Data Breach Policy
- Imperial Asset Managers Limited collects, holds, processes, and shares personal data, a valuable asset that needs to be suitably protected.
- Every care is taken to protect personal data from incidents (either accidentally or deliberately) to avoid a data protection breach that could compromise security.
- Compromise of information, confidentiality, integrity, or availability may result in harm to individual(s), reputational damage, detrimental effect on service provision, legislative non-compliance, and/or financial costs.
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DATA SUBJECT ACCESS REQUEST POLICY
About this Policy: scope, purpose and users
1.1 This procedure sets out the key features regarding handling or responding to requests for access to personal data made by data subjects, their representatives or other interested parties. This procedure will enable Imperial Asset Managers Limited (“Company”) to comply with legal obligations, provide better customer care, improve transparency, enable individuals to verify that information held about them is accurate, and increase the level of trust by being open with individuals about the information that is held about them.
BEST EXECUTION POLICY
General complaint handling principles
1. All complaints received must be handled; no complaint shall be ignored, suppressed or
rejected by any staff or unit.
2. Clients will not be charged any fee as a result of making a complaint.
3. A complaints management register must be maintained and updated immediately
complaints are received by any employee of IMP.
4. Adequate and accessible complaints channels should be in place to accommodate all
complaints from clients.
5. A complaint will be regarded as resolved and closed upon receipt of confirmation from
the client of his satisfaction with the resolution of the complaint. However, where no
feedback is received from the client within a period of 30 days from the date of
communication to the client of the resolution of a complaint, such complaint may also be
deemed to be closed.
6. There must be a centralized complaints desk for managing, reporting and analysing all
7. Every employee of IMP must be equipped to receive and resolve complaints from
8. Effective controls must be in place to ensure adherence to resolution timelines and
minimum standards for the handling of complaints.
Complaints Management Policy
For the purpose of this policy, a complaint is any expression of dissatisfaction or grievance
from a client regarding the provision of services, in which the client alleges that he has
suffered, or is likely to suffer financial prejudice as a result of IMP:
(1) Contravening or failing to comply with any instruction given by the client, or any
agreement or mandate entered into with the client;
(2) Contravening or failing to comply with the regulatory rules and directives;
(3) Acting dishonestly, negligently or recklessly; or
(4) Treating the client unreasonably or unfairly.