Why should you read this document?
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 of 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 social identity.
In the context of providing you with assistance in relation to your financial affairs, 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 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 information)
- 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
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
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
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
promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you,
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
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
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,