In order to provide you with financial planning services we will collect and hold personal data about and on you. We are also required to comply with the General Data Protection Regulation (Regulation (EU) 2016/679 (the “GDPR)) and as such hereby set out details as to how we process your data and your rights.
We need your data in order for us to:
Where we collect data directly from you, we will undertake:
Where you exercise your right to request (via email or post) access to data of which you are the data subject, we will undertake to respond to you within 30 calendar days of receipt of your request. There will be no charge for this service unless the request is manifestly unfounded or excessive in which case we reserve the right to charge a fee or refuse to respond.
You may at any time, by giving notice to us in writing, request that we cease to process your data. We will undertake to comply with any such request as soon as is reasonably practicable.
Where the legal basis for the processing of your data is to adhere to compliance with a statutory or contractual obligation, or the necessary precondition to entering into a contract, including compliance with the requirements of any Regulator, we will inform you as to:
Where we obtain your data otherwise than directly from you, you will have the same or equivalent rights to those set out above.
Save in the circumstance as detailed below, we will inform you which source the data originated from and whether it came from publically accessible sources. The information to be provided will be in accordance with the following time periods, whichever shall occur first:
We shall not be obliged to provide you with the information:
You have the right to complain in regard to any aspect of the processing of your data and any breach of the above rights to the relevant supervisory authority, who in the case of the United Kingdom is the Information Commissioners Office, whom may be contacted at:
We undertake to review the data we hold on you on a regular basis to ensure compliance with data protection law. In the course of any review, we will:
We may retain and process your data for the following periods. In the event that more than one period applies to the same data, we will retain the data to the last such period to expire:
We will regularly review data and where in our opinion such data has ceased to be Active we will archive it and process it only as Archived Data. Any data which is deemed Archived Data will only be processed in limited circumstances.
All storage of data, whether Active Data or Archived Data will be in accordance with good industry practice and will be undertaken in accordance with organisational systems and procedures, which will be regularly reviewed, to maintain the security of data.
On the termination or expiry of any agreement to provide services to you and on your written request, we will, subject to our right to retain copies of data for the purposes set out above, agree to return any data you have provided to us in a structured, commonly used machinereadable format, or transfer the same to a new data controller nominated by you.
In order to carry out our legitimate business and to provide you with financial planning services, we have entered into agreements with and will share your information with the following companies, for the purposes of Compliance, IT systems security, data management and control and auditing. Full details of these companies addresses (all UK based) and contact details are available on request:
In addition to the above listed companies you will be notified in accordance with the terms of this agreement as to the name and contact details of the data controller for any other third party entity with whom we share and / or transfer your data and their representative.
From time to time we may wish to contact you with details of other investment, pension or financial products and/or services which we think may be of interest and/or beneficial to you. If you consent to us contacting you for this purpose then please tick the options below in regard to how you would like to be contacted:
If you do not tick any of the above options we will reasonably assume that you do not wish to be contacted by us in regard to additional investment, pension or financial products and services.
We will not use your data for marketing purposes of any sort unless you have expressly given us your prior consent. The use of your data as detailed in the remained of this agreement is not affected by whether you choose to consent to the use of data for marketing purposes.
We may also like to pass on your details to other Investment, Pension or Financial Institutions within the UK so that they may contact you with details of their products and services which may be of interest and/or beneficial to you. If you consent to us passing on your details to third party financial institutions within the UK for this purposes then please tick the options below in regard to how you would like them to contact you:
If you do not tick any of the above options we will reasonably assume that you do not wish to be contacted by any third party financial institutions within the UK in regard to their investment, pension or financial products and services.
Please note that you may withdraw your consent to marketing at any time by giving us notice in writing.
If any provision, or part thereof, of this agreement is found by any court or administrative body of competent jurisdiction to be invalid, unenforceable or illegal, the other provisions shall remain in force.
In the event of any change in Data Protection Law occurring after the date of this agreement which requires the adoption of revised provisions dealing with data retention or portability, the parties will use all reasonable endeavours to agree such consequential changes to this agreement as may reasonably be required to comply with the requirements of Data Protection Law (“Compliant Terms”) and incorporate the same as an amendment to this agreement.
We take your privacy very seriously and will only use your personal information and data to administer the services we have agreed to provide you with, including but not limited to any products or contracts for investments, pensions, life cover, equity release or discretionary investment management services you have made or entered into through our firm.
You are confirming your agreement to these terms.
You are also confirming your marketing preferences as detailed in the ‘Marketing’ section of this agreement whereby you have given your consent, or otherwise, for either us and/or Third Party providers to contact you about additional products and services.
You further acknowledge, that you have been made aware of, and give your consent to, this firm’s policy on sharing your data with other companies as detailed in the ‘Whom we may share your data with’ section of this agreement.