We are committed to ensuring that your privacy is protected at all times. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you comply with any changes. This policy was last updated on 18.07.2018.
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 or 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 Investment and/or Insurance requirements 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 investment and/ or insurance 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 investment and/ or insurance requirements 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 subject.
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 / ethical investments, 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 / investment 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.
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 investment and/ or insurance. You will 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 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 (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/or Insurance 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 lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment 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
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment Providers 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, 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 investment and/ 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.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
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 indefinitely.
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: James Glasheen
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.
What Are Cookies & Why Are They Beneficial?
Cookies often store your settings for a website, such as your preferred language or location. When you return to the site, your browser sends back the cookies that belong to the site. This allows the site to present you with information customized to fit your needs.
Cookies can store a wide range of information, including personally identifiable information (such as your name, address, email address, or telephone number). However, this information can only be stored if you provide it – websites cannot gain access to information you didn’t provide to them, and they can’t access other files on your computer.
How Do Cookies Help?
They make our website work as you’d expect
They improve the speed & security of the website
They continuously improve our website for you
They make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)
Our Cookies Don’t..
Collect any personally identifiable information (without your express permission)
Collect any sensitive information (without your express permission)
Pass personally identifiable data to third parties
More About Cookies:
There is no way to prevent these cookies being set other than to not use our site.
Third Party Functions:
Our website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Disabling these cookies will likely break the functions offered by these third parties.
Anonymous Visitor Statistics Cookies:
We have a number of partners who promote our service on a success-only basis (i.e. instead of paying for advertising, we pay them commissions on sales). Cookies are required to allow us to reward these partners and these cookies are usually provided by specialist companies (known as affiliate networks). Neither us, the networks, or the partner advertising or recommending our services are able to identify you personally. We ask you to support us by allowing these cookies that ultimately help us to offer you the service we do at the price we do.
Turning Off Cookies:
You can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies, you can learn how here. Doing so however will likely limit the functionality of ours and a large proportion of the world’s websites as cookies are a standard part of most modern websites.
Here are links to information about cookie settings relating to the most commonly used browsers:
It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.
Cookies In Use On Our Website:
Google Analytics Cookie – These enable us to recognise repeat visitors to the site. By matching an anonymous, randomly generated identifier, we’re able to record specific browsing information such as how you arrive at the site, the pages you view, options you select, and the path you take through the site. By monitoring this information we’re able to make improvements to our sites. We use Google Analytics software to analyse page use, page interactions and the routes our customers take through our site. We don’t record any personal information you provide.
Session Cookie – These enable you to carry out some essential functions on our sites, such as maintaining log in details for the session or a transaction. They also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session.
Suite 007, 6 Queen Street,
Huddersfield, West Yorkshire.
01484 907000 / 07980 308868
We Are Proud To Be Part Of The Huddersfield Town FC Associate Programme. Keep A Look Out For Us At Kirklees Stadium.
Registered Address: 158 Penistone Road, Waterloo, Huddersfield, West Yorkshire HD5 8RN. Registered in England & Wales. Company Number 10078492. James Glasheen Financial Planning Limited is authorised and regulated by the Financial Conduct Authority. FCA Number 746378.