The UK Data Protection Act (DPA) 2018, was enacted into UK Law to encompass the European Union’s General Data Protection Regulation 2018 (GDPR). Both the act and the regulation applies to ‘personal data’ with a core principle of giving individuals more control of their personal data. Personal data includes (but is not limited to) such details as name, address, telephone number, date of birth, etc. This policy applies to data held in both electronic/digital or paper format and provides information about the way Platform One manages, shares and protects personal data. Throughout this policy ‘personal data’ means any information relating to an identified or identifiable natural person (a ‘data subject’) and the term ‘individual’ will be used in place of the more formal ‘data subject’. In this policy, it is our aim to present the information using clear and plain language and in a manner that is concise, transparent, easily accessible and intelligible. We aim to keep our policy under regular review and we’ll place any updates on our website (www.platform1online.com) and our internal Policy Library.
Platform One Limited T/A Platform One (Companies House Number: 6993268) is registered at Peartree Business Centre, Cobham Road, Wimborne, Dorset. This policy applies across all areas our business including internal policies and procedure, and our website www.platform1online.com. This policy has been adopted both by our parent entity, Platform One Group Limited and any subsidiaries of Platform One Limited.
Platform One Limited is authorised and regulated by the Financial Conduct Authority (FCA). Our registration details can be found on the FCA Financial Services Register at https://register.fca.org.uk. Our registration Number is 542059. Platform One Limited, its subsidiaries and its parent are all registered with the Information Commissions Office as a Data Controller. Our Data Protection Registration Licenses are as follows:
Platform One Limited – ZA647333
Platform One Group Limited (Parent) – ZA647319
Platform Nominees Limited (Subsidiary) – ZA647315
PLATO Nominee Limited (Subsidiary) – ZA647301
Platform One applies all principles of the GDPR and DPA in managing and protecting personal data. These principles are:
There are three important roles enacted into law with defined responsibilities:
· ‘Controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data;
· ‘Processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;
· ‘Sub-Processors’ or ‘Third Party Processors’ mean a natural or legal person, public authority, agency or other body who, under the direct authority of the Controller or Processor, are authorised to process personal data.
This distinction is important because there are specific legal responsibilities that apply to those roles. The DPA & GDPR places specific legal obligations on Processors and Sub-Processors; for example, they are required to maintain records of personal data and processing activities and they will have legal liability if they are responsible for a personal data breach. They place other obligations on Controllers, such as:
· ensuring that contracts with Processors comply with the law;
· providing information to individuals about the processing of their personal data;
· facilitating the exercise of individuals’ rights.
In most cases Platform One will act as a ‘Controller’. Where the relationship of an individual is shared with a third party, Platform One will act in the capacity as a ‘Joint Controller’.
Due to the nature of our business and of our partners’ businesses, the personal data required will typically relate in some way to individuals’ personal and financial circumstances. In the case where a new client is being introduced, the personal data would need to be sufficient to facilitate anti-money laundering and identity verification requirements. In some cases, personal data may also include special categories, such as data about an individual’s health if this is necessary for the provision of the service(s).
Where special category data is required, Platform One should have obtained explicit consent to collect and process that data from the individual.
The primary legal basis that Platform One has for the collection and processing of personal data is for the performance of a contract we have with an individual or with another company such as an adviser firm. Collection of personal data is essential for us to be able to carry out the services that are expected of us effectively. Without the personal data described, Platform One and the other companies we work with would be unable to fulfill our contractual, legal and regulatory obligations.
We share personal data with a custodian, depending upon the service involved. A different custodian is used for each service (i.e. our Imperial Service and Platinum Service, International Service, International Plus Service and our Global Service each use a different custodian). We will provide individual investors with specific details at an appropriate point in time (typically at the time of new client application or specific product application).
We will ensure that the companies we share and control data with have appropriate measures and controls in place to comply with the DPA and GDPR.
We will also ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in collecting and processing personal data and that they’ll only act in accordance with appropriate instructions.
When it is necessary for personal data to be sent to or collected by another party (such as a Product Provider), we’ll use appropriate security measures to protect the personal data.
To fulfill our obligations in respect of prevention of money-laundering and other financial crime we may send personal data to third party agencies for identity and anti-money laundering verification purposes. We will not share personal data with companies outside the Platform One Group of companies without seeking prior consent.
To comply with legal and financial regulations (including audit), we may need to share personal data with HMRC, Regulatory Authorities and/or law enforcement agencies.
In principle, Platform One shouldn’t hold personal data for longer than is required. Platform One has a regulatory and legal requirement to maintain data for a minimum period. We will keep personal data for as long as an individuals is a client of Platform One. Following the termination of the relationship between Platform One and an individual, we will retain personal data for a maximum period of 7 years. This will enable us to deal with any questions or complaints, to demonstrate compliance with regulatory requirements or for legal reasons. All data will be held securely in an encrypted format.
Platform One undertakes a review of personal data in line with our data retention period. Data that is no longer required by us is destroyed and/or deleted inline with the principles set within the DPA and GDPR. Once data has been deleted or destroyed, Platform One will be unable to restore it.
The personal data of individuals are protected by legal rights, including:
A ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. Platform is required to make notification where a data breach is likely to “result in a risk for the rights and freedoms of individuals”. This must be done within 72 hours of first having become aware of the breach.
If individuals have any questions or wish to raise a complaint with regard to how personal data is collect and/or processed by Platform One, they can do so by contacting our Data Protection Officer:
Peartree Business Centre
Tel: 01202 402767
A complainant may also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office,
For any further information regarding this policy please contact the Platform One Data Protection Office listed above.
Our website is provided to you subject to the following terms and conditions. Please read these carefully as, by visiting this Website, you are deemed to have accepted them. If you do not agree to our terms, please leave the Website immediately.
Platform One is an regulated Platform provider and technology company for Independent Financial Advisers (IFAs) and their clients. This website is operated by Platform One Limited (“we”, “the company” or “Platform One”). Platform One is a trading name of Platform One Limited, registered in England and Wales, company number 06993268. Our registered office is Peartree Business Centre, Cobham Road, Wimborne, Dorset, BH21 7PT. Platform One Limited is authorised and regulated by the Financial Conduct Authority. You can find our details on the FCA Financial Services Register at https://register.fca.org.uk. Our FCA Registration Number is 542059. We are also registered with the Information Commissions Office as a Data Controller. Our Data Protection Register number is ZA647333. Platform One Limited is a subsidiary of Platform One Group Limited.
The Website is provided on an “AS IS” and “AS AVAILABLE” basis without any representation or endorsement made and without warranty of any kind whether express or implied, including but not limited to the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security and accuracy. To the extent permitted by law, Platform One will not be liable for any indirect or consequential loss or damage whatever (including without limitation loss of business, opportunity, data, profits) arising out of or in connection with the use of the Website.
Platform One makes no warranty that the functionality of the Website will be uninterrupted or error free, that defects will be corrected or that the Website or the server that makes it available are free of viruses or anything else which may be harmful or destructive. Nothing in these Terms and Conditions shall be construed so as to exclude or limit the liability of Platform One for death or personal injury as a result of the negligence of Platform One or that of its employees or agents.
Platform One has taken all reasonable steps to ensure that the information contained within the pages of this site is accurate, current and complies with the relevant legislation and regulations, however no warranty is given and no representation is made regarding the accuracy of or completeness of the content of this site.
You agree to indemnify and hold Platform One and its employees and agents harmless from and against all liabilities, legal fees, damages, losses, costs and other expenses in relation to any claims or actions brought against Platform One arising out of any breach by you of these Terms and Conditions or other liabilities arising out of your use of this Website.
These Terms and Conditions shall be governed by and construed in accordance with the laws of England and you hereby submit to the exclusive jurisdiction of the English courts.
The Company may choose, from time to time, to amend the content of this Policy and should this happen, we will update the Policy and the revised version will be posted on this website. Please note that the Policy was last revised and updated on 8th February 2021. Please ensure that you visit this Policy on a regular basis so that you have read the latest version and continue to understand what we do with your information. Our status as (and that of any identified contributors) as the authors of content on our Websites must always be acknowledged.
The Website may include links to third party websites that are controlled and maintained by others. Any link to other websites is not an endorsement of such websites and you acknowledge and agree that we are not responsible for the content or availability of any such sites.
Platform One is not authorised to offer or provide investment advice. All content provided within this website is for information purposes only.
For information about how to complain, please see our complaints policy.
Platform One, Peartree Business Centre, Cobham Road, Wimborne, Dorset, BH21 7PT
Telephone: 0345 366 5445
The TCA Global Credit Master Fund went into receivership on May 11th 2020. This affects ISIN KYG8700A1067.
The WAY Absolute Return Fund (a sub-fund of the WAY MA Portfolio) was suspended on April 2nd 2020 prior to termination. This affects ISINs GB00B51M6M39, GB00BG1QH187, GB00B99MR421.
As a result of mergers, the following Kames funds have been suspended temporarily:
Kames High Yield Bond A GBP Acc (ISIN: GB0031425233)
Kames Ethical Corp Bond A GBP Acc (ISIN: GB0005342646)
Kames High Yield Bond A GBP Inc (ISIN: GB0031425126)
Kames Ethical Cautious Manag A Acc (ISIN: GB00B1N9DX45)
Due to “material uncertainty around the valuation of UK properties”, several property funds were suspended around March 16th:
Aviva Investors UK Property Fund (ISIN: GB00BYYYYX64)
Janus Henderson UK Property Fund (ISINs: GB00BP46GC27, GB00BP46GF57, GB00BYP82C20, GB00BYP82D37)
Threadneedle UK Property Authorised Investment Fund (ISINs: GB00BQ1YHT02, GB00BQ1YHS94)
The Kames Capital Property Income Gross B Fund (ISINs: GB00BK6MJB36, GB00BK6MJC43)
The Legal & General UK Property Fund (ISIN: GB00BK35DV33)
The Legal & General UK Property Feeder Fund (ISIN: GB00BK35F408)
The 2nd distributions for the liquidated LF Woodford Equity Income Fund occur on or near 26th March 2020.
* £0.032518 per Share held for ISIN: GB00BLRZQ620;
* £0.039765 per Share held for ISIN: GB00BLRZQC88;
* £0.039542 per Share held for ISIN: GB00BLRZQ737.
The TCA Global Credit Fund Ltd (USD) has been suspended. This was effective as of 21st January 2020 and relates to ISIN: KYG8700A1067.
The Credit Suisse Lux Small & Mid Cap Germany Equity Fund is due to be liquidated. This will occur on 14th February 2020 and relates to ISIN: LU0052265898.
The M&G Property Portfolio and M&G Feeder of Property Portfolio funds have been temporarily suspended. This took effect from midday on 4th December 2019 and relates to these ISINs: GB00B7SX7S61, GB00B842HT59, GB00B89X8P64, GB00B8FWH509, GB00B8FYD926.
For further information on these corporate actions, please contact your IFA.
We do our best to deliver outstanding customer service all the time – even when things go wrong. If your experience with us doesn’t live up to your expectations then please let us know so that we can try and put it right. We take all complaints and problems seriously, and we’ll do everything in our power to fix the problem.
FAO: The Compliance Manager
Peartree Business Centre
Telephone: 0345 366 5445
If we can address your complaint to your satisfaction straight away, we will. If we can’t, we’ll acknowledge your complaint in writing within five days of receiving it and appoint a member of staff to investigate it. You’ll deal with one person, who will stay in touch with you as they work hard to find a solution.
We aim to resolve your complaint within four weeks, at which point we’ll send you a final response. If we can’t fully respond within that time frame, we’ll send you an update indicating when a final response will be available. If we are unable to issue a final response within eight weeks, we will write to you to explain why this is and when we will be in a position to provide a final response.
If you don’t receive your final response within eight weeks of us receiving your complaint, or you are dissatisfied with it (or any other part of the process) you can write to:
Financial Ombudsman Service (FOS), Exchange Tower, London, E14 9SR
Telephone: 0800 023 4567
You must refer your complaint to the FOS within six months of the date on our final response letter.