This privacy notice explains how we use any personal information we collect about you and our data protection policy.
Why we collect and use your personal data
We collect and use your personal data in order to provide you with the financial advice and help arrange financial products you have asked us to.
We also need this information to meet our legal and regulatory obligations including anti-money laundering and sanctions checks.
How we collect personal data
We collect your personal information in a number of ways:
- Primarily this will be directly from you at meetings or via other communications including post, email and telephone
- With your authority, we may also collect information on your financial arrangements and products directly from the providers
- With your permission, we may use credit reference agencies to verify your identity
- We may use publicly available data to collect information, for example Companies House
- Information relating to your visits to our website is collected using cookies, see below
What information we collect about you
We may collect the following types of information:
- Personal – name, date of birth and contact details
- Nationality and residency
- Tax and National Insurance
- Financial – investments, life insurance, pensions, income, loans etc.
- Contacts with you – notes of meetings and telephone calls and copies of emails and letters
- Website – cookies when you visit one of our websites and Internal Protocol (IP) address
- Information classified as ‘special category’ personal information e.g. relating to your health, where necessary for advice on certain products and services or to comply with our legal obligations. We will obtain your explicit consent to process such information
- Family members and other people e.g. joint applicants or beneficiaries for services you have with us or products we advise on. Children are not able to buy products and services from us or to hold most types of investment. However, a parent or guardian can, and a child can also be named as a beneficiary on some funds. In these cases, we collect and use limited personal information to identify the child, such as their name, age, gender.
- Where you provide information on family members or other people, it will be your responsibility to ensure that you have the consent of the people concerned, to pass their information on to us. We can provide a copy of this privacy notice for them or, where appropriate, you can pass the privacy information to them. If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our services.
How we use the information about you
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with
We will not share your information, for marketing purposes, with other companies. In order to deliver our services to you effectively we may send your details to third parties, primarily product providers that we use to arrange financial products for you. 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, such as encryption of data, secure emails or password protection of attachments to emails. With your consent we may use a credit reference agency to verify your identity. We may need to provide information on you to our professional indemnity insurers in the event of a claim.
How long we hold your information
During the course of our relationship with you we will retain personal data for as long as it is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship. We are also subject to regulatory requirements to retain your data for specified minimum periods. The Financial Conduct Authority requires that records of our advice are kept, in most cases, for at least five years. This is the minimum period we are legally obliged to retain your records and we may retain the information for longer. In some cases, such as that relating to pension transfers, we must keep records indefinitely. You have the right to request deletion of your personal data. We will comply with this request, subject to regulatory obligations and legitimate interests as noted above.
How you can access the information we hold about you
You have the right to request a copy of the information that 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 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 think is incorrect.
Our website collects cookies, such information is completely anonymous and does not identify you personally. It is statistical data about our visitors and their use of our website.
You can set your browser not to accept cookies and the website below tells you how to remove them from your browser. For further information visit
Where your information is processed
The information we hold on you is processed by us solely in the UK
Your individual rights You have various rights in relation to how we use your information. They are:
1. Right to be informed
2. Right of access
You have the right to know what personal data we process and to be provided with access to the information. If you wish to receive a copy of the personal information we hold on you, you may make a subject access request.
3. Right to request that your personal information be rectified
If your personal data are inaccurate or incomplete, you can require that they are corrected.
4. Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for us to retain it.
5. Right to restrict processing
You can ask to block or suppress the processing of your personal data for certain reasons. This means that we are still permitted to keep your information but only to ensure we do not use it in the future for those reasons you have restricted.
6. Right to data portability
You can ask for a copy of your personal data for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way, for example, if you were changing financial adviser.
7. Right to object or withdraw consent
You can object to us processing your personal data where it is based on our legitimate interests, in which case we can no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. You can object at any time to our use of personal data relating to you in connection with our direct marketing with a view to attracting you as a client. Where you do so, the personal data shall not afterwards be processed for such purposes. Where your personal data is processed for direct marketing purposes, you will have the right to object at any time to it being processed for such marketing including profiling. Where we are processing personal data about you with your consent you can withdraw it at any time. However, where you do, it may not be possible for us to continue to offer services to you.
8. Rights related to automatic decision making including profiling
You have the right to ask us to:
- Give you information about processing of your personal information
- Request human intervention or challenge a decision where processing is done solely by automated processes
- Carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
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If you require any more information on your rights and how to exercise them, please contact us
How to contact us
6, Brunswick Terrace
01223 313 337
Making a complaint
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate)
Last updated April 2019