Introduction

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

We confirm when processing data on your behalf that we will comply with the relevant provisions of the Data Protection Legislation. You will also ensure that any disclosure of personal data to us complies with the Data Protection Legislation.

Information we collect and why we use it

Personal data is principally collected and processed when supplied by you in the course of our engagement with you under our terms and conditions and contract.

The personal information we collect from you will vary depending on services engaged. The personal information we collect might include your name, address, telephone number, email address, bank account details, your IP address, which pages you may have visited on our website and when you accessed them.

In general terms, and depending on which services you engage as part of providing our agreed services we may use your information to:

• contact you by post, portal, email or telephone
• verify your identity where this is required
• understand your needs and how they may be met
• maintain our records in accordance with applicable legal and regulatory obligations
• process financial transactions
• prevent and detect crime, fraud or corruption

Obligation on you when passing on personal data

If any of the details submitted for processing change, it is your responsibility to inform us so that we can update our records as soon as practically possible.

Your Rights

Access to your information: You have the right to request a copy of your personal information we hold.

Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you can ask us to correct any personal information about you that you believe does not meet these standards.

Deletion of your information: You have the right to ask us to delete personal information about you where you consider that we no longer require the information for the purposes for which it was obtained

• you have validly objected to our use of your personal information
• our use of your personal information is contrary to law or our other legal obligations
you have withdrawn your consent

Disclosure of your information

We may share your personal data within the Firm for the purposes of performing the services contracted and, where consented, business updates and marketing activities. We will not sell or rent your information to third parties.

We may pass your information to our third party service providers and subcontractors for the purposes of completing tasks and providing services to you on our behalf. However, when we use third party service providers, we disclose only the information that is necessary to deliver the service. Contractually information is kept secure and used only for the purposes of delivering the required service.

We will not release your information to other third parties unless you have requested that we do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.

Security of data

We take the security of your data seriously. All of our systems have appropriate security in place that complies with all applicable legislative and regulatory requirements. Whilst we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Where we have given, or where you have chosen, a password which enables you to access information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Retention of records

We will retain your personal data for as long as necessary to achieve the purposes set out in this Privacy Notice. You have a legal responsibility to retain documents and records relevant to your financial affairs.

We will retain your records for the duration of our engagement with you under our terms and contract. After any termination of the contract between us we will hold your records for the legal or regulatory minimum periods required. We also reserve the right to retain data for longer than this due to the possibility that it may be required to be provided to a regulator outside of these minimum periods.

Records held for the purpose of business updates are held until such time that notice of consent is revoked.

Changes to our privacy notice

We keep this privacy notice under regular review. This privacy notice was last updated on 1st May 2018.