Privacy policy

Baker Steel Capital Managers LLP and UK GDPR

Baker Steel Capital Managers LLP (“Baker Steel”) utilises the highest security measures to protect individual’s data. Baker Steel is committed to protecting the rights and freedoms of data subjects and understands the importance of safely and securely processing their data in accordance with all of our legal obligations.

Baker Steel holds personal data about our employees, clients, suppliers and other individuals for a variety of business purposes. Baker Steel is the ‘data controller’ in relation to your personal data that we hold, because we control the storage and use of that personal data.

This policy sets out how we seek to protect personal data and ensure that our staff understand the rules governing their use of the personal data to which they have access in the course of their work.

What is UK GDPR?

UK GDPR is a regulation in UK law on data protection and privacy for all individuals within the United Kingdom. It also addresses the export of personal data outside the United Kingdom. The UK GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the United Kingdom.

UK GDPR came into force on 31 January 2020, affecting all industry sectors, which addresses what a company can and cannot do with personal data. “Personal data” is information that identifies individuals directly or from which individuals can be identified indirectly.

The UK GDPR website can be found here.

Why does Baker Steel hold and process individuals’ data?

Baker Steel legitimately processes personal data for a range of reasons and different purposes:

  • For investor reporting
  • For portfolio management and trading for Baker Steel’s funds
  • For regulatory reporting and complying with the various laws and regulations to which we are subject
  • For verifying clients’ identities and carrying our regulatory checks
  • For marketing to a specific selection of professional investors
  • For keeping clients, investors, counterparties and media updated regarding Baker Steel and its products
  • For human resources purposes

What are the lawful grounds on which Baker Steel relies to process personal data?

Baker Steel has legitimate interest in processing personal data. “Legitimate interest” is a heading that covers a number of different reasons why we might need to process your personal data which may not be covered by other headings.

We regard our processing of the dataset described above to constitute legitimate interest. The three principles of legitimate interest have been applied:

  1. Purpose test – is there a legitimate interest behind the processing?
  2. Necessity test – is the processing necessary for that purpose?
  3. Balancing test – is the legitimate interest overridden by the individual’s interests, rights or freedoms?

To illustrate Baker Steel’s assessment of legitimate interests as justification for processing personal data, we consider the example of data processing for marketing to a selection of professional investors. Baker Steel applies the three-part test to its marketing activities to determine that it has a legitimate interest to process personal data. Firstly, Baker Steel’s marketing activities have a valid purpose; to promote the firm’s products to a selection of professional investors in a regulatory compliant manner. Secondly, we conclude that data processing is necessary for this purpose, given that certain personal data and contact details are required to carry out marketing activities. Thirdly, the balance of individuals interests, rights and freedoms does not override Baker Steel’s legitimate interest to conduct marketing activity with a selection of professional investors.

Furthermore, data processing is undertaken on lawful grounds by Baker Steel to meet contractual and legal obligations. Baker Steel is required to process personal data where necessary to fulfil contractual obligations with its service providers, suppliers, counterparties and clients. Baker Steel also lawfully processes personal data to comply with legal requirements and statutory obligations, where necessary.

What are my rights and how do I withdraw my consent for personal data processing?

UK GDPR gives you a number of rights over your data, subject to certain criteria being met.

These are:

  • Right to be informed – we provide clear privacy notices and keep records to ensure transparency and accountability.
  • Right of access – you have a right to obtain a copy of the data we hold about you as well as some supplementary information.
  • Right to rectification – we must endeavour to correct any mistakes in the data we hold about you which may be inaccurate or incomplete.
  • Right to data portability – we are required to be able to transfer personal data which you have provided to us, to you or to another firm.
  • Right to object – you have a right to object to the processing of your data on the basis of our legitimate interests and/or to the processing of your data for direct marketing purposes.
  • Right to erasure – we must erase personal data that we hold about you if we are so requested
  • Right to restriction – a right to require us to restrict our processing of your personal data.
  • Right in relation to automated decision making and profiling – We must respect the rights of individuals in relation to automated decision making and profiling.

Where we rely on your consent to process your personal data, you are able to withdraw such consent at any time. To withdraw your consent, please inform Baker Steel by phone (+442073890009) or email (enquiries@bakersteelcap.com) or via your usual Baker Steel contact person.

Will my personal data be passed to third parties?

Baker Steel may pass personal data to third parties whose services we require in order to be able to provide services to you. These may include custodians, brokers, banks, market counterparties, registrars, regulatory or tax authorities, professional advisers such as auditors or lawyers, administrators and software suppliers.

How long do you keep personal data?

Baker Steel retains personal data for as long as an individual remains a client and for a reasonable period of time after that. The length of time personal data is kept will reflect the obligations we have under applicable regulation to store personal data and the practicality of deleting or permanently anonymising personal data from our database.

How can I lodge a complaint regarding processing of my personal data?

If you consider that the processing of your personal data infringes applicable data protection laws, as data subject you have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with the supervisory authority.

The Supervisory Authority is the Information Commissioners Office (ICO) which can be contacted via its hotline (0303 123 1113) or through the Concerns section of its website (https://ico.org.uk/concerns/).

Contact details for Baker Steel

Please contact Baker Steel for any further information on our data processing under UK GDPR. Please contact us by phone (+442073890009) or email (enquiries@bakersteelcap.com) or via your usual Baker Steel contact person.

Updates to this notice

This notice may be updated periodically to reflect changes in the way we process personal data or to clarify information we have provided in this notice.

Source: Information Commissioners Office www.ico.org.uk