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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 or 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
In the context of providing you with assistance in relation to your financial affairs, Your Personal Data may
- 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
- Any pre-existing 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 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 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 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. 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, in particular life insurance and 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 of providers in relation to insurance products 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.
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 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 in relation to your financial affairs. 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. 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, mobile devices and on our computer systems for
example websites, email, hard drives, and cloud facilities. 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 Lenders 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 your
financial affairs, or to inform you of any developments in relation to those products and/or polices of
which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Product Providers / Lenders
- 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 your enquiry 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 legal right to such information we will retain records indefinitely.
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)
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 firm via the contact details within this 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 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.
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Certain cookies are necessary in order for you to use our websites. These are used ‘in-session’ each time you visit and then expire when you leave the site. They’re not stored on your computer and they don’t contain any personal data. However, you can delete them via your browser if you wish to, but this will restrict the functions that you’re able to carry out on our sites.
These enable you to carry out some essential functions on our sites, such as maintaining log in details for the session or a transaction. They also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session or logout of certain areas.
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Managing your cookies
You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.