Privacy Notice 

Introduction

This notice provides you with information concerning our collection and use of personal data. If you have any queries regarding this statement, please do not hesitate to contact us.

What data do we collect & what do we do with it

In order to provide financial advisory services, we will obtain personal information from you concerning your finances, circumstances, objectives and other relevant details. We will collect, store and process this information.

Legal basis

We collect, control and process your personal information because this is necessary to provide you with information, answer any queries you may have and provide services to you. ‘Contractual necessity’ is therefore the lawful basis for collecting, controlling and processing your personal details and potentially, those of your employees and service providers. There is a special category of personal data for which we may require individual consent. We do not normally request or process sensitive personal data unless this is required for insurance underwriting purposes and this includes all insurance – based products. In this case we are permitted to process sensitive or special category data on the basis of ‘necessity to contract’.

Sensitive or special category personal data includes:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Trade union membership
• Genetic data
• Biometric data
• Data concerning health
• Data concerning sex life or sexual orientation

We would discuss with you the need for the provision of sensitive data before you provide this information. The subsequent provision of sensitive personal data will be taken as consent to this processing.

It is your choice as to whether or not you choose to provide us with any personal information, but if you choose not to, we may not be able to assist you.

Sharing your data

In the course of our work with you, where necessary, we will share your personal data with product and service providers. Unless otherwise indicated, we may also share your data with compliance monitoring & support organizations and regulatory bodies who are also ‘Data Controllers’ and registered with a supervisory authority in a satisfactory jurisdiction and on terms which comply with Data Protection law in the UK.

We also use external data processors that will hold information for the following purposes:

• Secure file sharing
• Data backup
• Dissemination of information
• Report writing
• Research

We will not share your personal information with other companies without your express authority, except if the firm is sold or where we are required to do so by law.

Cross border transfer

All our data processing takes place within UK law, but in the event that any processor holds data on our behalf outside of the UK, we will take steps to ensure that it is held in a satisfactory jurisdiction. 

Marketing

The information we collect about you is used solely for the purposes for which it was provided. We will never use your data or share it for marketing purposes.

Retention

We will keep your personal data throughout our business relationship. At the end of any contractual relationship we are required to continue to hold personal data under current legislation for varying periods and in some circumstances indefinitely. We may also consider it necessary to keep data beyond these timescales in order to defend any future legal action. Where we no longer need regular access, we will transfer your data to a secure archive in order to avoid any unnecessary processing.

Your rights

Under data protection law you have the right to ask us for a copy of the information we hold about you, and to have any inaccuracies corrected or removed. You may also ask us to delete or cease processing all personal data held by us or any processor with whom we have shared your data. We may not always be able to comply with a request for deletion, but you can ask us to cease processing your data.

In addition, you have the right to be informed about the data we collect, where is located, with whom it is shared and the processing we undertake. You can question any automated, decision making processes.

To do this, or if you require more information please contact us, our contact details are below.

Complaints

The UK Information Commissioner’s Office is our supervising authority where you can refer any complaints about data protection. For more information, please go to: ico.org.uk.

Contact

For any queries about data protection please contact:

  Email: simon@clearfuturefp.co.uk