Privacy Notice for clients of Waverton Wealth
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 medical 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 of birth and 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 the performance of our contract for services with you, collection of your Personal Data may include:
• Title, name, date of birth, gender, nationality, civil partnership/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), and employment history;
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants;
• Health status and history, details of treatment and prognosis, and 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 investment/ mortgage/finance and/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 financial planning 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.
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, for example with life or health assurance, we will ask you for information including details of your health and your medical history (your Special Data). We will record and use your Special Data in order to make enquiries of insurance/investment providers in relation to insurance products that may meet your needs and to provide you with advice/ guidance 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.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
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 and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries, such as our firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
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 your financial planning. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example information from your employer, and searches of information in the public domain such as the Electoral Register.
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 our nominated processor, to access your information in this manner. With regards to electronic ID checks, we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
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 (websites, email, hard drives and cloud facilities). This information can only be accessed by employees and consultants 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 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 lenders and providers may raise;
• Use your Personal Data for the purposes of responding to any queries you may have in relation to any investment or insurance policy you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware.
Sharing your Personal Data
From time to time your Personal Data will be shared with:
• Investment providers and insurance providers;
• 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 and providers of other professional services such as legal and accountancy (in each case where 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 Privacy Notice, i.e. to meet your financial planning needs 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 Privacy Notice.
We do not envisage that the performance by us of our service will involve your Personal Data being transferred outside of the UK or the European Economic Area.
Security and retention of your Personal Data
Your privacy is important to us and we will keep your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, and 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 in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to your Personal Data
You can:
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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:
Jason Hemmings
Waverton Wealth
Exchange Tower
19 Canning Street
Edinburgh
EH3 8EH
jhemmings@wavertonwealth.co.uk
If we feel we have a legal right not todeal 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 also 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 Information Commissioner’s Office (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.
