We recognise our responsibility to treat your personal information with care and to comply with all relevant legislation, in particular the Data Protection Act 2018 and the EU General Data Protection
Regulation (GDPR) which we refer to as the “legislation” in this document. This notice covers our requirement to provide you with information on how and why we use your personal data and of your rights under the legislation.
We provided you with advice and the means to manage your investments, your pension arrangements and meet your protection needs. In addition, we may offer you mortgage and other credit facilities including Equity Release schemes. Consequently we are classed as the “data controller” which means we process your data. The contact details are shown at the foot of this notice. Your personal data which is limited to the details provided on our data gathering forms, outputs from fund managers, insurance companies and lenders in accordance with the products that you purchase through this business. The data is passed to these organisations who may be data controllers and their own right and may issue you with their own Data Protection Privacy Notices.
We will use personal information about you mainly to: –
• Provide advice and recommendations on investment strategy, protection needs and retirement planning.
• Provide advice on estate planning and the tax implications
• Arrange and administer your investments, pensions and insurance products
• Arrange mortgage and associated credit lending products which may include Equity Release schemes
• Inform you about our products and services;
• Ensure appropriate preventative Money Laundering processes are implemented.
• Statistical analysis.
Some of the personal information we ask you to provide may be regarded as being sensitive as defined in the legislation, e.g. medical data, health data, and about your occupation. This information is required to support applications made to secure the products of your choice, without which the application cannot be completed.
If you give us information about another person, in doing so you confirm that they have given you permission to provide it to us and that we may use their personal data in the same way as your own as set out in this notice.
Legal Basis for processing your Personal Information
We are required to have a lawful basis (as defined in the legislation) to process your personal data and the relevant bases which we use are show in the table opposite.
We may contact you by email, text, telephone, mail or other agreed means to keep you up to date about our products and services. The legislation allows us to do this in our own commercial interests for
certain communications with previous customers. In other circumstances we can only do so with your explicit consent. In all cases you can opt out from receiving such communications at any time.
Disclosure of your Personal Information
As a necessary part of providing you with the services described above we may need to disclose your personal data to other third parties. These include your selected fund managers, the Cofunds or FundsNetwork platforms, Regulatory authorities and the Police or other law enforcement bodies that assist with fraud prevention and detection. We may share information with other third part providers that assist this firm with the internal roles including our accountants, compliance support and IT specialists.
Your data will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. In most cases the period will be for a maximum of 7 years following the dis-investment anclosure of your account with this firm. We may be required to retain the data for a longer period due to business, legal or regulatory requirements.
International transfers of data
We do not presently transfer your personal data to destinations outside the European Economic Area (EEA). Should this become necessary in the future we will ensure that it is treated securely and in accordance with the legislation.
Under the legislation you have the following rights in relation to our processing of your personal data: –
1. The right to be informed about how we use your personal data (This Privacy Notice);
2. The right to see a copy of the personal information we hold about you. (In most cases this will be free of charge);
3. The right to have personal information rectified if inaccurate or incomplete;
4. The right of erasure of your personal information where there is no compelling reason for its continued processing;
5. The right to restrict processing in certain circumstances, e.g. if its accuracy is being contested;
6. The right to data portability which, subject to certain conditions, allows you to obtain and reuse your personal data across different services;
7. The right to object to certain processing including for the purposes of direct marketing;
8. Rights to information in relation to automated decision making and profiling.
If you have a complaint about how we use your personal information, please contact us at the address below. You also have the right to lodge a complaint with the Information Commissioner’s office at any time.
For further information on this Privacy Notice, to access your personal information or to exercise any of your other rights, please contact The Data Protection Officer, Penn Barn, By the Pond, Elm Road, Penn, Bucks HP10 8EQ at email address firstname.lastname@example.org at telephone number 01494 817151