Allotts Financial Services Ltd Data Privacy Notice

Updated August 2018

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We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how, why and what personal data we collect, store and use and in what circumstances we share personal data. This privacy notice also provides details of your rights in relation to your personal data together with information of how to contact both ourselves and the relevant supervisory authorities in the event you have a complaint.

Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how, why and what personal data we collect, store and use and in what circumstances we share personal data. This privacy notice also provides details of your rights in relation to your personal data together with information of how to contact both ourselves and the relevant supervisory authorities in the event you have a complaint.

Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document..


Who we are

Allotts Financial Services Ltd are Independent Financial Advisors. We are a company registered in England and Wales under company number 07465711. Our registered office is at The Old Grammar School, 13 Moorgate Road, Rotherham, S60 2EN. Allotts Financial Services Ltd is authorised and regulated by the Financial Conduct Authority under their register number 564185.

In our work as Independent Financial Advisors we need to collect and use certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.

When we mention "Allotts", "we", "us" or "our" we are referring to Allotts Financial Services Ltd. 
As part of our work we provide our clients with the following services:-

  • Regular proactive meetings at our offices or on request at the location of your choice within reasonable travelling distance.
  • Fact finding to update personal circumstances and assess financial objectives.
  • Review of existing holdings.
  • Risk profile assessment.
  • Asset allocation review.
  • Market research.
  • Client report detailing solutions.
  • Implementation of recommendations.
  • Monitor of holdings.
  • Generic market reports.
  • Professional introduction service.
  • Valuations on request at no extra charge.
  • Access to your financial advisor by telephone, email or letter.
  • Online access to portfolio if portfolio is on a ‘platform’.

 

The personal data we collect and use

In the course of providing our service to our clients we may collect the following personal data:

  • contact information
  • identity information
  • financial information
  • employment status
  • lifestyle information
  • health information
  • ethnicity
  • marital Status
  • details of any vulnerability
  • criminal Convictions
  • details of your dependents and/or beneficiaries under a policy (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.)
  • attitude to risk
  • product details
  • personal Bank Account Details
  • contents of relevant wills

 

Information collected from other sources

We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
By way of example the personal data we obtain from other sources may include the following:

    • From lenders and/or product providers:
      • product details
    • From identification and verification checking agencies:
      • identity information
      • sanction check information

    Special category data

    Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

    We may process:

    • health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
    • Criminal conviction or offence information when providing intermediary services in relation to a general insurance product

     

    How we use your personal data

    We collect information about you to provide you with the services for which you engage us.

    The below table sets out:

      • how we use your personal data
      • the lawful bases upon which we collect and use your personal data
      • who we routinely share your personal data with

      How we use your personal data

      In addition to the above we may also be processing personal data for :-

      • Legitimate interests such as for the purpose of the establishment, exercise or defence of legal claims.

      Or

        • Due to a legal requirement such as ensuring that in the course of our activities we have appropriate safeguards and procedures for money laundering in relation to the prevention, detection and investigation of financial crime and dishonesty.

         

        Marketing

        We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. When identifying such products and services outside a particular client engagement we will only use your personal data where we have obtained your prior consent in accordance with any marketing preferences you have provided to us.

        You can opt out of receiving our marketing communications at any time. If you wish to amend your marketing preferences please either use the unsubscribe link on our marketing emails or alternatively contact us in any of the following ways:

        • By phone: 01709 828400
        • By email: fsd@allotts.co.uk
        • By Post: The Old Grammar School, 13 Moorgate Road, Rotherham, S60 2EN

         

        Whether information has to be provided by you, and if so why

        We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.

         

        How long your personal data will be kept

        We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.

        How long your personal data will be kept

         

        These are minimum periods, during which we have a legal obligation to retain your records.

        We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 20 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, subject to the restrictions of our regulatory obligations and legitimate interests as noted above. 

         

        Sharing personal data with third parties

        From time to time Your Personal Data will be shared with:

        • Investment Providers/Mortgage lenders 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 privacy notice, such as to progress your investment/mortgage 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

        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.

        You have a right to ask us for more information about the safeguards we have put in place. To learn more, please see ‘Your rights’ below.

         

        Your rights

        You have legal rights under data protection regulation in relation to your personal data. These are set out under the headings below:

        • To access personal data
        • To correct / erase personal data
        • To restrict how we use personal data
        • To object to how we use personal data
        • To ask us to transfer personal data to another organisation
        • To object to automated decision making
        • To understand how we protect information transferred outside Europe
        • To find out more about how we use personal data
        • The right to withdraw consent to the processing of personal data

        We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

        We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive.  Where a fee is necessary, we will inform you before proceeding with your request.

        We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests.  We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about. 

        We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

        To access personal data
        You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

        To rectify / erase personal data
        You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.
        You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
        You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
        We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligations or where we need to use your personal data to establish, exercise or defend legal claims. 

        To restrict how we use personal data
        You can ask that we restrict our use of your personal data in certain circumstances, for example

        • where you think the information is inaccurate and we need to verify it;
        • where our use of your personal data is not or no longer based on one of the permitted lawful bases but you do not want us to erase it;
        • where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
        • where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

        We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

        To object to how we use personal data
        You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

        To request a transfer of personal data
        You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).
        You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

        To contest decisions based on automatic decision making
        If a third party made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by that third party produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where the third party are authorised by law to make such decisions and have adopted suitable safeguards in their decision making processes to protect your rights and freedoms.

        To obtain a copy of our safety measures for transfers outside of Europe
        You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the European Economic Area. We are not required to share details of these safeguards where sharing such details would affect our commercial position, or create a security risk.

         

        To find out more about how we use personal data

        If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.
        If you would like to exercise any of the above rights, please:

          • email our Data Controller at DataController@allotts.co.uk or write to our Data Controller at The Old Grammar School, 13 Moorgate Road, Rotherham, S60 2EN. 
          • let us have enough information to identify you, e.g. name, address, date of birth;
          • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
          • let us know the information to which your request relates.

           

          Keeping your personal data secure

          We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

          We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

           

          Our supervisory authority

          If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).

          We ask that you please attempt to resolve any issues with us before contacting the ICO.

           

          How to contact us

          Please contact our Data Controller if you have any questions about this privacy notice or the information we hold about you. If you wish to contact our Data Controller, please send an email to DataController@allotts.co.uk or write to The Old Grammar School, 13 Moorgate Road, Rotherham, S60 2EN.

           

          Glossary of Terms


          we, us or our

          Allotts Financial Services Ltd a company registered in England and Wales company number 07465711 and having its registered office at The Old Grammar School, 13 Moorgate Road, Rotherham, S60 2EN.

          contact information

          these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address

          data controller

          means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services

          data protection regulation

          applicable data privacy and protection laws

          employment status

          this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance

          FCA

          the Financial Conduct Authority, being the independent watchdog that regulates financial services

          financial information

          this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60

          health information

          this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history

          identity information

          this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number

          intermediary services

          these are the services we provide to you in relation to the products

          lenders

          a mortgage lender (for a list of current lenders which we work with, please contact us – see How to contact us above)

          lifestyle information

          this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits

          product

          this is an investment, pension, mortgage, protection and/or general insurance product in respect of which we provide intermediary services to you

          product provider

          a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above)

          sanction check information

          this is information relating to  politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering 

          vulnerability

          a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care.  These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence)