Customer Privacy Notice
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 with your personal advice requirements, your Personal Data may include:
Title, name, 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.
Special Category Data. For example, health status and history, details of treatment and prognosis and medical reports. (Further details are provided below with regard to the processing we may undertake in relation to this type of information).
Details of any pre-existing investment, protection or mortgage products 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 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 arrange the products you require, we have the right to use Your Personal Data. We also need this in order to be able to provide you with fully and properly personalised advice, tailored to your specific circumstances.
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, regulators, 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. 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
When discussing your financial plans we will need to ask you about your ethnic origin, your health and medical history (Your Special Category Data). We will record and use Your Special Category Data in order to ensure we recommendations and use products that meet your needs fully. For example, health information can have an impact on underwriting for life cover, as well as on life expectancy when considering investments and pensions. We need to be able to ensure that we have sufficient information about these points to ensure that the products recommended are fully suited to your individual needs.
If you have parental responsibility for children under the age of 13, we may need to record information on our systems that relates to those children and potentially, to their Special Category Data. This might be necessary if you had a child with a long-term health problem or disability, for example.
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 (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use Special Category Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice. Information on Special Category Data and Criminal Disclosures 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 that their needs require.
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 and needs and preferences. You will provide information to us 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. We may need to 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 need to conduct an electronic ID check to comply with anti-money-laundering rules. This will include a Politically Exposed Persons (PEP) and Sanctions check. On some occasions we may ask you to supply a Passport or Driving Licence number, as this can be required to complete an electronic ID check.
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, mobile devices and on our computer systems. 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 Your Personal Data to Product Providers and Mortgage Lenders, both on paper 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. This will also enable us to verify your identification with the Provider, should any queries need to be resolved.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to any product or policy you may take out, or to inform you of any developments in relation to those products 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, Mortgage lenders and Insurance 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. i.e. to progress in helping us to meet your financial 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.
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 the legal right or regulatory requirement to hold records indefinitely for complaint handling purposes.
Your rights in relation to Your Personal Data
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).
Some data is provided jointly, for example on a joint mortgage. If we are later asked by just one person to provide a copy of the data held, we will also need consent from the other person. This is because joint personal information provided for advice and applications cannot later be separated out.
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 our principal firm:
The Data Protection Officer, Rosemount Financial Solutions (IFA) Ltd, Rosemount House, 2-4 Chequers Road, Basingstoke, Hampshire, RG21 7PU. Tel: 01256-405460.
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.
Please keep this Privacy Notice stored safely along with the Client Agreement and any other advice related documents that you receive later in the process. The Declaration page on your Client Agreement makes reference to this Privacy Notice. Your declaration and signature will confirm your consent for us to process your personal data for the purposes stated in this Customer Privacy Notice.
Future contact with you
As part of ensuring that our advice to you remains suitable over the longer term, we may need to contact you in future. As an example, we may need to do this if we have recommended a fixed term mortgage deal, where the term is shortly coming to an end.