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 recommend 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 have 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 submit an enquiry regarding your personal data directly to our Data Protection team.