Why should you read our Privacy Statement?
While dealing with us, we will ask you to provide 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 essential as it allows us to explain what we do with Your Personal Data, and the various rights you have.
What do we mean by “Your Personal Data”?
- Your Personal Data means any information that describes or relates to your personal Your Personal Data may identify you directly, for example, your name, address, date of birth and 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 relating to your financial arrangements your Personal Data may include:
- Your 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 about the processing we may undertake relating to this type of information)
- Any pre-existing investment, pension, mortgage/finance and insurance products and the terms and conditions relating to these
The basis upon which we will process certain parts of Your Personal Data
We only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances, where:
- we need to perform the contract we have entered into with you
- we need to comply with a legal (or regulatory) obligation
- it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights don’t override those interests
- we have your consent
When we speak with you about your financial arrangements and requirements, we do so on the basis that both parties are entering a contract for the supply of services. 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:-
- Where you ask us to assist you with for example your insurance needs, in particular, life insurance and insurance that may help 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 to make enquiries of insurance providers about insurance products that may meet your needs and to provide you with advice and 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 relate 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 historical 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, 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.
- Depending on the instructions we receive from you, we may pass your data to other professionals and financial service/product providers to enable us to provide advice most suited to your circumstances.
- We may share your information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets or who are stakeholders or investors in our business. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this notice.
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 a 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 broader compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data to meet a legal compliance or other regulatory obligation to which we are subject.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly from you. You will usually provide information during our initial meetings and conversations to establish your circumstances and needs and preferences about your desired financial products and services. You may 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 we will only do this if we have consent from you for our nominated processor or us to access your information in this manner. With regards to electronic ID checks, we do not require your consent. We may also collect data about you and your family from third parties, such as product providers who you hold policies with.
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, both in paper form and online 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 in response to any queries you may have about any financial product you may take out, or to inform you of any developments about those products and policies of which we might become aware
- Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment, pension and insurance providers
- Third parties who we believe will be able to assist us with your enquiry or application, or who can 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, tax advisers or surveyors
- In each case, your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress the service you have agreed for us to undertake
- 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 encourage you to take reasonable steps to safeguard your own privacy when transferring information to us, such as ensuring confidential information sent by email is password protected or encrypted and only using secure methods of postage when sending original documentation.
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 to such information we will keep records indefinitely.
Your rights about Your Personal Data
- You can request copies of Your Personal Data that is under our control
- You can ask us to explain further how we use Your Personal Data
- You can 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)
- You can ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- You can 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 to exercise any of your rights set out within it, please contact Gerard Burrows, our Data Protection Officer, here at the office.
If we feel we have a legal right not to deal with your request, or to act in a 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 regulatory obligations.
If you feel dissatisfied with how we have handled your data you may raise a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection regulator. The ICO can be contacted through their website at https://ico.org.uk/global/contact-us/ ,by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or by telephone on 0303 123 1113.
© Sterling Financial Services Ltd.
9 Clarendon Street,
Tel: 0115 9584115
Registered in England and Wales No. 4047196.
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