General Data Protection Regulation (GDPR)
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Customer Privacy Notice
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 explains what we do with this data and your various rights in relation to it.
What is “Personal Data”?
Personal Data means any information that describes or relates to your personal circumstances. It may identify you either directly or indirectly. Examples include your name, address, date of birth, National Insurance number, 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 acting as your personal financial planning advisers, 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 dependants
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 investment, pension, mortgage / finance or insurance products and the terms and conditions relating to these
What We Do with Your Personal Data?
Whilst you choose to pay for our services, we have the right to use Your Personal Data for the purposes of:
Completing a Financial Plan (using cashflow modelling software)
Contacting you between pre-agreed Annual Planning Meetings to aid progress of agreed actions and to seek updates on your position
Contacting you as and when appropriate in order to provide personal guidance or recommendations in response to changes in external conditions such as tax rules or relevant legislation
Recommending and setting up specific investment, pension or insurance products on your behalf
Providing ongoing product related administration services and acting as your agent
Contacting you occasionally via email newsletter with generic information or guidance which is relevant to our ability to provide you with the best possible financial planning services and where one to one contact is not practical. For example:
Changes to Values to Vision FP Ltd investment models
Tax year end action reminders
Details of changes to tax rules or legislation such as those announced in the annual budget, news relating to
Staff or other general service changes which affect how we look after our clients
Submit Your Personal Data to Product Providers, 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 providers may raise.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment/finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware
Outside of Any Contracted Service
Either in the course of initial discussions with you (prior to you becoming a client) 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 product providers or 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.
Processing “Special Data”
Where you ask us to assist you with for example your insurance needs, 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 insurance 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.
We will use special Data in the same way as your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data 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 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 investments, pensions, insurances and general financial planning arrangements. You will provide information to us verbally and in writing, including email.
How Do We Store and Access Your Personal Data?
We record and store Your Personal Data in our paper files, on 3rd party financial planning software tools and on our computer systems. These include email servers, hard drives and cloud-based data storage facilities such as Dropbox. With the exception of paper files, all data can be accessed via web-based applications. We also have limited access to this data via mobile devices (notably emails and SMS messages).
This information can only be accessed by employees 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.
Sharing Your Personal Data
From time to time we must share Your Personal Data with (for example):
Investment 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, providers of legal services such as estate planners, (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 investment or insurance 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 (for example, in relation to any regulated recommendations made), 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 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)
Values to Vision FP ltd does not use any of your information for marketing purposes. Nor do we make it available to anyone else expressly for this purpose.
Our only contact with you will be as part of our contractual service commitments (which you can end at any point), or where it is necessary as part of our regulatory or legal accountabilities.
Further Contact & Complaints
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: Nick Lincoln, Values to Vision Financial Planning Ltd.
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.