In summary, we collect and use information about you to:
– Deliver our services and meet our legal responsibilities;
– Verify your identity where required;
– Contact you by post, email or telephone about important changes to our services or contact details;
– Maintain our records;
– Prevent and detect crime, fraud or corruption
Personal data is any information which enables the identification of the ‘data subject’ (i.e. the person to whom the data relates), whether directly or indirectly.
In most circumstances the information that we collect about you is restricted to that which is required, or that which may be likely to be required in the future, to provide you with financial advice, for instance:
– Your personal and contact details
– Documentation used to verify the accuracy of information you provide, i.e. proof of identity and/or address etc;
– Information connected to the products or services that you use (i.e. bank account or investment details);
– Information concerning your personal finances, including assets and liabilities;
– Employment status, employment remuneration details including salary, benefits in kind and pension arrangements;
– Employment and job application details;
– Information collected automatically via cookies when you visit our website;
– Photographic identification and video footage;
– Information concerning your health, marital or civil partnership status, though only where this is necessary to provide the service you have requested or to comply with a legal obligation
Please note that this is not an exhaustive list. Whilst we make every effort to minimise the amount of data that we collect, process and store, the nature of the work for which we are contracted often requires a comprehensive understanding of present and likely future circumstances.
We will continue to process your personal information where you have signed up to one of our ongoing service packages. Such processing is limited to the extent that it is necessary for us to meet our contractual and regulatory obligations and so that we can continue to provide our services to you.
We do not engage in direct marketing activities, nor do we share your information with companies who may seek to use your data for unsolicited direct marketing campaigns.
WHY DO WE PROCESS YOUR PERSONAL INFORMATION?
– To fulfil our contractual obligations to you, or otherwise taking steps as described in our ‘Service Costs & Disclosure Document’ (including any associated administration), including steps taken in contemplation of entry into a contract with us, i.e. data arising from any initial meeting(s);
– To contact you or otherwise administer our contract with you;
– To respond to initial enquiries or other queries submitted to us;
– To manage our relationship with you or your business;
– To comply with any professional, legal or regulatory obligations, for example anti-money laundering and sanctions checks; and
– To enable you to make a claim in the future and to have such a claim fully investigated independently by us in the first instance but ultimately by the Financial Ombudsman Service.
THE LEGAL BASES FOR PROCESSING YOUR DATA
– To enter into or carry out our contract with you;
– To comply with legal and regulatory obligations;
– Where we have a legitimate interest in doing so, i.e. the retention of data for the establishment, exercise or defence of legal claims
HOW WILL WE USE YOUR INFORMATION?
– We will only process information where it is lawful to do so, and we will only do so in a fair and transparent manner.
– We will only collect, process and store data for specified, explicit and legitimate purposes and will not further process personal data in a manner which is inconsistent with these stated purposes.
– We will keep data in a form which could allow identification for no longer than is necessary for the purposes for which it is processed.
– We will take reasonable steps to ensure that the data we hold remains accurate and up to date, though you also have the right to request that any errors be rectified (please see the section on your rights below).
HOW WILL WE SECURE YOUR DATA?
– We keep data within hard copy, paper, files. Such files are kept within locked filling cabinets at our office. Our office is alarmed and is protected by (non-fixed) CCTV surveillance cameras;
– We also store data electronically. This data is held across distributed systems and is backed up daily to both physical and cloud devices with the aim of maintaining the integrity of the data in case of a catastrophic hardware failure or event such as a flood/fire. All data is password protected and backups are encrypted. Furthermore, we undergo periodic hardware upgrades to help mitigate hardware failures.
You have a number of rights in relation to the data that you provide to us, some of which relate to information that must be provided to you at the point that the data is collected, whereas other rights relate to the ongoing treatment of the data and your rights in connection with it.
Wherever we collect data from you, we will always provide you with the following information:
– Our contact details including relevant company identifiers, i.e. company number and ICO registration number;
– The name and contact details of our Data Protection Officer;
– The purposes for which we are collecting and processing the data in question;
– Details of the persons with whom the data may be shared;
– Where applicable, the fact that data is or may be transferred outside the European Economic Area;
– Minimum period of storage and/or continued processing; and
– Notification of your other ongoing rights pertaining to the data
We are also committed to upholding your perpetual rights in relation to your data, which are detailed below.
ACCESS TO YOUR INFORMATION
You have the right to obtain confirmation of whether we hold any data about you and if so, the right to its release in addition to supplementary information concerning your information rights.
Once such a request is received by us we must provide the relevant information within a month of the date of the request. We are no longer permitted to charge a fee for the release of this information, unless repeated or vexatious requests are received.
CORRECTING YOUR INFORMATION
It is important that the information that we hold about you is accurate and up to date, not least to enable us to fulfil our contractual obligations to you.
You have the right to insist that errors within the data we hold about you be corrected without delay.
DELETING YOUR INFORMATION
You have the right to request that we erase your personal data, where:
– We are no longer using the information for the purposes for which it was originally collected and there are no other legal bases for its retention;
– The information in question had been collected and processed on the basis of your consent and that consent has been withdrawn;
– You have validly objected to our use of your personal information (please see relevant section below);
– Our use of your information is contrary to law or our other legal obligations.
Please note that the right to erasure is subject to an important caveat – we may refuse to delete all or part of your data where believe that it is in our legitimate interests to do so, i.e. to enable the full investigation of your case in the future by the Financial Ombudsman Service, to comply with professional, legal or regulatory obligations by which we are bound.
OBJECTING TO HOW WE MAY USE YOUR INFORMATION
This is a right to object to the certain further processing activities relating to your data, though this will depend upon whether there are any overriding legal bases for its continued processing.
We do not use your personal information for direct or indirect marketing purposes, nor will we share your data with other entities who may seek to use your data for any such purpose without having first obtained your informed and express consent.
RESTRICTING HOW WE MAY USE YOUR INFORMATION
This allows us to retain your data but prevents us from using it for purposes outside of your restriction i.e. where you have requested that the data we hold be erased though we have an overriding interest in its retention (such as in the example given above), you may impose conditions upon how that data is processed in the future etc.
Where this right is validly exercised we may only use the information in question with your express or where there is another overriding legal basis for the processing.
There are two elements to this: firstly, you have right to receive copies of your data in a commonly used, machine readable format; secondly, the right to transmit your data to another data controller.
WITHDRAWING YOUR CONSENT
Where your information is processed on the basis of your consent, you may withdraw your consent at any time and we will stop using your personal information for the purposes for which consent was given.
Data Protection Officer: Liam Turnbull
Active Investment Managers Limited (Company no: 02140781) T/as Morgan Williams & Co
174 Kingston Road
East Riding of Yorkshire
Telephone: 01482 659364
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner’s Office:
By phone: 0303 123 1113
By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF