Why should you read our Privacy Statement?
While dealing with us we will ask you, or an appointed representative, to provide detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history. 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. Some of the Personal Data we may process can be more sensitive, such as your physical and mental health history, or any information associated with your cultural or social identity. Such Personal Data is sub-categorised as Special Category Data.
- In the context of providing you with assistance relating to your financial arrangements your Personal Data, including Special Category 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, or an appointed representative, 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 products you require, we have the right to use Your Personal Data, including Special Category 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, or an appointed representative, information about your ethnic origin, your health and medical history (Your Special Category Data). We will record and use Your Special Category 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.
- We may require specific details about your health to provide you an effective financial advice service. For example, we may need to tailor how we provide our service to individuals based on specific needs derived from a health condition.
- 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 Category Data.
- The arrangement of certain types of insurance may involve disclosure by you, or an appointed representative, 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 Category 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, or an appointed representative, 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.
- We will retain sufficient personal data to provide an initial and ongoing financial service, to facilitate necessary client communications and for our legitimate marketing purposes. We will NOT pass on your data to third parties for any marketing purposes.
Either during initial discussions with you, or an appointed representative, or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data, including Special Category 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 about advice we gave you or to contact 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, our auditors, or any other organisation to achieve 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, including Special Category Data, via various sources, but mainly from you or an appointed representative. You will usually provide information during our meetings and discussions to establish your circumstances, 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 electoral register. 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?
Whilst handling Your Personal Data, and Special Category Data, we will:
- Record and store such Data in 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 such 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 such 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.
- Where necessary, share Your Personal Data and Special Category Data.
From time to time Your Personal Data, and Special Category Data, may be shared with:
- Investment, pension and insurance providers.
- Third parties who we believe can assist us with your enquiry or application, or who can support your needs as identified. These third parties may 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, including Special Category 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 sharing of Your Personal Data, including Special Category 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, including Special Category Data
Your privacy is important to us, and we will keep all Data secure and 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, including Special Category Data, will be retained by us either electronically or in paper format for a minimum of six years, or in some instances indefinitely, where we must do so owing to a legal or regulatory obligation.
Your rights about Your Personal Data
- You can request copies of Your Personal Data, and Special Category Data, that is under our control.
- You can ask us to explain further how we use Your Personal Data and Special Category Data.
- You can ask us to correct, delete or require us to restrict or stop using, obtaining, processing or disclosing Your Personal Data, including Special Category 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, including Special Category 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) by contacting our Data Protection Officer.
How to contact our Firm regarding the use of Your Personal Data and Special Category 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 on 0115 958 4115. Or write to the Data Protection Officer, Sterling Financial Services Limited, 9 Clarendon Street, Nottingham, NG1 5HR.
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 contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, including Special Category Data, so 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 is contactable via 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.
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