Corinthian House, 17 Lansdowne Road, Croydon, Surrey CR0 2BX
We are committed to protecting your personal information and ensuring that it is used fairly and responsibly. This is our Policy which will advise how we collect and use the personal information that you supply us with. By submitting your data to us, it is implied that you have given us your permission to use your data under the terms of this policy
Our Contact Details
If you have a query about any aspect of this Policy or wish to have any part of it clarified, please contact us.
Goddard Perry Consulting Limited, Corinthian House, 17 Lansdowne Road, Croydon CR0 2BX
Tel: 020 8603 3700 Please ask for Steve Goddard Email: email@example.com
Goddard Perry Consulting Limited are Data Controllers registered with the UK Information
Commissioner’s Office (ICO). You can find the details in the Public Register of Data Controllers on the ICO’s website at www.ico.gov.uk
Purpose of Processing
We need to collect information about you, and where applicable any corporate circumstances to provide financial planning advice and employee benefit consulting advice. This information may relate to personal and financial circumstances.
Generally, we collect information directly from you but we may also obtain information from third parties, such as your employer, your other professional advisers (e.g. accountant, solicitor), HMRC and credit reference agencies. When you provide us with personal information relating to others, (e.g. your dependants) you confirm that you have their consent or are otherwise entitled to provide this information to us and for us to use it in the ways described in this Policy.
Furthermore, your data will be accessible by the firm should you use the Personal Finance Portal (PFP). This software is available via Intelligent Office which is the firm’s chosen client management system. We encourage clients to use the PFP as this is a secure system for transferring documents between us and you, the client. It is also a secure messaging system. Lastly, this system can also be accessed to use the Open Banking feature which enables you to link payment accounts which you access online (such as current accounts and credit card accounts) so that you can review your finances all in one place. You will also be able to view all of your transactions across each of those accounts. You will be able to categorise your transaction data in the PFP.
You consent to us being able to see (through PFP) the balance of each of your accounts selected for this service and the total balance across those accounts.
You should note that if this system is selected, the account information collected from your bank or other account provider cannot be checked for accuracy, so neither the firm nor Intelligent Office can ensure that the information provided to you through the PFP is accurate. We, and Intelligent Office, have no responsibility for the service provided to you by your bank or other account provider.
Why We Need to Collect and Use Your Personal Data
The primary basis for which we use your data (and data about your family’s circumstances where relevant) is for providing advisory services. The information we collect about you is essential for us to be able to carry out the services that you require from us effectively. Also, without collecting your personal data we would not be able to fulfil our legal and regulatory obligations.
Recipients of Personal Data
We may send your personal information as set out as follows:
- By post to your nominated address.
- To your nominated email address.
- To enable us to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you. We, and any third-party specialist advisers to whom we introduce you, may pass your data to organisations when you agree to purchase or amend policies and products.
- To fulfil our obligations in respect of prevention of money laundering and other financial crime we may send your details to credit reference agencies to verify your identity. The reference agency will check the details supplied by you against particulars on any database (public or otherwise) to which they have access. The agency will add a note to your credit file to show that an identity check has been made, but only you will be able to see this. It will not be disclosed to any third parties and it will not affect your credit rating.
- To legal and regulatory authorities or any third party when required to do so. For example, to comply with a court order, or in connection with suspected money laundering or other serious crime, or to respond to any request from either a UK or overseas regulator.
- Your advisers, for example your accountant, tax advisers, solicitor or other specialist advisers.
- To companies who provide a service to us. For example, data processing companies who help us maintain and develop our computer systems and compliance companies who help us with our regulatory compliance obligations.
Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our instructions.
We may need to collect sensitive personal data including information about your health, ethnic origin, or criminal prosecutions from you and third parties such as employers and credit reference agencies, fraud prevention agencies and other similar organisations in order to provide you with the services, for example where you require advice on protection or annuity products.
To provide our financial planning services, we must ensure we understand your health, beliefs, and other factors to ensure we are able to provide you with the most appropriate advice and products. This means that we may obtain your sensitive personal data from the third parties referred to above for the purpose of providing you with the services and share it with third party providers to obtain quotes on your behalf for example where we are providing you with annuity or protection advice as part of our services.
We believe that we can obtain and hold sensitive data about you under the lawful basis of ‘Legal Claims’.
Security of Data
We are committed to ensure that your personal information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to keep it safe and secure. This includes a variety of electronic security measures such as passwords, firewalls and data encryption techniques.
Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our instructions. Sometimes a product or service may be administered from a country outside Europe. If this is the case, the firm must put a contract in place to ensure that your information is adequately protected.
Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit.
We undertake to review the data we hold on you on a regular basis to ensure compliance with data protection law. In the course of any review, we will:
- Delete any data which is trivial or transitory in nature, or which in our opinion is no longer required for the purposes set out above.
- Update the data to ensure that any errors or inaccuracies are corrected.
- Archive data as detailed below.
- Subject to the data retention periods, as detailed below, securely delete the data when it is identified that we no longer need to hold it.
We may retain and process your data for the following periods. In the event that more than one period applies to the same data, we will retain the data to the last such period to expire:
- We will hold any agreements between you and us for a period of 6 years from the termination or expiry of the agreement unless we have been notified of any claim or circumstance which might give rise to a claim under or by reference to such agreements.
- We will process data relating to investments which we have provided advice on and / or arranged for you. We will process such data throughout the entire period you are and remain a client of the firm and for a period of not less than 6 years following our ceasing to provide service to you in regard to those investments. In the case of long-term investments we may process your data until the date of maturation of such long-term investments.
- We will hold data as required by any Regulator until the end of any limitation period imposed by that Regulator, which in the case of the Financial Conduct Authority is currently 6 years for all types of business undertaken except for Occupational Pension Schemes, which can include Defined Benefit Transfers and Scheme Money Purchase Transfers, whereby the data retention period is indefinite.
- We will hold data as required by any relevant third party until the end of any limitation period imposed by that relevant third party, which in the case of HMRC shall be 7 years, unless we are notified that any period is considered “open” by HMRC in which case it will be until we are notified the period is “closed”.
- We will hold data as required for the purposes of any legal proceedings for a period of 6 years following the conclusion of any such proceedings unless a longer period is required pursuant to any court rule or enactment. Proceedings will be taken to have concluded on the expiry of any period given for appealing any final judgment or on the date of concluding any settlement staying all relevant claims if the proceedings were settled before judgement.
- Save for the above, we will hold data for a maximum of 50 years from the date we receive the data.
Rights of Individuals
You have a right to request a copy of the personal information we hold about you. If you would like a copy of some or all of your personal information please write to us at the address given at the end of this document. We will provide you with the personal information you have requested within one month from date of request. We do not charge for this service.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to make sure your personal information is accurate and up to date. You may ask us to remove, update or correct any information you think is inaccurate.
Marketing and Your Right to Withdraw Consent
If you agree, we may wish to contact you by telephone, email or post about other products or services that we think may be of interest to you. We do not share your information for marketing purposes with other companies.
If you have agreed that we can contact you for marketing purposes you can change your mind easily by contacting us by email or post as detailed at the beginning of this policy.
Right to Lodge a Complaint with the Information Commissioner’s Office (ICO)
You have the right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Telephone 0303 123 1113 (local rate)
Regularly Review and, where necessary, Update our Privacy Information
We keep our Policy under regular review and we will place any updates on our website. You may also contact us for an up to date version.
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