This page explains how and why personal data submitted through this website may be used.

As explained on the home page, Dame Elizabeth Gloster (the “Independent Investigator”) has been appointed to lead an investigation into issues connected with the regulation by the Financial Conduct Authority of London Capital & Finance Plc (the “Investigation”). In conducting the Investigation, it will often be necessary for the Independent Investigator to process information about individuals that relates to the Investigation and the matters covered by the Investigation.

This privacy notice applies to personal data that is included in information submitted to the Independent Investigator through the routes described on the submissions page of this website.

In this Privacy Notice ‘personal data’ means any information about a living identifiable individual who can be directly or indirectly identified from that information.

The personal data the Independent Investigator may use

In order to properly undertake the Investigation, the Independent Investigator will be required to collect a wide range of varied information. The types of personal data that the Independent Investigator is likely to mainly use include names, contact details, personal opinions, financial information and allegations, but the Independent Investigator may process any other personal data that you submit. It is requested that you minimise the personal data that you include in the information you submit and that you only submit personal data that is relevant to the Investigation. The remit of the investigation is described on the ‘Remit of the investigation’ page of this website. It is not anticipated that any special categories of personal data will be relevant, but it is possible that such information may be included in information submitted to the Independent Investigator through this website.

Why the Independent Investigator uses this personal data

The Independent Investigator will use this personal data solely for the purposes of conducting the Investigation. Further information about the Investigation and its remit is set out on the ‘What is the investigation’, ‘Remit of the investigation’ and ‘FAQs’ pages of this website.

The lawful basis for using this personal data

The Independent Investigator will use this personal data under Article 6(1)(e) of the General Data Protection Regulation (it is necessary for the performance of a task carried out in the public interest). The Independent Investigator does not anticipate that any special categories of personal data will be relevant to the Investigation and it is requested that you avoid submitting special categories of personal data unless absolutely necessary. Depending on the information submitted, it is possible that some special categories of personal data may be included. To the extent that the Independent Investigator uses any special categories of data as part of the Investigation, this will be done under Article 9(2)(g) of the General Data Protection Regulation (it is necessary for reasons of substantial public interest).

The ‘special categories of data’ are specifically listed in the General Data Protection Regulation. They include race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, or information about a person’s sex life or sexual orientation. You may also hear people refer to sensitive personal data to mean the same thing. 

Sharing personal data as part of the Investigation

Personal data may be transferred to:

•        the Independent Investigator’s professional advisers, including the Independent Investigator’s lawyers, Dechert LLP, and the Independent Investigator’s communications specialists, Lansons, to the extent such information is relevant to their performance of their services; and

•        service providers, such as IT providers, where such information is relevant to their performance of such services.

The Independent Investigator may also need to share your personal data with a regulator or to otherwise comply with applicable law or judicial process or if the Independent Investigator reasonably believes that disclosure is necessary to protect the Independent Investigator’s rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

Transfers of personal data outside the EU and the UK

The Independent Investigator is based in the UK. Personal data submitted through this website will be received and processed in the UK and it is not intended that personal data will be transferred out of the UK.

Data Retention

The Independent Investigator will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and the Independent Investigator’s legitimate interests in maintaining such personal information in the Independent Investigator’s records. The duration for which personal data is retained will depend on the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which your personal data is processed and whether those purposes can be achieved through other means, and the applicable legal requirements.

In some circumstances your personal data may be anonymised so that it can no longer be associated with you, in which case it will no longer constitute personal data.

Once your personal data is no longer required for the purposes for which it was collected, it will be securely destroyed in accordance with applicable laws and regulations.

Your rights

Under the General Data Protection Regulation, you have rights as an individual which you can exercise in relation to the personal data held by or on behalf of the Independent Investigator, which can be exercised in certain circumstances. For example, the rights to:

  • request access to, and deletion or correction of, information about you
  • object to the way in which information about you is used and request restriction of the way in which information about you is used
  • request that your personal data be transferred to another organisation
  • complain to the Information Commissioner’s Office if you are unhappy about the way information about you is used

If you wish to find out what personal data, if any, the Independent Investigator holds about you or if you wish to exercise any of your other privacy rights, you can contact the Independent Investigator using the contact details in the ‘Contact’ section below.


The Independent Investigator, Dame Elizabeth Gloster, is a ‘data controller’ in respect of the personal data submitted through this website. The ‘data controller’ is the person that decides the purposes for which and the means by which personal data is used.

You can contact the Independent Investigator using the following contact details:


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