Policies and Procedures
Data Protection | Complaints | Anti-Money Laundering
COMPLIANCE
At The Iron Circle, we prioritise compliance with all relevant regulations and standards to ensure the security and legality of our property investment operations. We are committed to maintaining the highest levels of integrity and transparency in all our dealings. Here’s how we ensure compliance:
Property Redress Scheme (PRS)
The Iron Circle is a member of the Property Redress Scheme (PRS), which provides an independent and impartial dispute resolution service. This membership ensures that any complaints or disputes that may arise are handled fairly and professionally.
Key Points:
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Impartial Resolution: The PRS offers a neutral platform for resolving disputes between property professionals and their clients.
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Consumer Protection: Membership in the PRS underscores our commitment to consumer protection and fair practice.
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Accountability: Being part of the PRS holds us accountable to high standards of service and ethics.
Information Commissioner’s Office (ICO)
We are registered with the Information Commissioner’s Office (ICO) under the Data Protection Act. This registration ensures that we handle your personal data with the utmost care and in compliance with data protection laws.
Key Points:
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Data Protection: We are committed to protecting your personal information and ensuring it is used lawfully, fairly, and transparently.
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Privacy: Your privacy is of paramount importance to us, and we have robust measures in place to safeguard your data.
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Rights: You have rights regarding your personal data, including access, correction, and deletion. We respect and uphold these rights in all our dealings.
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Anti-Money Laundering (AML) Supervision with HMRC
The Iron Circle is supervised by HM Revenue & Customs (HMRC) for Anti-Money Laundering (AML) compliance. We have stringent measures in place to prevent money laundering and financial crime.
Key Points:
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Verification: We conduct thorough due diligence, including identity verification and proof of funds, to ensure compliance with AML regulations.
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Monitoring: Continuous monitoring of transactions and activities helps us detect and prevent suspicious activities.
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Training: Our team is regularly trained on AML policies and procedures to stay updated with the latest regulatory requirements.
Data Protection Policy
1. Introduction
At The Iron Circle, we are committed to protecting the privacy and security of
the personal data of our investors. This Data Protection Policy outlines how we handle,
store, and process investor data in compliance with the requirements set forth by the
Information Commissioner's Office (ICO) and relevant data protection legislation.
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2. Scope
This policy applies to all employees, contractors, and third parties who handle investor
data on behalf of The Iron Circle. It covers all forms of personal data, whether
processed electronically or manually, and includes data collected from investors, both
online and offline.
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3. Principles of Data Protection
The Iron Circle adheres to the following principles when handling investor
data:
3.1. Lawfulness, Fairness, and Transparency: We process personal data lawfully, fairly,
and in a transparent manner. We provide clear and concise information to investors
about how their data is collected, used, and stored.
3.2. Purpose Limitation: We collect and process personal data only for specified and
legitimate purposes. Data is not further processed in a manner incompatible with these
purposes.
3.3. Data Minimisation: We collect and process only the minimum amount of personal
data necessary for the intended purposes.
3.4. Accuracy: We ensure that personal data is accurate, up-to-date, and relevant. We
take reasonable steps to rectify or erase inaccurate or incomplete data.
3.5. Storage Limitation: We retain personal data for no longer than necessary to fulfill
the purposes for which it was collected, taking into account any legal or regulatory
requirements.
3.6. Integrity and Confidentiality: We implement appropriate technical and
organizational measures to ensure the security and confidentiality of personal data,
protecting it against unauthorized access, loss, destruction, or alteration.
3.7. Accountability: We are accountable for our data protection practices, ensuring
compliance with applicable laws and regulations. We maintain records of our data
processing activities.
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4. Collection and Use of Investor Data
4.1. Data Collection: We collect personal data from investors for the purpose of
providing our deal packaging services. This may include, but is not limited to, names,
contact details, financial information, and any other information required for
investment purposes.
4.2. Legal Basis: We rely on one or more legal bases, such as the performance of a
contract, compliance with a legal obligation, or the legitimate interests pursued by
The Iron Circle, to lawfully process investor data.
4.3. Data Use: Investor data is used solely for the purpose of fulfilling our contractual
obligations, managing investor accounts, and communicating relevant investment-
related information. We do not use investor data for marketing purposes without
explicit consent.
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5. Investor Data Storage and Security
5.1. Data Storage: Investor data is stored securely in electronic and/or physical
formats, using industry-standard security measures to protect against unauthorised
access, loss, or theft. We maintain appropriate technical and organizational safeguards
to ensure the confidentiality, integrity, and availability of investor data.
5.2. Third-Party Processors: In some cases, we may engage third-party processors to
handle investor data on our behalf. We ensure that these processors comply with
applicable data protection laws and have adequate security measures in place.
5.3. Data Transfer: If personal data is transferred outside of the European Economic
Area (EEA), we ensure that appropriate safeguards are in place, such as utilising
standard contractual clauses or relying on the adequacy decisions made by the
European Commission.
5.4. Data Breach Response: In the event of a data breach involving investor data, we
have procedures in place to respond promptly and effectively. We will notify affected
individuals and the ICO, as required by law.
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6. Investor Rights
6.1. Data Subject Rights: We respect the rights of investors regarding their personal
data, including the rights to access, rectify, erase, restrict processing, object to
processing, and data portability. We provide mechanisms to exercise these rights and
respond to requests in a timely manner.
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7. Training and Compliance
7.1. Training: We provide regular training to employees and contractors on data
protection principles, best practices, and their obligations under this policy.
7.2. Compliance Monitoring: We monitor compliance with this policy through audits,
assessments, and reviews. Any suspected breaches of this policy or data protection
laws should be reported immediately to the designated data protection officer.
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8. Review and Update
This Data Protection Policy will be reviewed and updated as necessary to ensure
ongoing compliance with ICO requirements and any changes in relevant data
protection legislation.
Complaints Policy
At The Iron Circle, we strive to provide exceptional service to our
clients. We take pride in our commitment to transparency, professionalism, and
customer satisfaction. However, we understand that there may be occasions when our
clients feel the need to raise a complaint. We value your feedback and are dedicated to
resolving any issues promptly and fairly. This complaints policy outlines the steps to be
followed when making a complaint to our business, inline with the Property Redress
Scheme's Code of Conduct.
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1. Objective
Our objective is to handle all complaints efficiently, effectively, and fairly, ensuring that
we address your concerns and take appropriate actions to resolve the issue.
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2. Definitions
For the purpose of this policy, the following terms shall have the meanings assigned to
them:
-"Complainant" refers to any individual or organisation who is dissatisfied with our
services and wishes to make a formal complaint.
-"Complaint" refers to an expression of dissatisfaction made by a complainant,
whether written or verbal.
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3. Complaints Procedure
3.1. Informal Resolution
We encourage complainants to initially raise any concerns informally with the
individual(s) directly involved in the matter. In most cases, an informal resolution can
be achieved promptly, avoiding the need for a formal complaint.
3.2. Formal Complaint
If an informal resolution is not possible or fails to address the issue satisfactorily, a
formal complaint may be lodged. To make a formal complaint, the following steps
should be followed:
3.2.1. Written Complaint
The complainant should submit a written complaint to The Iron Circle,
detailing the nature of the complaint, including any relevant supporting documents or
evidence. The written complaint can be submitted via email, letter, or through our
online complaint form.
3.2.2. Acknowledgement
Upon receipt of the written complaint, The Iron Circle will
acknowledge the complaint within ten business days. The acknowledgement will
include the name of the person responsible for handling the complaint and an outline
of the expected time frame for resolution.
3.2.3. Investigation
A thorough investigation will be conducted to gather all necessary information related
to the complaint. This may involve reviewing relevant documentation, speaking with
involved parties, and any other reasonable steps to assess the complaint thoroughly.
3.2.4. Resolution
The Iron Circle aims to resolve complaints within 30 business days
from the date of acknowledgement. Once the investigation is complete, we will provide
a written response to the complainant, outlining the findings, any actions taken or to be
taken, and the rationale behind the decision.
3.2.5. Property Redress Scheme
If the complainant remains dissatisfied with the outcome, they have the right to
escalate the complaint to the relevant Property Redress Scheme. We will provide the
necessary details and guidance on how to proceed with this option.
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4. Records
All complaints and related documentation will be recorded and maintained securely by
The Iron Circle for a minimum of 10 years.
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5. Continuous Improvement
We view complaints as an opportunity to learn, improve our services, and prevent
similar issues from recurring in the future. Regular reviews of the complaints received
will be conducted to identify any underlying trends or systemic problems that require
remedial action.
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6. Confidentiality
All complaints and the associated information will be treated with the utmost
confidentiality, respecting the privacy of the complainant and the individuals involved.
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7. Training and Awareness
The Iron Circle will ensure that all staff members are aware of this
complaints policy, understand their role in its implementation, and receive appropriate
training to handle complaints effectively and in line with the Property Redress
Scheme's Code of Conduct.
We are committed to providing a transparent and robust complaints process to
address any concerns raised by our clients. If you have any questions or require further
assistance, please do not hesitate to contact us.
Anti-Money Laundering Policy
Purpose:
The purpose of this Anti-Money Laundering (AML) Policy is to outline the measures
and procedures that our deal packaging business implements to ensure compliance
with anti-money laundering regulations. This policy specifically focuses on monitoring
investor proof of funds, maintaining a proper audit trail, handling overseas investors,
and addressing high-risk investors.
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1. Monitoring Investor Proof of Funds:
1.1. Before entering into any business transactions, we require investors to provide
satisfactory proof of funds, demonstrating the legitimacy of the funds being used for
investment purposes.
1.2. We establish clear guidelines regarding acceptable forms of proof of funds, such as
bank statements, financial statements, or other relevant documents.
1.3. Our team verifies the authenticity of the provided documents by cross-referencing
them with reputable financial institutions or conducting independent verification
through third-party sources.
1.4. We document and maintain records of all proof of funds provided by investors as
part of the audit trail.
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2. Audit Trail:
2.1. We maintain a comprehensive audit trail for each transaction, recording all
relevant information and documentation in a secure and easily accessible manner.
2.2. The audit trail includes details such as investor identification information, proof of
funds, transaction records, and any other relevant documentation.
2.3. All communication related to transactions is appropriately documented, including
emails, messages, or other forms of correspondence.
2.4. Regular internal audits are conducted to ensure the integrity and accuracy of the
audit trail.
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3. Dealing with Overseas Investors:
3.1. When engaging with overseas investors, we exercise additional due diligence to
address potential money laundering risks associated with cross-border transactions.
3.2. We conduct enhanced verification procedures, including verifying the identity of
the investor through reliable and independent sources.
3.3. We assess the investor's home jurisdiction and consider the country's level of AML
regulation and its inclusion on recognised international watchlists.
3.4. We ensure compliance with any applicable local laws and regulations, including
those related to foreign investments and AML requirements.
4. High-Risk Investor Monitoring:
4.1. We establish criteria to identify high-risk investors based on recognized factors
that could indicate potential money laundering or illicit activities.
4.2. High-risk factors may include, but are not limited to:
a) Politically Exposed Persons (PEPs) or individuals closely associated with PEPs.
b) Individuals from countries known for high levels of corruption or inadequate AML
regulation.
c) Investors with a history of involvement in suspicious financial activities or illicit
transactions.
d) Investors exhibiting unusual or unexplained transaction patterns or behaviour.
4.3. Once identified as high-risk, we subject these investors to enhanced due diligence
measures.
4.4. Enhanced due diligence may include seeking additional information, conducting
background checks, obtaining external reports, and seeking approval from senior
management before proceeding with any transactions.
4.5. We continuously monitor high-risk investors throughout the duration of their
engagement, keeping a close eye on any changes in their circumstances or behaviours
that may raise further concerns.
