Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to Pension, Investment or Insurance requirements, Your Personal Data may include:
• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• 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 (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing Pension, Investment or Insurance products and the terms and conditions relating to these
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Pension, Investment or Insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from Insurance and other Product providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with, for example, your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance and investment providers in relation to products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable clients to secure the important insurance protection to meet their needs.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to Pension, Investment or Insurances. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, ID checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, we will only do this if we have consent from you for us or the processing service we are using to access your information in this manner. With regards to electronic ID checks, although we would not require your consent, we will inform you of how such software operates and the purpose for which it is used if you wish.
A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user’s computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.
This website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of our website and compile reports for us on the activity on our website.
How to restrict or delete cookies
The cookies we use are essential for parts of the website to operate, some may have already been set. You may delete and block all cookies from this website, but please be aware that restricting or deleting cookies may impact on the functionality of the website. Your web browser may allow you to restrict or delete cookies set by this website. The Help function within your browser should tell you how. Alternatively, you can visit www.allaboutcookies.org which provides general information about cookies and how you can manage cookies on your computer.
Use of Third Party Testimonial Gatherers
At certain times we may ask our clients consent to provide online testimonials or reviews about the service they have received from Financial Planning Concepts. We always protect our clients’ identity by ensuring that full names are not provided in the reviews.
How Secure are your details?
When you register your details, we will take all reasonable steps to keep these details secure and free from unauthorised access by use of technology and internal systems which will be updated as new technology becomes available and is appropriate to our systems.
Third Party Sites
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems. This information can only be accessed by employees within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
• Submit Your Personal Data to relevant Product Providers both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that providers may raise
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any pension, investment or insurance policy you may take out, or to inform you of any developments in relation to those products and polices of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
• Investment & Pension Providers and Insurance companies.
• 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, providers of legal services such as estate planners or similar professionals (only when 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 Client privacy notice, i.e. to progress your Pension, Investment 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, and as otherwise set out in this Client Privacy Notice.
We will only share information required on a confidential basis and only when the recipient has undertaken to be bound by the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679). This also applies in the event that your data is shared outside the European Economic Area.
Security and retention of Your Personal Data
We respect that your privacy is important, and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take all the reasonable steps we can to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
In order to protect your Data, we ask that you also take reasonable steps to safeguard your own privacy when transferring information to us. For example, please do not send confidential information over unprotected email, please ensure email attachments with confidential data are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or when we are required to keep the information longer we may retain records indefinitely.
Your rights in relation to Your Personal Data
• request copies of Your Personal Data that we hold and is under our control
• ask us to further explain how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish
• change the basis of any consent you may have provided to enable us to market to you in the future.
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Our ICO registration number is Z9934318.
Withdrawal of Consent
If at any time you wish us – or any company associated with us – to cease obtaining, using, processing and disclosing personal data about you (including any communication for marketing purposes), please contact us in writing to withdraw your consent:
Please write to:
Financial Planning Concepts Ltd, 4 Walsingham Place, Truro, Cornwall, TR1 2RP
We need to draw your attention to the fact that if we are unable to store your data on our computer records or make contact with you we will be unable to act for you after withdrawal of consent. If you are unsure about how we use your data or wish to vary the consent you are welcome to discuss this first.
You are entitled to have access to your personal data held by us, this is subject to certain exceptions.
Whether you are an executive, professional, business owner or retiree our adviser Jerry Wellington will be able to review your current situation and agree with you a better way forward which will generally simplify matters and bring clarity to your financial future.
We look forward to hearing from you. Call us on 01872 278588 to arrange a meeting, at our cost, or email us at , we very much look forward to meeting you.
Financial Planning Concepts Ltd is Authorised and Regulated by the Financial Conduct Authority.
Financial Services Register Number 620075. Registered in England & Wales, Company Number 5907482.
Registered Office address: 22 Victoria Road, St Austell, Cornwall, PL25 4QD.