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This regulatory notice is for your information. You do not need to take any action.

The purpose of this notice:

One of the requirements of General Data Protection Regulation (commonly called GDPR) is that we provide you with details of how we process your personal data.  Processing includes obtaining, recording or storing personal data and carrying out any tasks using the personal data.

Why we need your data:

We need your data in order for us to:

  • Provide financial planning services to you which may include making recommendations for investments and financial products. To do this we would undertake a detailed analysis of your personal circumstances and requirements.
  • Comply with our regulatory obligations imposed by the Financial Conduct Authority (FCA) to ‘know our clients’ and to retain information about you for purposes of audit and review. We will also need to keep records of transactions we have undertaken for prescribed periods of time as directed by the FCA.
  • Respond to any legitimate legal requests for information about you. For example in response to a request from the FCA, to comply with money laundering regulations or a court order.
  • Carry out our legitimate business and professional management responsibilities. This includes monitoring and reviewing levels and types of business that we undertake, assessing business risks or investigating and resolving complaints.

Your Data

Where we collect data directly from you, we will undertake:

  • To set out in our Client Agreement the purposes for which the data is to be processed.
  • To inform you of the recipients of data. For example, if we provide your accountant with information for your tax return we will obtain your permission before sharing the information.
  • In the event that the data controller (the entity that holds your personal information) proposes to transfer the data to a country other than those covered by the GDPR, to provide you with details of the safeguards surrounding such transfers and how to obtain a copy of them.

Your Rights

You may:

  • request access to your personal data
  • object to, or withdraw consent for, the processing of the data
  • obtain rectification of inaccurate data
  • prevent data processing for the purposes of direct marketing
  • object to decisions being taken by automated means and to have the logic behind those decisions clearly explained
  • claim compensation for damages caused by a breach of GDPR
  • request data erasure

Where you exercise your right to request (via email or post) access to your personal data, 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 the requirements of any Regulator or contract, we will let you know:

  • Whether you are legally required to provide such data, and
  • The consequences of failing to provide such data

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:

  • As soon as practicable after obtaining the data and in any event within 1 month
  • At the time of our first communication with you using the data
  • When the data is first disclosed to another person

We shall not be obliged to provide you with the information:

  • Where you already have this information
  • Where we are subject to an obligation of professional secrecy prohibiting the disclosure of the information
  • Where disclosure would render impossible or severely impair the achievement of the reasons for which the data is to be processed. In such cases, we will do what we can to protect your rights and freedoms with respect to our processing of the data

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:

  • Online: ico.org.uk
  • Phone: 0303 123 1113

Sensitive data (Special category data)

We may need to collect sensitive personal data including information about your health, ethnic origin, or criminal prosecutions from you and third parties such as credit reference agencies, fraud prevention agencies and other similar organisations in order to provide you with advice on areas such as protection or annuities.

We may obtain your sensitive personal data from third parties and share it with third parties to obtain quotes on your behalf.

To provide our financial planning service we must ensure we understand your health, beliefs and other factors so we can give you the most appropriate advice. 

We believe Data Protection legislation allows us to obtain and hold your sensitive data for suitable product recommendations under ‘Legal Claims’ provisions.

Holding your data:

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:

  • Delete any data which in our opinion is no longer required for the purposes set out above.
  • Update the data to ensure that any errors or inaccuracies are corrected.
  • Archive data as detailed below.

We will retain your data for as long as we consider necessary to provide services to you, to defend ourselves against any claims and to satisfy our legal and regulatory obligations.

Archiving data:

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.

Data portability:

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 machine-readable format, or transfer the same to a new data controller nominated by you.

Whom we may share your data with:

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 companies listed below, 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:

  • Compliance and Training Solutions Ltd (Compliance consultants)
  • Software Into Action (IT consultants)
  • Intelligent Office (back office software)

Legal Terms:

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.