Ireland: Data Protection Notice

What is held, and on what basis

The Ireland entity holds identification documents, ownership and control records, tax residence declarations, settlement instructions, transaction and valuation records, correspondence, meeting notes and the access logs of the client portal. Each processing activity appears in the group processing register with its origin, its lawful basis, its retention period and a named owner. The firm buys no personal data from data brokers, builds no behavioural profile of a client, and draws no inference about an individual that the mandate does not require. Client data is never sold, and it is never used to train a model that serves another client.

What an individual can require

Any individual whose data the firm holds may ask what is held, ask for a copy, ask for a correction, object to a particular use, or ask for deletion where no retention rule requires the record to be kept. Requests go to privacy@iguako.tech and are answered within 30 days, without charge, whatever the size of the relationship. Where a decision has been assisted by a model, the client may require that a person take the decision again, and the office in Dublin arranges that review within ten business days. A refusal is explained in writing and names the rule relied on.

Where the data goes and how long it stays

Client records sit on group systems and are copied to the regional hub that holds Ireland records, under the intra-group transfer agreement binding every entity in the network. External processors, principally administrators, custodians and auditors, receive only what their function requires, and each is engaged on written terms carrying the same standard. Data is encrypted at rest and in transit, and access to client records is logged and reviewed monthly. Records are kept for seven years after a relationship ends and are then deleted on a scheduled cycle, not at the discretion of the desk that holds them.

The local regime and the reporting of breaches

Data protection law differs across the 28 domiciles. IGUAKO Fund Management (Ireland) Limited records in the group processing register which regime governs its files, which authority supervises that regime, and what the local rule requires beyond the group minimum.

Investor data is held by the administrator as processor under a written agreement that names the vehicle as controller, limits use to the mandate and requires deletion or return at the end of the appointment. A data protection officer is notified to the national data-protection authority for the manager and for the vehicles. A subject request is answered within one month and a personal data breach is notified to the authority within seventy-two hours of confirmation, which matches the group deadline for telling the client. The office keeps a register of processing activities and reviews it before each board meeting of the vehicles.

A suspected breach is reported to the Group Data Protection Officer within 24 hours of discovery and assessed within 72 hours wherever in the network it occurs, and the Europe regional compliance officer is told at the same time.

Personal data is a liability the firm carries on behalf of the people it belongs to, and it is treated that way. The firm collects the minimum the mandate needs, keeps it only as long as a rule requires, and answers for it through a named officer in every jurisdiction where it holds a file.