Hlayisani Fund Managers is committed to protect the confidential information of its clients, employees, and long-term consultants and to ensure the confidentiality of personal information provided to Hlayisani Fund Managers in the course of our business.
Our files may contain both personal information and confidential information that do not fall under the definition of personal information. Under all circumstances, it is understood that Hlayisani Fund Managers shall protect the confidentiality of any information it is entrusted with.
This policy sets out our standards for collecting, using, disposing, and storing the personal information of our clients, employees, and long-term consultants. This Policy also explains how we safeguard the personal information and the right to access that information by our client and employees. The related procedures specify how it shall be applied.
Identifying purposes
For clients
The purpose of the collection and verification of information is twofold: to ensure that Hlayisani Fund Managers’s clients are protected by assisting them in determining investment objectives, risk tolerance, and suitability of investments, and to satisfy Hlayisani Fund Managers’s legal and regulatory obligations, including potential insider or control relationships, the prevention of possible money laundering, and tax reporting requirements.
For employees and long-term consultants
The personal information gathered shall be used for the employment contract between Hlayisani Fund Managers and the employee or its consultants and for the application of the Personal Trading Policy.
Limiting use, disclosure, retention
When personal information is collected from clients, it is to be retained for the period during which clients maintain an account with Hlayisani Fund Managers and for a period of time following the termination of the account, which is stipulated, by law or regulations. When personal information is no longer required, it is to be disposed of in a secure manner.
The personal information collected from any employee or any long-term consultant will be retained for the period during which the employee is with Hlayisani Fund Managers and for a period of time following the termination of the employment or contract as provided by law or regulations.
As a portfolio manager, Hlayisani Fund Managers may in, certain cases, be required to make certain personal information of its clients, employees or long-term consultants available to certain companies, governmental, regulatory and self-regulatory agencies and organisations. These entities are bound to ensure the confidentiality of the personal information provided by Hlayisani Fund Managers. The communication of personal information shall be done with the consent of the individual unless required by law.
The personal information shall not be preserved for longer than needed for the established purposes. Thereafter it shall be disposed of in a secure manner.
Accountability
Hlayisani Fund Managers has appointed a Compliance Officer who is responsible for ensuring that Hlayisani Fund Managers complies with the principles outlined in this Confidentiality Policy and its related procedures.
All employees and long-term consultants of Hlayisani Fund Managers are bound by Hlayisani Fund Managers’s established Policy and procedures to ensure that the personal information of its clients remains confidential.
Accuracy
Hlayisani Fund Managers is committed to maintaining accurate records of its clients’ personal information. From time to time, Hlayisani Fund Managers will request updated account documentation in order to ensure that the personal information is complete and accurate.
Safeguarding client information
Hlayisani Fund Managers implemented and continues to maintain rigorous safeguards in order to ensure that the personal information remains confidential and is protected against loss or theft, as well as unauthorized access or disclosure.
Protection methods include limited access to the premises, technological measures such as off-site backups and archiving to protect personal information of its clients.
Request for access to information
All clients, employees, and long-term consultants have the right to request any information we hold about them and to see this information. They also have the right to enquire on how we used it and to whom it may have been disclosed.
Queries regarding Hlayisani Fund Managers’s Privacy Policy and the assurance of the confidentiality of the personal information, if any, collected from clients, employees, and long-term consultants may be directed, in writing, to:
Hlayisani Fund Managers (Pty) Ltd: admin@hlayisani.com
Complaints and concerns
A complaint concerning the protection of personal information should be addressed to the Compliance Officer at the address provided above.
Compliance
This policy and the related procedures will be reviewed periodically to ascertain their conformity and effectiveness. Furthermore, the Compliance Officer will send at least on an annual basis or further to any changes a reminder of the Policy and its related procedures to all employees and long term consultants.