This Privacy Notice explains how we use any personal information that we collect about you.
What information do we collect about you?
We collect information about you when you engage us for financial planning, investment management, pensions advice, financial protection etc. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services. We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this Privacy Notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to effectively carry out the services you require from us. Without collecting your personal data, we would also be unable to fulfil our legal and regulatory obligations. Where special category data is required, we will obtain your explicit consent to collect and process this information.
How will we use the information we collect about you?
We will use the information we collect about you in order to provide you with the services for which you engage us. If you agree, we may send you information on other products or services which we believe may be of interest to you.
Who might we share your information with?
We won’t share your information with other companies for marketing purposes. In order to deliver our services to you effectively, we may send your details to third parties such as those we engage for professional Compliance, Accountancy or Legal services, as well as product and platform providers that we use to arrange financial products for you. Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions. Where it’s necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit, for example via password protection of electronic files and/or encryption of data.
To fulfil our obligations in respect of Anti-Money Laundering and other Financial Crime, we may send your details to third party agencies for identity verification purposes.
How long do we keep your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re are 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-outs
- 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. In any case, we will review the retention of your data after six years from the date your relationship with us ends.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interest as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please email or write to us using the contact details noted below. When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use. 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 feel is incorrect.
Cookies & Other Websites
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site and to compile statistical reports on website activity. For further information please visit www.allaboutcookies.org You can set your browser to not accept cookies and the above website tells you how to remove them from your browser. However, in a few cases, some of our website features may not function as a result. Our website contains links to other websites. This Privacy Notice only applies to our website, so when you follow links to other websites, you should read their own privacy notices.
From time-to-time we may send you information about our products or services which may be of interest to you. If you agree to receive this, you may opt out again at any time. You have the right, at any time, to stop us contacting you for marketing purposes. To do so, please contact us by email or post.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 1st May 2018.
How to contact us
Please contact us if you have any questions about our Privacy Notice or information we hold about you, by email; firstname.lastname@example.org or write to us.
What can you do if you are unhappy with how your personal data is processed?
You have the right to lodge a complaint with the supervisory authority for Data Protection. In Northern Ireland this is;
The Information Commissioner’s Office – Northern Ireland
14 Cromac Place
T: 02890 278757 (Local Rate)