Edinburgh and Alamy.
5. United Kingdom Residents:
This website is issued in the United Kingdom and is intended for the information and use of United Kingdom citizens. The information and guidance contained within the website is subject to the UK regulatory regime and is therefore primarily targeted at customers in the UK.
6. Downloading Information:
Please note that any downloading of software or information is done at your own risk. Caledonia Asset Management Ltd does not warrant the suitability of anything that is downloaded and accepts no liability for any problems that may arise as a result. If you are in any doubt about downloading anything, we recommend that you take specialist advice before downloading.
7. E-mail:
Caledonia Asset Management Ltd does not guarantee that any e-mail sent to us will be received, or that the contents will remain private during transmission. If you are concerned about this, then please consider other means of communication. You will be responsible for ensuring that any electronic message or information you send to us is free from any virus or defect that may harm our systems in any way.
8. Website Availability:
Caledonia Asset Management Ltd does not guarantee that this website will be available at all times. Further, this website may be withdrawn at any time without notice. Caledonia Asset Management Ltd shall not be liable in any way if this website is unavailable or withdrawn.
9. General:
(a) Caledonia Asset Management Ltd has taken care concerning the accuracy and integrity of content on this website. However, Caledonia Asset Management Ltd is not to be held liable in any way for any errors and/or omissions concerning what is on, or is omitted from, this website.
(b) The information on this website is based on Caledonia Asset Management Ltd.’s interpretation and understanding of the law, regulations and HM Revenue & Customs practice as at September 2015. We believe this interpretation is correct, but cannot guarantee it. The content of the website is intended for general information and should be used in that form only. The content is not intended to address your particular requirements nor does it constitute a full and authoritative statement of the law/legislation. It is not intended to be nor shall it be deemed to be advice, nor does it constitute advice. Although every effort has been made to provide accurate and timely information, there can be no guarantee that the information is accurate as of the date it is accessed by you or that it will continue to be accurate in the future. No individual or company should act upon such information without receiving appropriate professional advice after a thorough examination of their particular situation. We cannot accept responsibility for any loss as a result of acts taken or not taken as a result of information in any part of this website, or for any omissions within it.
(c) Caledonia Asset Management Ltd will not be liable in any way for the results of any unauthorised access to this website, or any unauthorised alteration to this website.
(D) The terms of, and use of, this website shall be governed by the law of Scotland.
10. Anti Bribery Policy and Procedures:
Caledonia Asset Management Ltd values its reputation for ethical behaviour, honesty and reliability. It recognises that over and above the commission of any crime, any involvement in bribery will also reflect adversely on its image and reputation. Its aim therefore is to limit its exposure to bribery by putting in place policies to do this.
Caledonia Asset Management Ltd expressly prohibits the following behaviours:
The offering, giving, solicitation or acceptance of any bribe, whether cash, gift, hospitality or other inducement to or from an individual or business, wherever they are situated and whether they are a public official or body or private person or company by any individual employee, agent or other person or body acting on the firm’s behalf for the purposes of gaining any commercial, contractual or regulatory advantage for the firm in a way which is unethical or in order to gain any personal advantage for the individual or anyone connected with the individual.
Caledonia Asset Management Ltd Undertakes to:
Train all employees so that they can recognise and avoid the use of bribery by themselves and others; Encourage its employees to be vigilant and to report any suspicion of bribery, providing them with suitable channels of communication and ensuring sensitive information is treated appropriately; Rigorously investigate instances of alleged bribery and assisting the police and other appropriate authorities in any resultant prosecution; Take firm and vigorous action against any individual(s) involved in bribery.
11. Risk Warning:
The value of any investment may go down as well as up, and you may receive back less than you originally invested.
12. Suitability Warning:
You should consider your ability to withstand losses, as well as gains before making any investment. Investing is a risk based activity.
13. Regulatory Information
Caledonia Asset Management Ltd is Authorised and Regulated by the Financial Conduct Authority under 214037.