What information do we collect about you?
We may collect and process the following data about you:
- Information that you provide during advice meetings with your adviser, or by corresponding with us by phone, email or otherwise. The information you give us may include but is not limited to:
- Name, date of birth, gender, nationality, civil/marital status, contact details, address and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits).
- 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
- Any pre-existing pension, investment, mortgage or insurance products and the terms and conditions relating to these.
- In the event that you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our web site and the areas that you access. Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information. You should be aware that you have the right to withdraw this consent at any time.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
In order 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.
Where third parties are involved in processing your data we’ll 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’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods these are generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than deemed necessary. In any case we will not retain your data for longer than 25 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, where possible, and subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you (subject access request). If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
You have the right to data portability. This allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. Should you request the data we hold about you, we will endeavour to do it in a compatible format, for your own purposes.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We’d like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
If you agree, we may email, telephone or text you about other products or services that we think may be of interest to you.
If you agree, we’ll pass on your personal information to our group of companies so that they may offer you their products and services.
We won’t share your information for marketing purposes with companies outside our group of companies/other companies.
You have a right at any time to withdraw consent and stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
Automated decision process
There may be some occasions where we us automated decision making processes, for example in assessing your attitude to risk and your capacity for loss. Should you object about any automated decisions made about you using the personal data you’ve provided, we will respond to your enquiries in person.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate)
How to contact us
Or write to us at;
True Bearing Limited
2 Buckshaw Court
East Terrace Business Park