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Information for Fund Managers


                                                                                                           

Information for Fund Managers

Global Edition

6 February 2023

                                                                                                                

Who we are and what we do

This document is for the information of managers / general partners of hedge
funds, private markets funds and other alternative investment vehicles
(together, “managers” and, individually, a “manager”, or “you”).

“We”, “our” and “us” are the Albourne Group, or just “Albourne”, comprising the
parent company, Albourne Partners Limited (“APL”), its branches and its
subsidiaries from time to time. At present, the subsidiaries are Albourne
America LLC, Albourne Partners (Asia) Limited, Albourne Partners Japan, Albourne
Partners (Singapore) Pte. Ltd., Albourne Partners Deutschland AG, Albourne
Partners (Canada) Limited, Albourne Partners (Cyprus) Limited, Albourne Partners
(Bermuda) Limited and Albourne Cyprus Limited. APL has a branch in Bahrain.

Albourne is an investment consultant that was established in the UK in 1994 and
is wholly owned by current and former employees. Today, it has over 560
employees located in offices worldwide. The principal offices are in London, San
Francisco, Connecticut, Canada, Hong Kong, Singapore, Cyprus and Germany.

Albourne provides research and advisory services in relation to its clients’
investments in hedge funds, private equity funds, real estate funds, real asset
funds, long-only funds, private credit funds, dynamic beta products and other
alternative investments. Albourne works for many prestigious professional
investors around the world, comprising foundations, endowments, sovereign wealth
funds, pension plans, family offices and financial intermediaries. We differ
from many of our competitors because we do not manage any capital and we do not
run a fund of funds.

To complement its research and advisory services, Albourne provides additional
services to its clients. These include:

 * Portfolio Monitoring: Albourne provides periodic monitoring services on
   client portfolios, which can include the use of the client’s information to
   run quantitative analysis on the portfolio and the underlying funds, a
   qualitative assessment of the portfolio and further monitoring by reference
   to Albourne’s fund-level research and externally-gathered news (“Portfolio
   Monitoring”).
 * Implementation: Albourne offers middle- and back-office services
   (“Implementation Services”) to assist clients when they make their
   investments and to monitor and maintain those investments.

Albourne also constructs, maintains and administers indices with respect to
hedge funds, dynamic beta products and private markets funds (each an “Index”,
and together, “Indices”). These Indices are designed to measure the aggregate
performance of a segment of the funds or dynamic beta products universe.

Regulation

A number of the Albourne companies are regulated. APL is authorised and
regulated by the Financial Conduct Authority in the United Kingdom. Albourne
America LLC is registered as an investment adviser with the US Securities and
Exchange Commission. Albourne Partners (Canada) Limited is registered with the
Ontario Securities Commission. Albourne Partners (Asia) Limited is regulated by
the Securities and Futures Commission in Hong Kong. Albourne Partners Japan is
registered with the Kanto Finance Bureau. Albourne Partners Deutschland AG is
authorised and regulated by the Bundesanstalt für Finanzdienstleistungsaufsicht
(BaFin). Albourne Cyprus Limited is authorised and regulated by the Cyprus
Securities & Exchange Commission (“CySec”). APL’s Bahrain branch is licensed and
regulated by the Central Bank of Bahrain.

Data

APL owns and maintains Albourne’s secure internal central database, which stores
both the data used generally in Albourne’s investment advisory business
(“Reports Information”) and, separately, data received from or on behalf of
clients (“Client Information”) in connection with client-specific services
provided to those clients, such as Portfolio Monitoring and Implementation
Services. Reports Information is the source of the information used in
Albourne’s research reports held in the Albourne Castle, which is a secure,
password protected internet portal for Albourne clients. The Castle can only be
accessed by clients who have signed a service agreement with Albourne and, on a
limited basis by selected prospective clients, in each case who have agreed to
treat all confidential information obtained from the Castle as confidential.

Safeguards over data

We conduct pre-employment checks on all new members of staff globally. All staff
are required to comply with strict confidentiality clauses and Albourne’s Group
Compliance Manuals and Policies as part of their employment terms.

Our contracts with clients include strict confidentiality clauses that prohibit
them from sharing our research beyond a pre-agreed client user group. All
Albourne research reports bear confidentiality legends and are watermarked with
the recipient’s name. Given the increasing use of cloud computing storage and
services by entities in the financial sector, Albourne reminds its client Castle
users that any use of such facilities by the client must include safeguards
enabling the client to comply with its confidentiality obligations.

Albourne operates globally and stores data in various countries, including the
UK, US, Hong Kong, Singapore, Cyprus, Canada and Germany. Data is monitored and
secured to industry standards and complies with all relevant regulation.

Albourne Village

In addition to providing investment advisory services, APL runs a free,
non-profit website called the Albourne Village. The Village provides links to
news articles, industry research papers and job postings for the alternative
investment fund community. The Village is run separately from Albourne’s core
investment advisory business and other services mentioned above. Accordingly, we
never post or otherwise disseminate any data obtained in connection with our
fund due diligence activities on or through the Village website.

Our due diligence process

The extent of due diligence carried out by Albourne varies considerably, in
response to client requirements. Any or all of the following steps may be taken:

 1.  We interview portfolio managers to build an understanding of a firm’s
     strategy, investment process, portfolio, management team, risk process and
     performance. Our analysts seek to understand the key drivers of a given
     strategy and the inherent risks involved. This includes an assessment of
     the team and their professional backgrounds.
 2.  We model the fund’s performance against key benchmarks, indices and the
     performance of peer funds. We try to identify correlations if they exist.
     We capture portfolio breakdowns as provided by the manager, review
     underlying investments to support analysis of a fund’s regional and
     industry exposures and provide trends in a graphical format. We also review
     underlying investments to support our analysis of a fund’s strengths and
     issues. We model AUM and fee trends and, for some clients, perform fee
     reconciliations.
 3.  We obtain information concerning the manager and key individuals from
     various sources, including fund documents, surveys and interviews.
     Information obtained may include special category data and criminal records
     data (see “Personal Data / Privacy Notice” at the end of this document for
     further information). We also check the manager and names of key
     individuals against regulatory, legal, subscription and media databases
     (e.g., SEC, FCA, Bloomberg, Refinitiv World-Check, PACER, LexisNexis) to
     confirm matters, such as any regulatory registrations, regulatory status
     and history, litigation and disciplinary records, and to identify issues
     and information that may have an impact on our clients’ investment
     decisions. In some cases, we may seek explanation or clarification from the
     manager or the individual. Information from these searches and enquiries
     may be included in the reports we provide to our clients and selected
     prospective clients.
 4.  We interview the COO, CFO, CCO, CTO and other key individuals involved in
     the middle and back office operations of the manager. The focus is on
     operations, systems and staffing, and our analysts may ask to examine
     certain documents and processes.
 5.  In conducting its research, Albourne does not wish to receive any Material
     Non-Public Information from any person (including, but not limited to, any
     fund, manager or advisor). Please do not provide Albourne with Material
     Non-Public Information concerning your firm or fund or any of its
     investments unless expressly asked by Albourne to do so.
 6.  We contact service providers, including fund administrators, prime brokers,
     auditors and lawyers, to confirm these service providers’ involvement with
     the manager and/or the fund. We also obtain character and professional
     references for key individuals involved with the fund. These references may
     or may not have been provided to us by the manager. We also undertake
     educational and professional qualification verifications and confirm past
     employment history of key individuals at the manager/fund and may also
     engage a background check provider to conduct more detailed checks covering
     items such as litigation records not in the public domain. If we do, we or
     the background check provider may contact the individuals subject to those
     checks directly to obtain further information and to secure any necessary
     consent, if required. Information from these checks and enquiries may be
     included in the reports we provide to our clients and selected prospective
     clients.
 7.  We capture fundraising information such as closing dates and relevant fund
     sizes.
 8.  We review:
     1. investor letters and other communications issued by the manager and
        summarise the key points. We may follow up with the manager if there are
        key changes, e.g., staff departures or changes of strategy or terms.
     2. the financial statements of the fund, report on fund activity and
        performance and identify any issues for follow up. We reconcile the
        fund’s AUM and returns with newsletters and other sources and review the
        Notes.
     3. offering documents, the principal contractual and constitutional
        documents and any supplements thereto, and summarise the terms.
 9.  We review client-specific capital account statements, capital call and
     distribution notices and capture relevant performance activity to support
     portfolio-level performance analysis. We may follow up with the manager to
     clarify client-specific commitment and performance-related information.
 10. The results of our due diligence process are generally contained in written
     reports. Such reports and any associated ratings are only made available to
     our clients and selected prospective clients (on a confidential basis and
     subject to the protections referred to herein) and may contain personal
     data on the key and other individuals connected with the manager, the fund
     or the investment vehicle on which we have conducted due diligence.
     Albourne will not share its reports and any associated ratings with the
     manager or the fund or investment vehicle that is the subject of the report
     and rating.

The process described above also generally applies to any due diligence
conducted for Albourne clients on any other investment (including, but not
limited to, any non-fund investments, e.g., managed accounts and
co-investments).

Albourne Indices

Albourne uses fund and dynamic beta product data provided by managers on an
aggregated basis in its proprietary Indices. Where a fund has more than one
share class, Albourne may include in an Index the returns of a representative
share class only, or alternatively, a composite return series, in either case,
as determined by Albourne.

Albourne may use the daily and historic levels of the Indices (aggregated as
Indices) in internal and external presentations, reports, analyses and marketing
materials, and may also make such daily and historic levels of the Indices
publicly available, such as through publication on its website www.albourne.com,
provided that the names of any Index’s constituents are only available to
Albourne clients on a confidential basis.

Albourne’s clients and Index data subscribers may use the daily and historic
levels of the Indices (aggregated as Indices) in their own internal and external
presentations, reports, analyses and marketing materials.

For the avoidance of doubt, Albourne does not itself, or permit any party,
including its clients, to use any Index in a manner that constitutes a regulated
“use” as a benchmark under Regulation (EU) 2016/1011, the United Kingdom
Benchmarks Regulation or any other similar or equivalent laws or regulations (as
re-enacted, updated or replaced) in any other jurisdiction.

MoatSpace

Hedge fund, private markets fund and dynamic beta product data can be provided
to us using MoatSpace, which is a web portal through which investment managers
can submit information on their funds or client information at the request and
on behalf of investors that are Albourne clients, and complete questionnaires.
Data uploaded to MoatSpace is capable of being verified by the investment
manager submitting the fund information and, in the case of Reports Information,
may be viewed by our clients in Albourne’s reports.

Fund private placement memoranda and other general marketing documents together
with LPAs and fund constitutional documents uploaded to MoatSpace or otherwise
provided to Albourne, will not be provided to any client without a specific
prior approval from the fund or its manager.

Contacts

For questions about due diligence, please contact the sender of this document or
any Albourne analyst with whom you normally correspond. For questions on
MoatSpace, please contact moatspace@albourne.com. For information about
Albourne’s business generally, please contact your local Albourne office,
details of which can be found at www.albourne.com.

Personal Data / Privacy Notice

Introduction

This Notice replaces all prior Personal Data / Privacy Notices of Albourne
Partners Limited (“APL”) and its branches and subsidiaries (together with APL,
the “Albourne Group” or “Albourne”) which may have been previously provided to
you from time to time. Each member of the Albourne Group, whether a branch or a
subsidiary, is in this Notice called an “Albourne Group Company” and,
collectively, the “Albourne Group Companies”. This Notice has been drafted to
comply with the EU General Data Protection Regulation 2016/679 (“GDPR”) and any
replacement or amended laws enforceable in the United Kingdom together with any
and all other applicable privacy laws and standards in those jurisdictions in
which Albourne conducts business (together “Applicable Data Laws”).

In respect of your personal data, Albourne Partners Limited, 16 Palace Street,
London, SW1E 5JD, Tel +44 (0)207 346 7000, is the data controller.

General Notice and Purpose of Processing

Albourne takes its data protection and privacy responsibilities seriously.

Albourne will process personal data concerning you in the due diligence process
as described above including professional or employment-related information
(such as your job title, work address, email address, phone number, licensing
and credentials, and disciplinary records), education information such as
educational records and degree confirmations, and information that may be
provided by you to us in any interviews or in response to our written requests. 
We may also collect publicly available information that is lawfully made
available from federal, state or local government records, such as civil
litigation records and records of criminal proceedings. Albourne processes this
personal data, which may contain data that is special category data[1] and
criminal records data[2], in order to carry on its investment advisory business,
and in particular, undertaking due diligence and analysis on funds, other
investment opportunities, and any associated managers and advisers. Albourne
does so in connection with fulfilling its contractual obligations to its clients
who request such diligence and analysis for the purpose of evaluating investment
opportunities.  

Your personal data may be provided to clients and prospective clients who have
signed appropriate confidentiality undertakings with Albourne. In particular,
your personal data may be included in research reports prepared for clients of
Albourne.

Personal data may be collected from various sources, including meetings, calls,
written communications with you and others, fund documents, the internet
generally, internet search engines, publicly available records, subscription
databases, administrative bodies, and educational institutions. These sources
may include regulatory and disciplinary records, litigation records, and news
and media reports. Such personal data may include special category data
processed in connection with Albourne’s due diligence and analysis activities
together with criminal records data.

If Albourne contacts individuals in search of references in respect of your
professional performance and character, Albourne uses reference contact details
provided by you, by your employer or by third parties which form part of
Albourne’s own network of reference sources.

Albourne may also process your personal data in order to allow it to comply with
its legal and regulatory obligations. Any uses of your personal data other than
those set out in this Notice will be with prior notice or your advance consent,
as required.

Albourne will use your personal data (including special category data and
criminal records data) to:

 * assess your skills, qualifications and suitability to manage investments;
 * make inferences in the due diligence process;
 * maintain records relating to its fund selection process and investment
   advisory business;
 * comply with contractual, legal and/or regulatory requirements; and
 * provide investment advice to clients. 

Please see our Information for Fund Managers Document for more information on
what we do and how we interact with Managers and related individuals.

The bases on which Albourne processes your personal data

The bases on which Albourne will process your personal data will depend on the
type of data being processed and your ordinary place of residence (the “Your
Home Country”).

 * Your personal data that is not special category data or criminal records data

This data will be processed on the basis of the legitimate interest of Albourne
and/or its clients or an equivalent or similar principle in Your Home Country.
Where Your Home Country does not recognize legitimate interest or an equivalent
or similar principle or right (other than seeking your consent) as a basis for
processing your personal data, we will seek your consent to process such data.

 * Your special category data or criminal records data
   * Where we ask for your consent to process your special category data and
     criminal records data, such data will be processed on the basis of your
     consent, in accordance with the terms of Albourne’s Notice and Personal
     Data Consent form;
   * Where we do not ask for your consent to process your special category data
     and criminal records data, this data will be processed on the basis of:
     * where that data is your criminal records data, this data will be
       processed on the basis of a legitimate interest of Albourne and/or its
       clients in combination with the fact that:
       * such processing is required to be carried out in accordance with a
         regulatory requirement forming part of generally accepted principles of
         good practice for investors’ due diligence on the managers of their
         investments;
       * such processing is necessary for reasons of substantial public
         interest;
       * such records having been deemed to have been made manifestly public by
         virtue of you committing the criminal offence for which you have been
         convicted; or
       * such processing is otherwise permitted under applicable laws
         (including, but not limited to, the UK Data Protection Act 2018 and
         those of Your Home Jurisdiction) without your consent.
     * where that data is special category data, this data will be processed on
       the basis of a legitimate interest of Albourne and/or its clients in
       combination with the fact that such information has been manifestly made
       public by you. Where Your Home Country does not recognize legitimate
       interest or an equivalent or similar principle (other than consent) as a
       basis for processing your special category data, we will either seek your
       consent to process such data or not process your special category data.

Your rights 

Albourne will process personal data obtained via its due diligence processes
fairly and in accordance with Applicable Data Laws. In particular, Albourne will
ensure that your personal data is:

 * used lawfully, fairly and in a transparent way;
 * collected only for valid purposes that Albourne has clearly explained and not
   used in any way that is incompatible with those purposes;
 * relevant to the purposes notified to you and limited only to those purposes;
 * accurate and kept up to date;
 * kept only as long as necessary for the purposes Albourne has told you about;
   and
 * kept securely.

If your personal data has been processed by Albourne, you have a number of
rights in relation to how we process your personal data. These include:

 * access (the right to access the personal data Albourne holds about you);
 * rectification (the right to have any inaccurate personal data that Albourne
   holds about you corrected);
 * erasure (the right to delete your personal data where Albourne has no valid
   reason to continue to process it or where you have validly objected to your
   personal data being processed);
 * objection (the right to object to your personal data being processed where
   Albourne is processing such data on the basis of its legitimate interest or
   that of a third party);
 * restriction of processing (the right to ask Albourne to suspend the
   processing of your personal data, for example, if you want Albourne to
   establish its accuracy or the reason for processing it);
 * portability (the right to have your personal data transferred to you or
   another party).

These rights are subject to applicable legal restrictions and Albourne may take
reasonable steps to verify your identity before processing your request. If you
wish to exercise any of these rights, you may contact Albourne’s Personal Data
Protection Officer at dataprotection@albourne.com.

If you are located outside of the United Kingdom (UK) or the European Economic
Area (EEA), you may have similar or additional rights, which are also
exercisable by contacting us.

For the purposes of this section “processing” shall be interpreted in accordance
with the GDPR.

You may withdraw your consent at any time by sending a request to the Personal
Data Protection Officer at dataprotection@albourne.com.

Albourne may transfer your personal data outside of the UK or the EEA or Your
Home Country in order to carry on its investment advisory business, to undertake
due diligence and analysis on funds and to fulfil its contractual obligations to
its clients. Your personal data may be transferred to and between various
Albourne Group Companies globally, and in particular, amongst Albourne’s offices
in the UK, United States, Hong Kong, Japan, Singapore, Bermuda, Canada, Cyprus,
Germany and Bahrain, to Albourne’s clients globally, subject to any
confidentiality agreement Albourne may have with a fund manager, and to
background check providers engaged by Albourne. Albourne shall ensure that,
where a transfer of personal data to a country outside the UK, the EEA or Your
Home Country is necessary, the data are protected by security measures that are
appropriate to the risks presented by the processing and the nature of the data.

Security and Retention

Albourne takes appropriate technical and organisational measures to ensure the
confidentiality and security of personal data it holds or transfers and to
safeguard such personal data against unauthorised or unlawful use and against
accidental loss, damage or corruption.

Albourne maintains a secure computing environment and an application security
process that is monitored and regularly tested. Systems are certified to the
ISO/IEC27001:2013 standard. Albourne makes use of Center for Internet Security
templates and SANS best practice documents.

Albourne’s data centres all offer high levels of physical security. Key to the
resilience of Albourne’s service delivery is that its data centres are
geographically dispersed. If a technical failure occurs in any single data
centre, users are redirected to one of the other data centres. Network services
in the data centres are provided by separate companies, so that a failure on one
company’s network does not affect the other data centres.

While all manager data is kept in Albourne’s data centres, Albourne uses
Microsoft 365 for employee emails and internal document preparation, and
consequently some manager data may be stored on the Microsoft 365 cloud during
report writing. With the exception of emails sent to funds@albourne.com, which
remain on Albourne’s internal email system and are not routed via or stored on
the M365 cloud.

Data is compartmentalised in accordance with appropriate access control lists
and is not transferred outside Albourne except via our extranet websites.
Albourne’s websites are currently rated as “A+” on Qualys’ SSL test and their
security is tested twice every twelve months by an external security firm.

Internal penetration tests are performed regularly on the infrastructure and web
application stack. Pre-employment screening checks are conducted on all
employees.

Albourne will not keep personal data for longer than necessary and will dispose
of any such data securely. Albourne uses a range of IT security tools on its
network in order to protect the information held, including monitoring the
sending of data and documents to recipients outside the network, in order to
detect unauthorised sharing or transmission of personal data or Albourne
confidential material.

Questions or concerns

If you have any questions about how Albourne uses your personal data, please
email dataprotection@albourne.com. 

Should you have cause to complain about how we handle your personal data, please
contact us in the first instance. We will do our best to resolve your concern.
Alternatively, you may prefer to submit a complaint directly to the applicable
data protection authority in the country in which you are located.  For UK
individuals, this is the UK Information Commissioner’s Office (ICO):
https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us/.

Changes

Albourne may update or revise this Notice from time to time and shall notify you
as and when it does so. If Albourne intends to use, process or disclose personal
data for purposes materially different than those described in this Notice,
Albourne will inform you before proceeding with the use, processing or
disclosure.

Notice for California residents

This section provides additional information pursuant to the California Consumer
Privacy Act (“CCPA”) as amended by the California Privacy Rights Act, applicable
to information concerning California residents that constitutes “personal
information” and “sensitive personal information” under the CCPA.

If you are a California resident and the personal data constitutes “personal
information” or “sensitive personal information” under the California Consumer
Privacy Act (“CCPA”) as amended by the California Privacy Rights Act, then
Albourne may “sell” that personal data under the CCPA.

Albourne collects personal information about you in connection with Albourne’s
diligence services for clients who are evaluating potential investment
opportunities. Albourne will provide the information that is gathered on your
behalf to those clients, sophisticated investors evaluating potential
investments with your associated investment firm.

As described in this Notice above, if within the scope of the CCPA, such
personal information includes:

 * your educational, professional and employment-related information, as well as
   inferences drawn from those;
 * your civil litigation and records of criminal proceedings; and
 * identifying information (such as a real name, your alias, postal address,
   email address, unique personal identifiers or other similar identifiers); and

Where you have created a MoatSpace account with Albourne, we will collect your
user name and password, and potentially your internet and electronic network
activity information.

As part of its due diligence, Albourne collects much information from
publicly-available sources.  In the event that sensitive personal information is
provided directly to Albourne, these categories may include: racial or ethnic
origin, political opinions, religious or philosophical beliefs, trade union
membership, genetic data, data concerning health, and data concerning a natural
person’s sex life or sexual orientation.  Where Albourne collects your sensitive
personal information, it is not for the purpose of inferring characteristics
about you. Albourne will attempt to limit the inclusion of this type of personal
information in its reports.

The purposes for which Albourne collects the above personal information and
sensitive information are:

 * to assess your skills, qualifications and suitability to manage investments;
 * to conduct analysis during the due diligence process;
 * to maintain records relating to its fund selection process and investment
   advisory business;
 * to comply with contractual, legal and/or regulatory requirements; and
 * to provide investment advice and due diligence reports to clients. 

Albourne considers a number of factors in its evaluation of the retention period
for your personal information.  These include, but are not limited to,
applicable law and policy that apply to the data. Albourne will not keep
personal data for longer than necessary and will dispose of any such data
securely.  Albourne does not collect your personal information for purposes of
cross-contextual behavioral advertising, as contemplated by the CCPA.

The third parties that Albourne provides your personal data to includes clients
and prospective clients of Albourne, who are bound by certain confidentiality
obligations to Albourne.  We may ask these clients to safeguard your personal
data and to comply with all applicable laws and regulations regarding your
personal data.

A California resident may have the following rights under the CCPA: the right to
know what personal information Albourne has collected about you (including the
categories of personal information, the categories of sources from which the
personal information is collected, the business or commercial purpose, the
categories of third parties to whom the business discloses personal information,
and the specific pieces of personal information the business has collected about
you), the right to delete personal information that the business has collected
from you, the right to correct inaccurate personal information that a business
maintains about you; the right to opt-out of the sale of personal information,
and the right not to receive discriminatory treatment by Albourne for the
exercise of privacy rights (including the right not to be retaliated against for
the exercise of these rights).

To make a request you may email us at dataprotection@albourne.com or contact us
through the webforms listed in Albourne’s privacy statement at
https://www-us.albourne.com/albourne/privacystatement. In most cases, you will
be required to provide your name and business contact information, including
business email address so that we can verify your request, and in some cases
additional information may be required. A California resident also may also have
the right to direct us to not sell the resident’s personal information. To make
an opt-out request, please go to: “California Residents - Do Not Sell My
Personal Info” via this link: https://www-us.albourne.com/albourne/ccpa/optout.

Under the CCPA, California residents may use an authorized agent to make privacy
rights requests. We require the authorized agent to provide us with proof of the
California consumer’s written permission (for example, a power of attorney) that
demonstrates authorization to submit a request for the California consumer. An
authorized agent must follow the process described above to make a request, and
we will also (a) require the authorized agent to verify the agent’s own identity
and (b) confirm the agent’s authority with the California consumer about whom
the request was made.

This Website is not intended for minors under the age of 18.

You can access the Albourne Privacy Policy and Processing Notice (“Privacy
Statement”) at: https://www-us.albourne.com/albourne/privacystatement.


[1]‘Special category data’ includes racial or ethnic origin, political opinions,
religious or philosophical beliefs, trade union membership, genetic data,
biometric data for the purpose of uniquely identifying a natural person, data
concerning health or data concerning a natural person’s sex life or sexual
orientation.

[2] ‘Criminal records data’ includes personal data relating to any proceedings
for any offence committed or alleged to have been committed by a person, the
disposal of such proceedings or the sentence of any court in such proceedings.

Information Security Policy Statement   |  Company Information  |  Terms &
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