In order for us to assist you, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, where necessary, your health and family data. We class this as your Personal Data, and it may include such matters as your name, gender, date of birth, contact details, employment and remuneration information, bank account and credit details, family circumstances, health history and status and any financial transactions that you have entered into.
It is important that you read this statement as it explains what we will need to do with your Personal Data and your various rights in relation to this Personal Data.
When we discuss your financial arrangements and requirements with you, we do so on the basis that both parties are entering a contract for the supply of our services. In order to perform our duties under that contract, we have the right to use your personal data. In addition, during our initial discussions or after any contract between us has come to an end for whatever reason, we have the right to use your personal data provided that it is in our legitimate business interests to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers or our regulator, The Financial Conduct Authority, about the advice we have given to you, or for wider compliance with any regulatory or legal obligation to which we may be subject. Thus, we would be processing your personal data in order to meet a compliance, legal or other regulatory obligation to which we are subject.
Certain parts of your Personal Data are deemed Special Data. These include such facts as your ethnic origin, your health and medical history, and the details of children under the age of 13 for which you have parental responsibility. We may also ask you to disclose details of any historic or current criminal convictions or offences, these being labelled together as Criminal Disclosures. All of these details together are relevant to insurance related activities such as underwriting, claims and fraud management. We will use special data and any criminal disclosures in the same way as we use your personal data generally, as set out in this statement. Information on Special Data and Criminal Disclosures must be able to be exchanged freely between insurance intermediaries like our firm and insurance providers to enable customers to secure the insurance protection they need.
We will collect and record your Personal Data mainly from you. You will usually provide information during the course of our initial meetings so that we can establish your circumstances, needs and objectives in relation to your financial planning. You will provide us with the information both verbally and in writing (including by email). We may also receive information from third parties such as investment and pension providers, your employer and searches of information in the public domain. We will ask for your consent if we use technology to assist in the collection of your data.
We will record and store your personal data in our paper files, mobile devices and on our computer system (which includes cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you or perform any administration tasks associated with that service.
We will submit that information to product providers and insurance companies both in paper form and online via secure portals. The provision of this information to a third party is essential for us to progress applications and or enquiries that we have submitted on your behalf.
We will use your personal data for the purposes of responding to any enquiries you may have in relation to any investment you may take out, or to inform you of any information relevant to those products or policies of which we may become aware.
From time to time your personal data will be shared with investment providers, mortgage lenders, and insurance providers, and third parties who we believe will be able to assist us in supporting your needs as identified. These third parties may include, but are not limited to our compliance advisers, product specialists, legal specialists and accountancy specialists. In each case, your personal data will only be shared for the purpose set out in this privacy notice
Your privacy is important to us and we will keep it secure in accordance with our legal responsibilities. We take all reasonable steps to safeguard your personal data against it being accessed unlawfully or maliciously by a third party. We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as allowing us to send sensitive information to you encrypted, not sending confidential information to us over unprotected email, ensuring that attachments are password protected and only using secure methods of postage when original documentation is being sent to us. Your personal data will be retained by us either electronically or in paper format for a minimum of six years, or in circumstances where we have a legal right to such information, we will retain it indefinitely.
If you have any questions or comments, or wish to exercise your rights in regard to your Personal Data, please contact us by email on firstname.lastname@example.org or telephone us on 01923 479850 and ask to speak to the Compliance Officer.
If we feel we have a legal right not to deal with your request, or action it in a different way, we will tell you at the time of the request. If you have any concerns or complaints as to how we have handled your personal data, you may lodge a complaint with the ICO, the UK’s data protection regulator, who can be contacted by writing to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by visiting their website at https://ico.org.uk/global/contact-us/