Privacy Statement

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 peopleÕs information as one of our goals. We hold data in various forms ranging from paper based through to computerised

Statement

This statement details the Caledonia Asset Management Ltd policy on Data Protection and Privacy. Caledonia Asset Management Ltd collects and uses certain types of personal information about people with whom it deals in order to operate. These include current, past and prospective employees, suppliers, clients, visitors, and others with whom it communicates. Examples of personal information include names and addresses, national insurance numbers, salaries, pension contributions, gender, and age. Where necessary, Caledonia Asset Management Ltd will process 'sensitive data' (including any medical information) in accordance with the Data Protection Act (from now referred to as the Act). Caledonia Asset Management Ltd has a confidentiality policy in place.

Caledonia Asset Management Ltd will not otherwise pass any personal data to third parties, except where permitted by law or where you have given your prior consent. In addition, Caledonia Asset Management Ltd will disclose information to certain bodies where it has a legal obligation to do so, for example to regulatory bodies or authorities such as the Financial Services Authority or the Inland Revenue. Caledonia Asset Management Ltd may also be required to disclose information in order to comply with money laundering laws and for other purposes, for example detecting crime. Caledonia Asset Management Ltd regards the lawful and correct treatment of personal information as important to successful operations, and to the maintenance of confidence between it and those with whom it deals.

We will ensure that our staff and those acting on our behalf obtain, use and disclose personal information lawfully and correctly. To this end we fully endorse and adhere to the principles of Data Protection, as set out in the Act. Specifically, the principles require that personal information shall:

Be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met
Be obtained only for one or more specified and lawful purposes, and shall not be further processed in any manner incompatible with that purpose or those purposes
Be adequate, relevant and not excessive in relation to the purpose or purposes for which it is processed
Be accurate and, where necessary, kept up-to-date
Not be kept for longer than is necessary for that purpose or those purposes. In particular, information submitted to us electronically via this site will be destroyed by secure methods if Caledonia Asset Management is not subsequently appointed as financial adviser to the supplier of such information
Be processed in accordance with the rights of the individual under the Act
Have in place appropriate technical and organizational measures against unauthorized or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal information

Caledonia Asset Management Ltd will, through the use of appropriate and consistent management and application of controls:

Observe the conditions in the Act regarding the fair collection and use of information
Meet its legal obligations to specify the purposes for which personal information is used
Collect and process appropriate information, only to the extent that it is needed to fulfil our operational needs or to comply with a legal requirement
Ensure the quality and accuracy of information
Apply checks to determine the length of time information is held
Ensure that the rights of people about whom information is held, are able to be fully exercised under the Act
Take appropriate technical and organizational security measures to safeguard personal information

Security

Caledonia Asset Management Ltd currently operate their Security requirements through the Security Policy:

Ensuring that staff treat the data with respect:
All members of staff, including temporary members of staff, sign confidentiality agreements
Staff are restricted to certain systems to which are required in order to comply with their job function
Caledonia Asset Management Ltd ensures that personal information is passed to only those people and organisations that are entitled to know. Checks are made to confirm that people are who they say, and that these organisations or people are allowed to have access to this information.

We have implemented security policies, rules and technical measures to protect the personal data that we have under our control from:

Unauthorised access
Improper use or disclosure
Unauthorised modification
Unlawful destruction or accidental loss

All our employees and data processors, who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of our visitors' personal data.

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