Our Commitment to Data Protection

​

RBIM Investment Management places the highest priority on safeguarding personal data. We are committed to handling information responsibly, transparently, and in compliance with all applicable laws and regulations, including:

• UK General Data Protection Regulation (UK GDPR)

• Data Protection Act 2018

• FCA Handbook and Consumer Duty

• MiFID II requirements

This policy applies to all personal data processed in connection with our services, including discretionary portfolio management, adviser engagement, recruitment, and digital interactions.

​

Who We Are

​

RBIM Investment Management Limited is an FCA-authorised discretionary fund manager.

Registered Office: Greville House, 10 Jury Street, Warwick, Warwickshire, CV34 4EW

Company No: 16333138 | FCA No: 1035655

Email: mail@rbim.co.uk

​

Categories of Data We Process

​

We collect and process personal data relevant to our operations, which may include:

• Professional Contacts & Advisers: Name, business details, regulatory credentials, correspondence.

• Clients (via advisers): Contact details, investment objectives, risk profiles, platform information, suitability documentation.

• Website Users: IP addresses, cookies, browsing preferences, enquiry details.

• Employees & Applicants: CVs, employment history, right-to-work documentation, references.

We do not collect data directly from retail clients without adviser involvement.

​

Why We Process Your Data

​

Personal data is processed for legitimate purposes, including:

• Delivering discretionary portfolio services and investment oversight.

• Meeting contractual obligations with advisers and platforms.

• Complying with regulatory requirements (AML, KYC, MiFID II, FCA rules).

• Communicating updates, reports, and service notices.

• Enhancing website functionality and user experience.

• Recruitment and HR administration.

Processing is always based on lawful grounds under UK GDPR, such as contractual necessity, legal obligation, legitimate interests, or consent where applicable.

​

Use of AI and Analytics

​

RBIM may employ AI-driven tools for operational efficiency and investment analysis, including:

• Risk modelling and portfolio performance monitoring.

• Summarising market commentary and internal reports.

• Data tagging and sentiment analysis for internal use.

Important safeguards:

• No automated decisions with significant legal effects.

• AI tools operate under Data Protection Impact Assessments (DPIAs).

• All outputs are reviewed by qualified staff.

• Client personal data is never used to train AI models or retained by external AI platforms.

​

Sharing Your Data

​

We may share data with:

• Your financial adviser or platform provider.

• Third-party service providers (IT, compliance, secure storage).

• Regulatory bodies (e.g., FCA) when required.

• Professional advisers (auditors, legal counsel).

All third parties are bound by data processing agreements and UK GDPR standards. We do not sell or rent personal data.

​

Call Recording

​

In compliance with MiFID II and FCA COBS 11.8, RBIM records calls relating to:

• Investment discussions and portfolio oversight.

• Transaction instructions received via advisers.

• Internal investment committee decisions.

Recordings are retained securely for 5 years (or 7 years where legally required) and used for compliance, quality assurance, and dispute resolution.

​

International Transfers

​

Where data is transferred outside the UK or EEA (e.g., cloud hosting), RBIM ensures:

• Standard Contractual Clauses and UK Addendum safeguards.

• Risk assessments and compliance checks.

​

Data Security

​

We apply robust technical and organisational measures, including:

• Encryption of data in transit and at rest.

• Role-based access controls.

• Regular penetration testing and security audits.

• Mandatory staff training on confidentiality and data protection.

​

Data Retention

​

Personal data is retained only for as long as necessary to fulfil:

• Regulatory requirements (typically 5–7 years for investment services).

• Contractual obligations.

• Legitimate business needs.

After this period, data is securely deleted or anonymised.

​

Your Rights

​

Under UK GDPR, you have the right to:

• Access and obtain a copy of your data.

• Request correction of inaccurate information.

• Request deletion where lawful.

• Restrict or object to processing.

• Request data portability (where applicable).

• Lodge a complaint with the ICO.

To exercise your rights, contact: mail@rbim.co.uk

​

Policy Updates

This policy may be updated periodically to reflect regulatory changes or operational improvements. The latest version will always be available on our website.