Data Protection Commissioner
Data Protection Commissioner

Registry Details for 'Citco Fund Services (Ireland) Ltd'

Company Name: Citco Fund Services (Ireland) Ltd
Ref Number: 5672/A
Reg Type: DC+DP
Company Address: Block 6 Custom House Plaza International Financial Services Centre Dublin 1
Contact: AlanBurke
Purpose: (a) As administrator of investment funds, Citco Fund Services (Dublin) Limited ("CFSD") collects and maintains identification documentation containing personal data on all investors for anti-money laundering ("AML") purposes - CFSD collects more personal data than is required by the funds for AML purposes as the funds are mostly domiciled outside of Ireland (in the Cayman Islands whereas CFSD is established in Ireland and therefore subject to Irish AML laws and regulations and its own global KYC policy which all require CFSD to collect more identification documentation from all investors and clients that would be required by the funds themselves under Cayman Laws
(b) CFSD receives and holds personal data on the directors founder shareholders of the funds which it takes on
(c) CFSD also collects personal data on his employees
(b) CFSD receives and holds personal data on the directors founder shareholders of the funds which it takes on
(c) CFSD also collects personal data on his employees.
Continuation Due Date: 14/08/2018
Description:
(a) AML documents CFSD collects (for its own AML purposes) and all the extensive documentation required under the attached global policy of the group to which it belongs. This policy goes beyond what is required under the laws and regulations applicable to the investment funds which are clients (mainly funds domiciled in the Cayman Islands) and CFSD is therefore more than a processor and is actually a Data Controller with regard to the AML documents it collects and maintains.
(b) AML documents on the investment fund clients themselves before delivering services CFSD collects indentification documentation on all the directors and certain founder shareholders of the fund entities before they even become clients and in this respect CFSD is not acting as a data processor at all and only as a data controller. CFSD also receives similar AML documentationn from its group affiliates worldwide.
Disclosees: (a) and (b) All data subjects of the identification documentation have already provided written consent to disclosure of their personal data to fund's manager, investment manager, auditors, lawyers and affiliates of CFSD. In certain cases, the data subjects have also consented to disclosure to other third parties such as the fund's distributor and its affiliates as well.
Transfers Abroad: Yes
Country: Netherlands, Bahamas, Bermuda, British Virgin Islands, Cayman Islands, Netherland Antilles (Curacao), Luxembourg,U.S.A, Australia, Canada, Singapore, - Description of Data: Identification documents. - Description of Data: Identification documents. - Purpose of Transfer: Comply with anti-money laundering laws and regulations applicable to CFSD and its affilitaes worldwide which go above those required by the funds themselves.