Privacy Notice
This privacy notice tells you what to expect when our organisation collects personal data, and how to contact us should you wish to discuss any aspect of how we handle that data.
Our data protection contact
We have a single point of contact for data protection queries:
Email: ellie@therelocationagent.je
The information we collect and process
We collect various types of personal data, including:
Contact information.
Family relationships.
Personal identification information, which may include items such as your name, address, passport data, PEP status and other data that we might need for Client Due Diligence (“CDD”), Anti Money Laundering (“AML”) checks, and the like.
Financial information such as sources of wealth, assets and shareholdings.
Information about client matters
Our sources of information
As well as collecting data from the individuals themselves we may also obtain personal data from various sources. Some examples are:
Materials gathered as part of regulatory requirements (e.g. CDD and AML).
Documents that we work with as part of the services we carry out for our clients.
Advisors, lawyers or official authorities.
Introducers (e.g. organisations that introduce someone as a potential client).
How we use the personal data we collect
We use personal data in order to operate our business and provide our clients with the services for which they’ve engaged us. The reason that we need any data will generally be made clear when we collect it, but if you do have any specific questions about why we’re collecting any item then please get in touch and ask.
There are various other reasons for which we might use personal data, for example:
For internal administration (e.g. billing).
Compliance with legal and regulatory obligations or procedures.
To protect our interests (e.g. to defend against legal claims).
To send you relevant marketing materials (e.g. invitations to events or updates on the services we provide).
To process queries from customers or other client feedback.
For other legitimate business purposes.
To monitor our compliance with data protection law (e.g. records of subject access requests or data corrections).
If we use data for statistical analysis purposes that don’t need us to be able to identify the individuals to which it relates, we’ll anonymise it (i.e. take out the personal references that could identify people).
Sharing personal data with others
We may also need to share personal data with third parties, such as:
External agents, suppliers or contractors.
Service providers (e.g. contractors or IT service providers).
Lawyers, accountants and other professional entities.
Regulatory or government authorities.
Law enforcement agencies.
Personal data is only shared outside the organisation where it is lawful and legitimate to do so.
Sharing personal data overseas
Where data is being shared with organisations outside the Channel Islands, this will always take place in line with the relevant data protection law both locally and remotely. Consideration will be given to the overseas location, particularly:
Whether the location is in the EU, and is therefore regulated under the GDPR legislation.
Whether the location has a valid adequacy finding from the EU (at the time of writing there are 15 jurisdictions with adequacy findings; this includes Jersey).
Whether the recipient may have signed a contract based on standard contractual clauses approved by the European Commission.
Where none of the above applies, the appropriate risk assessments will be carried out and any necessary controls implemented to ensure the data is protected.
Data retention and disposal
We retain personal data only for as long as it is required to fulfil the purposes to which it relates; we also retain data for as long as we may need it to defend against a legal claim or if we’re required to do so by law or other regulatory requirements.
When data is no longer required it is deleted (for electronic data) or destroyed (for physical documents). Data deletion exercises are carried out periodically so any item that is no longer required will be disposed of in the next deletion exercise.
Marketing
As mentioned previously, personal data may be used to communicate relevant marketing materials. You’re welcome to email us at the above address to ask us to remove you from any list.
Rights of data subjects
Data subjects – the individuals to which personal data relates – have a number of rights under data protection legislation. For example, individuals can request a copy of the data we hold on them, ask us to correct mistakes, ask us to restrict processing of the data or erase it completely, or request that we send it to a third party.
If we’re using individuals’ data solely because they consented to us doing so, that consent may also be withdrawn.
Data subjects can email us at the address given above to exercise any of these rights.
Other sources of data protection information
Our standard Terms of Business have some more detail about confidentiality in general and data protection in particular.
Complaints
Should you have any cause for complaint, please email us at the address given above.
If you’re dissatisfied with the way in which your complaint has been handled you may contact your local data protection supervisory authority, or write to our local Information Commissioner:
Office of the Information Commissioner2nd Floor5 Castle StreetSt. HelierJE2 3BTJersey
Web: https://jerseyoic.orgEmail: enquiries@jerseyoic.org