What information do we collect about you?
We collect information about you when you engage us for financial planning services. This information will relate to your personal and financial circumstances. 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 our website to personalise your repeat visits to the site.
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. Any relevant marketing activity we undertake is done because as a firm we have a legitimate interest to do so. However, you have rights, as listed below, which impact how we can use and process your data.
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 would also be unable to fulfil our legal and regulatory obligations.
Where special category data is required, we will obtain your explicit consent, in order to collect and process this information.
This type of personal data is sensitive by nature and includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health. Depending on the nature of the products and services that you engage us for we may need to obtain your sensitive personal data particularly in relation to health.
What personal information do we collect?
Personal information includes your name, address, or phone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, visit a financial advisor, visit a website we may have or register to receive one of our newsletters.
The type of personal information we collect will depend on the purpose for which it is collected and includes:
- Contact details
- Information to verify your identity
- Family, lifestyle, health and financial information
- Payment details
We collect personal information directly from you. For example, we ask for personal information at the start of our relationship and in subsequent communications, in order to check your identity and protect you and us from fraud. This is a legal requirement and is important to help safeguard you against potential crime.
We may also collect information when you complete a client survey, provide feedback, or request literature, guides, or further details regarding our services.
Information about connected individuals
So that we can provide our services effectively, we may need to gather personal information about your close family members and dependents. In such cases, we rely on you to have obtained the consent of the people concerned, to pass their information on to us. We will be happy to provide them with a copy of this Notice upon request.
How we protect information
The security and confidentiality of your personal information is extremely important to us.
All personal data which is collected and recorded, whether on paper or electronically, has appropriate safeguards applied in line with our legal obligations.
Data is protected by our internal policies and procedures, which are designed to minimise loss or damage through accident, negligence, or deliberate actions. Our employees undertake regular training in relation to data protection and are subject to duties of confidentiality which apply to the personal data we obtain and process.
Our information security controls are aligned to industry standards and good practice. This provides a secure control environment that effectively manages risks to the confidentiality, integrity, and availability of information. Additionally, our controls ensure we can restore your data in situations where the data is corrupted or lost in a disaster recovery situation.
Where appropriate, we use encryption or other security measures which we deem suitable to protect your information. We also review our security procedures periodically and will consider relevant new technologies and updated methods. But, despite our reasonable efforts, no security measure can ever be perfect or impenetrable.
If you would like more details, or are concerned about a particular issue, please contact us (see later section ‘How to contact us’ for details).
Handling telephone calls and other electronic communications
We retain copies of electronic communications for record keeping, monitoring and quality purposes, the provision of our services and for audit and training purposes. We may record telephone or internet/video calls, access to which is restricted to those individuals who have a need to access them for the purposes set out here.
How will we use the information about you?
We collect information about you 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 companies outside our group of companies.
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 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 written instructions.
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. 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 should not be held for longer than is required under the terms of our contract for services with you.
However, we are subject to regulatory requirements to retain data for specified minimum periods. 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 will not retain your personal data for longer than three years past the time of your death.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
Your rights in relation to Data Protection
You have rights under data protection laws in relation to how we process your information. These are summarised below, however If you are unhappy with the way in which we process your data, you may contact the UK’s supervisory authority for data protection at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Tel: 0303 123 1113 (local rate)
Right to be informed
You have a right to receive clear and easy to understand information on what personal information we have, why we have it, and who we share it with.
Right to access your information
Subject to certain exceptions and exemptions, you are entitled to request a copy of the information we hold about you.
Where your personal data is processed by automated means, you have the right to request that we 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, so please ask us to correct or remove any information you feel is incorrect.
Right to request erasure
You can ask for your information to be deleted or removed, which will be done where there is not a compelling or regulatory/legal reason for us to retain it.
Right to restrict processing
You can ask us to block or suppress the processing of your personal data for certain reasons. This means that we are still permitted to keep your information, but only to ensure we do not use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal data for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way; for example, if you were moving your pension or savings account to another provider.
Right to object or withdraw consent
You can object to us processing your personal data, in which case we must cease to do so unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms; or for the establishment, exercise or defence of legal claims.
Where we are processing your personal data with your consent, this can be withdrawn at any time. This might, however, limit or remove our ability to act in accordance with the prevailing terms of engagement between us.
Marketing
We would like to send you information about our products and services which may be of interest to you. If you have agreed 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 you no longer wish to be contacted for marketing purposes, please contact us by telephone, email or post.
Cookies
We use cookies to track visitor use of the website and to compile statistical reports on website activity.
For further information visit 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.
Other websites
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
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, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Changes to our privacy policy
We keep our privacy policy under regular review, and we will place any updates on our website and inform you of any changes when they occur.
How to contact us
Please contact us if you have any questions about our privacy policy or the information which we hold about you:
By email at: [email protected]
Call us on 01228 210 137
Or write to us at: Vesta Wealth Limited, Minerva House, Port Road Business Park, Carlisle, Cumbria, CA2 7AF.
(last updated 28/09/2020)