The purpose of this policy is to explain to you how we control, process, handle and protect your personal information including your rights under current laws and regulations.
Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, Kingsfleet Wealth
- “you”, “the user” refer to our clients (or potential clients)
- UK GDPR means UK General Data Protection Regulation
- DPA means Data Protection Act
- ICO means Information Commissioner’s Office
Personal Data We May Collect About You
Kingsfleet Wealth is a data controller under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA) and the personal and financial information you provide, including data provided when communicating with us via our website, on the telephone and during meetings will be processed subject to these regulations for the purposes of providing our financial planning advice services. This information will be treated confidentially, held securely and we will only process it for a legitimate purpose.
We will ask prospective new clients to complete our Fact Find form in order to provide personal and financial information ahead of an initial meeting.
All telephone calls and meetings will be recorded.
Sensitive personal data Consent
There are certain categories of personal data that are sensitive by nature. The categories include: 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. We may also engage the services of third-party providers of professional services in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of their contract with us. If you wish to know the names of these third parties, please contact us for further information.
Our policy is that we will only gather this sensitive personal data with your explicit consent..
Information about other individuals
Lawful basis for processing data
The legal basis we rely on for processing your data is:
- the performance of our contract i.e. to provide you with the financial planning advice services you request
- to comply with legal and regulatory obligations
- the purposes of our legitimate interests for example providing a high-quality service, and being able to respond to future enquiries
How we use your personal data
We may use your data for the following purposes:
- to carry out our obligations arising from any contracts entered into by you and us
- communicate directly with you via telephone, post and email
- to help us identify you and any accounts you hold with us
- research, statistical analysis and behavioural analysis
- customer profiling
- fraud prevention and detection
- to notify you of any changes to our services that may affect you
- security vetting
- to send you information about products and services offered by Kingsfleet Wealth, but only if you have given us your explicit permission [consent] to receive such marketing material.
Disclosure of personal data
We may disclose your personal data to:
- our agents and service providers
- law enforcement agencies in connection with any investigation to help prevent unlawful activity.
We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except as described in this policy or with your prior permission.
Data security and protection
We will use technical and organisational measures to safeguard your personal data. We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Some of the service providers we use are located in the US that does not offer the same protection to your personal data as the UK and the EU. In these cases, your personal data will be protected through contracts with wording (Standard Contractual Clauses) approved by the European Commission to ensure adequate safeguards to personal data when it is transferred outside of the EU.
You should note that while we will use all reasonable efforts to safeguard your personal data, you should acknowledge that the use of the internet for electronic communication is not entirely secure and for this reason we will avoid sending unencrypted emails containing confidential or sensitive, personal data. We also encourage you to attach a password protected Word document if you wish to communicate such information electronically.
Clients (ie someone who has signed a Client Agreement)
Due to the nature of financial services and the possible need to review historical advice, client data will be held indefinitely.
We would only move data to a storage-only archive where it would no longer be actively processed, backed up and where access would be restricted, upon receipt of a valid deletion request.
Leads/Prospects (ie someone who has not signed a Client Agreement)
For a lead/prospect who does not convert to a client of Kingsfleet Wealth (ie does not sign a Client Agreement) we will retain your data electronically as well as in paper format for six months after we last have any form of contact with you. At this point we will delete all hard copy and live system data. It should be noted however that any electronic data is backed up regularly and cannot be selectively erased or destroyed. Consequently, such data will be stored indefinitely but will not be actively processed.
Your rights and your personal data
Unless subject to an exemption under the GDPR/DPA, you have the following rights with respect to your personal data:
- the right to request a copy of your personal information held by Kingsfleet Wealth. This is known as a Subject Access Request. We will provide information to you free of charge and within 30 days from when we have verified your identity
- the right to request updates and amendments to the personal data that we hold where that data is found to be inaccurate or out of date
- the right to request your personal data is erased where a valid data deletion request is received
- The right to request that Kingsfleet Wealth provides you with your personal data held and, where possible, to transmit that data directly to another data controller (known as the right to data portability and only applies where the processing is based on consent or for the performance of a contract and, in either case, the processing is carried out by automated means)
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to the processing of personal data (only applies where processing is based on legitimate interests)
- the right to lodge a complaint with the ICO. Contact details are below
If you would like to exercise any of the above rights then please do contact us.
Queries and complaints
To exercise all relevant rights or for queries or complaints please contact Colin Low at Kingsfleet Wealth either via email: email@example.com or telephone: 01473 744724.
ICO Contact Details
You can contact the ICO on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF