What information do we hold about you and why?
The only information we hold about you is information you have provided to us along with details about your financial products. This information is necessary for us to be able to advise you appropriately and open and run the products you require. We keep this within a “client file” in our secure electronic filing system and there are no paper copies retained.
When you originally engage us to provide you with financial planning and/or advice we go through a structured fact find with you to enable you to give us the information we need to advise you appropriately. This information relates to your personal and financial circumstances, your objectives and hopes, your attitude to risk and any existing financial products you hold as well as a statement about your state of health. It also includes, where it results in better planning or advice, personal information about your spouse and children. It is your responsibility to make sure you have their consent to pass this information to us and ensure they have read this document.
We assume that where we are advising a couple (married or living as partners) that you are consenting for the information either of you provides and any future valuations to be shared with both parties unless and until you tell us otherwise (in writing).
Information about people connected with you
We may need to gather personal information about your close family members and dependents in order to provide our services to you effectively. In such cases it is your responsibility to ensure you have the consent of the people concerned to pass their information to us. We will provide a copy of this privacy notice for them or ask you to pass a copy to them.
The legislation categorises any information about your health as “special” and in order for us to collect and hold this information we need your express consent. We only hold the health information that you share with us and that is necessary for being able to advise you best.
Will we share your data?
Yes, with companies we use to deliver our services to you for example product and platform providers and our professional advisers.
And in order to fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies to check your identity.
Where we do share your information we will have a contract in place to ensure that the nature and purpose of their processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures, such as secure email, to protect your personal data in transit.
How long do we keep your information?
During the course of our relationship with you we’ll keep the personal data necessary to provide our services to you. We’ll take all reasonable steps to keep your personal data up-to-date.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.
You have the right to ask us to delete your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How you can access the information we hold about you
You can request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF and their phone number is 0303 123 1113 (local rate).
Keeping the policy up to date