Privacy Policy Statement

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 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 Your Personal Data.

What do we mean by “Your Personal Data”?

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. Your Personal Data 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 Investment/Retirement/Estate Planning/Later Life requirements, your Personal Data may include:

  • Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
  • 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 pre-existing plans where you have provided us with authority or information, for example, this could be details of your mortgage, protection policies, investment accounts, pension plans.

The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your Investment, Retirement, Estate Planning or Later Life  requirements 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 implement the solutions recommended for you, we have the right to use Your Personal Data for the purposes detailed below.

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 various types of 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.  In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are 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 insurance, investment or pensions and in particular life 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 (Your Special Data). We will record and use Your Special Data in order to make enquiries with the relevant providers in relation to product/solution researched that may meet your needs and to provide you with advice/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 that relates to those children and potentially, to their Special Data.

How do we collect Your Personal Data?

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, needs and preferences in relation to Investment/Retirement/Estate Planning/Later Life requirements. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit status, information from your employer, and searches of information in the public domain such as the voters roll and Companies House.  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 Your Personal Data in our paper files and computer systems (email, hard drive and cloud facilities). This information can only be accessed by employees and consultants within our Firm as well as any outsourced administration support we have in place, only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service we are providing to you, in order to achieve your requirements.
  • Submit Your Personal Data to any relevant product providers sourced, 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 that lenders and providers may raise.
  • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any products/solution sourced that you wish to implement, or to inform you of any developments in relation to those products/solutions and/or polices of which we might become aware.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

  • Insurance/Investment/Pension/Long Term Care Providers.
  • 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 where we believe this to be required due to your particular circumstances).

In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, to address your Investment/Retirement/Estate Planning/Later Life requirements and to provide you with our professional services.

Please note that this sharing of Your Personal Data 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 Personal Data 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 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 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 whereby we have a 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
  • ask us to further explain how we use Your Personal Data
  • ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
  • ask us to send an electronic copy of Your Personal Data to another organisation should you wish
  • 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)

Cookies

Our website uses cookies to distinguish you from other users. A cookie is a small text file written to your hard drive that contains information about you. Cookies do not contain any Personal Data about users.  We use traffic log cookies to identify which pages are being used enabling us to monitor which pages visitors find useful and which they do not and in so doing we can improve our website in order to tailor it to customer needs.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you set up your browser to reject the cookie, you may still use the website.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.  By using this website, you consent to the processing of Personal Data about you by Google in the manner and for the purposes set out above.

Website and Internet Disclaimer

This website is a guide on advice and does not try to recommend specific investments. Please speak to us regarding the suitability of any advice.

Where there are third party links to other sites, for instance calculators or budget tools, please be aware that we are not responsible for the content on these sites, you should see a pop-up warning you of this before proceeding to external sites when this is the case.

We cannot be held liable for any loss caused to you by use of these external sites.

Website and Internet Liability

Due to the nature of the internet, any liability we may have for any losses or claims arising from an inability to access our website, or from any use of our website or reliance on the data transmitted using our website, is excluded to the fullest extent permissible by law. In no event shall we be liable for any loss of profit, revenues, goodwill, business, opportunity, anticipated savings or other indirect or consequential loss of any kind in contract, tort (including negligence) or otherwise arising out of use of the website.

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: Lisa Footes, Footes Financial Planning UK Ltd, Innovation Centre, 1 Devon Way, Longbridge Technology Park, Birmingham, B31 2TS. Telephone: 0121 222 5655 or email: customer.svs@footes-financialplanning.co.uk

If we feel we have a legal right not to deal with your request, or to action it in 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 on you 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.