Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your circumstances, your financial situation and, in some cases, your health and family health history (“Your Personal Data”). This document is important as it allows us to explain to you the various rights you have in relation to these details.
What do we mean by “Your Personal Data”?
This means any information that relates to your personal circumstances. This may identify you directly, for example your name, address, date or birth, National Insurance number. It may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with advice in relation to your financial arrangements it may also include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Information related to family members, your children including minors, and financial dependants
- Employment and remuneration information (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any existing investment products and polices that you hold and the terms and conditions relating to these
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your financial affairs we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Either in the course of initial discussions with you, or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers or our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received. On occasions, we may need to use it to meet the contractual responsibilities we have to our regulator, The Financial Conduct Authority, or for wider compliance with any legal, compliance, or other regulatory obligation to which we might be subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your financial needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (this is referred to within the GDPR regulations as ‘Special Data’). We will record and use the information in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice on the suitability of any product for you.
If you have parental responsibility for children under the age of 18, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences, known as “Criminal Disclosures”. This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information relating to both must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the insurance protection they require.
How do we collect Your Personal Data?
We will collect and record the information from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to financial arrangements. You may also provide information to us in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the Electoral Roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store the information in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
- Submit the information to providers of financial services both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues they may raise.
- Use the information for the purposes of responding to any queries you have raised in relation to your financial products/policies, or to inform you of any developments in relation to those products and/or polices of which we might become aware
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment Providers, Insurance Providers Mortgage lenders, and Finance lenders
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to our Compliance Advisers, Product specialists, Estate Agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case only where we believe this to be required for your particular circumstances).
Please note that this sharing of information does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve your details being transferred outside of the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep the information secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard such details being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances where we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
You can request copies of Your Personal Data that is under our control or, ask us to further explain how we use the information or to correct, delete or require us to restrict or stop using it (details as to the extent to which we can do this will be provided at the time of any such request), or ask us to send an electronic copy of the details to another organisation should you wish.
You can change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety).
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Stephanie Evans – firstname.lastname@example.org
If we feel we have a legal right not to deal with your request, or to action it in different way to that requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.