Chartham Financial Planning Limited is an appointed representative of Best Practice IFA Group Limited (Best Practice). We are committed to protecting and respecting your privacy. This privacy notice explains how we use any personal information we collect about you.
For the purpose of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (collectively the “Data Protection Laws”) the Data Controller is Chartham Financial Planning Limited.
Best Practice assist us with various aspects of our compliance activity, including Financial Conduct Authority compliance, Anti-Money Laundering checks and data protection. In order that Best Practice can provide these services, we are required to send across personal data we have collected. More information about how Best Practice will use your personal data can be found in their Privacy Notice at [https://www.bestpractice.co.uk/best-practice/privacy-policy/].
What information do we collect about you?
We collect information about you for the purpose of fulfilling our contractual obligations to you as detailed in our Client Engagement, or to meet a pre-contractual request, for example, providing a quotation. This information will relate to your personal and financial circumstances which may vary but will usually include:
• name, date of birth, postal & email address, gender, bank details, tax identifiers and other information about your financial affairs, tax affairs, assets and liabilities.
It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us. 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 will use your information collected from the website to personalise your repeat visits to the site.
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 will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Should we need to process children’s personal data, we will generally only process a child’s name and date of birth, unless further details are required to fulfil a service that you have specifically requested. Examples might include establishing investments for or on behalf of the child, school planning purposes or to establish health or life insurance. Whenever we collate information for children, we would always explain why the information is needed. Where a child is party to the contract or over the age of 13, we would always consider the child’s capacity to understand the contract they are entering into. We will never use the child’s personal data for marketing purposes.
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 the “performance of a contract with the data subject”. The information that we collect about you is essential to carry out the services that you require from us. In all other circumstances we rely on “legitimate interest” and our legitimate interests are the improvement of our services and /or the prevention or detection of fraud. This includes verifying your identification for the prevention of money – laundering and other financial crime. Without collecting your personal data, we would be unable to fulfil our legal and regulatory obligations.
To comply with our legal obligations as an authorised representative of an FCA regulated entity, including preparing and sending reports, and submissions to Best Practice or the FCA, “Compliance with a legal obligation” will be the lawful basis on which we will rely when carrying our regulated activities.
Special Categories of personal data includes, but is not limited to, racial or ethnic origins, political opinion, religious or similar belief, trade union membership, your physical or mental health. Where special category data is required we will obtain your explicit consent to collect and process this information.
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?
If you agree, we may email you about other products or services that we think may be of interest to you.
We will not share your information for marketing purposes with other companies.
To deliver our services to you effectively we routinely pass on your information to Best Practice, who provide us with various compliance services. We may also pass on your information 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 will have a contract in place with them to ensure that the nature and purpose of the processing is clear. The organisations to whom we may pass your details also have their own obligations to deal with your personal information appropriately and act in accordance with our written instructions. Sometimes, a product or service may be administered in countries outside Europe (such as India and the USA) that do not always have the same standard of data protection laws as the UK. However, they are required to 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, this may be transferred electronically (e.g. by email or over the internet) and we, or any relevant third party, may contact you in future by what we believe to be the most appropriate means of communication at the time (e.g. telephone/ email /letter etc.). We will use appropriate security measures to protect your personal data in transit.
How long do we keep hold of your information?
Chartham Financial Planning will keep your personal data securely for as long as is necessary for the purpose it was collected.
During the course of our relationship with you we retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to the Financial Conduct Authority’s regulatory requirements to retain your 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 reserve the right to retain data for longer where we believe it is in our legitimate interests to do so.
What are your rights?
You have the right to erasure and request deletion of your personal data. This does not provide an absolute right to be forgotten but does provide for the right, in certain circumstances, to have personal data erased and to prevent further processing. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email or write to us using the contact details noted below.
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 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 would like to send you information about our products and services which may be of interest to you. If you agree to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If this is the case, please contact The Data Protection Office on 01372 891129 or in writing at The Bullpen, Bulrushes Business Park, Coombe Hill Road, East Grinstead, RH19 4LZ.
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.
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
Tel: 0303 123 1113 (local rate)
How to contact us