For details of our firm and how to contact us, please refer to our website footer.
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing 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 what we will need to do with Your Personal Data, and the various rights you have in relation to it.
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly — for example, your name, address, date of 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 assistance in relation to your financial affairs, Your Personal Data may include:
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 in this notice.
Alternatively, 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 mortgage lenders, insurance providers and 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 occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject.
Where you ask us to assist you with, for example, your insurance — in particular life insurance and insurance that may assist you in the event of an accident or illness — we will ask you for information about your ethnic origin, health and medical history ("Your Special Data"). We will record and use Your Special Data in order to make enquiries of providers in relation to insurance products that may meet your needs, and to provide you with advice and guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems relating to those children, and potentially 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 ("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 notice. Such information must be capable of being exchanged freely between insurance intermediaries such as our firm and insurance providers, to enable customers to secure the important insurance protection their needs require.
We will collect and record Your Personal Data 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 your financial affairs — verbally and 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 voters' roll. If we use technology solutions to assist in the collection of Your Personal Data — for example, software that verifies your credit status — we will only do this with your consent for us or our nominated processor to access your information in this manner. With regard 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.
In the course of handling Your Personal Data, we will:
From time to time Your Personal Data will be shared with:
In each case, Your Personal Data will only be shared for the purposes set out in this notice — to progress your enquiry and provide you with our professional services. This sharing does not entitle such third parties to send you marketing or promotional messages: it is shared solely to ensure we can adequately fulfil our responsibilities to you.
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it 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 sending original documentation.
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 a legal right to such information, we will retain records indefinitely.
You can:
If you have any questions or comments about this notice, or wish to exercise any of the rights set out within it, please contact our firm via the contact details on our website and ask for the person responsible for data protection.
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible if you become 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 about how we have handled Your Personal Data, or believe our processing does not comply with data protection law, you may lodge a complaint with the UK's data protection regulator, the Information Commissioner's Office (ICO).
Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: 0303 123 1113
Website: ico.org.uk
Our website may contain hyperlinks to websites owned and operated by third parties. This Privacy Notice does not apply to those other websites. We encourage you to read the privacy statements on the other websites you visit, as they will govern the use of any personal data you provide when visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites, and your use of such websites is at your own risk.
This Privacy Notice may be updated from time to time, so you may want to check it each time you provide personal data to us.