Our Privacy Policy
How we collect, use, share and protect your personal information, and your rights over it.
This privacy notice applies to Independent Advice Ltd., which also trades as H.J. Scott & Co. ("we", "our", "us" or "Independent Advice"), of Suite C, Futura One, Aspinall Way, Middlebrook, Bolton, BL6 6PG. We are the "data controller" for the personal information described in this notice, and are authorised and regulated by the Financial Conduct Authority as a discretionary investment manager, and registered with the Information Commissioner's Office (ICO), registration number Z2414677.
Please read this notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using it.
How we will use your information
In general terms, we collect and use personal information about you to:
- deliver our services and meet our legal responsibilities;
- verify your identity where this is required;
- contact you by post, email or telephone about important changes to our services;
- maintain our records;
- process financial transactions; and
- prevent and detect crime, fraud or corruption.
At the time you provide us with any information in response to a request from us, that request will explain how we will use it. We may contact you by email, phone, fax or post for the purposes set out above; by providing this information you are deemed to have agreed to us contacting you by these methods, and we will continue to do so until you advise us in writing otherwise. You are asked to accept at least one method of receiving communication from us. We will not pass your details to anyone else other than as set out below.
The personal information we collect and use
This includes:
- your personal contact details (such as name, date of birth and email/postal address);
- documentation confirming your identity, tax residency and legal authority;
- information connected to the product or services you use (for example, bank account details);
- information you provide about other people (for example, for joint applicants or beneficiaries for products or services);
- your correspondence with us (such as letters, emails, calls or meetings);
- images of you submitted by yourself; and
- information relating to your health, marital or civil partnership status — only where necessary to provide the product or service you have requested, or where required to comply with our legal obligations.
Most of this information is provided directly by you, whether in person, by phone, by email, or through our client forms. This information is necessary to enable us to provide our services to you; if you do not wish for your personal information to be processed, we will be unable to provide you with our services.
Sharing your information
We will not transfer, disclose, sell, distribute or lease your personal information to third parties other than:
- where we have your permission;
- where we are required to do so by law;
- where it is needed by our recommended product provider or our service providers, involved in running accounts and services for you or in undertaking activities linked to the operation of such services or accounts on our behalf; or
- where the transfer or disclosure would otherwise be in compliance with legal requirements we are subject to, including but not limited to statute or regulation.
Our current recommended product provider is:
- Transact (Integrated Financial Arrangements Ltd) — our investment platform, which holds and administers your account. Transact is itself an independent data controller for the data it holds about you, and provides its own privacy notice when you apply for an investment through the platform.
We also use carefully selected service providers to run our systems. Except where noted, they act only on our instructions, under contracts that require them to keep your information secure and confidential, and may not use it for their own purposes:
- UK2.net (UK-2 Limited) — our email and domain provider.
- Hetzner (Hetzner Online GmbH) — hosts the secure server on which our website and client records are held.
- Veriphy (Veriphy Ltd, part of Davies Group) — our electronic identity verification provider, used to meet our anti-money-laundering obligations. For the checks it carries out, Veriphy is an independent data controller and provides its own privacy notice at the point of verification.
- DocuSign — used when you sign your client agreement and Transact application forms electronically.
We may also share information with our professional advisers (for example our accountants, auditors and compliance consultants), and with regulators and law enforcement (including the FCA and HMRC) where we are legally required to.
Your information is held in the UK and in the European Economic Area. Our email, and the records held by Transact and Veriphy, are held in the UK. Since October 2026 our website and client records have been held on our own secure server in Germany, and documents you sign electronically through DocuSign are held in its European Union service. Both are within the European Economic Area, which the UK recognises as providing an adequate level of data protection. We do not transfer your personal information outside the UK or European Economic Area. If this changes, we will only do so where the country concerned provides an adequate level of protection, or where an appropriate safeguard is in place.
Reasons and legal basis for processing your information
The reason and legal basis we rely on for using your personal information depends on the circumstances:
| Reason for processing your personal information | Legal basis |
|---|---|
| Making a decision to engage with you as a client, and making decisions about your continued status as a client, including arrangements for termination of our contract if appropriate | To enter or carry out the contract (our terms and conditions) |
| Contacting you; administering our contract with you and exercising our rights; ensuring compliance with our terms and conditions; processing payments and deducting fees | To enter or carry out the contract (our terms and conditions) |
| Verifying your identity, tax residency and legal authority (client identification and anti-money-laundering checks) | To comply with our legal obligations |
| Business management and planning, including accounting or auditing; making improvements to our services; monitoring your use of our IT and communications systems | Legitimate interests |
| Processing information relating to health, marital or civil partnership status, where necessary to provide the product or service requested | Legitimate interests, or explicit consent where required |
| Letting you know about our other products and services | Legitimate interests, or consent where required |
We do not use your personal information for any purpose that is incompatible with the purposes set out above without telling you first.
How long we keep your information
We keep client records for as long as they may be needed, which in practice means we retain them indefinitely. Many of our client relationships continue over many years and across generations of a family, and the time limits for raising a complaint about financial advice run from when a client first becomes aware of a problem, which can be many years after the advice was given. Keeping records allows us to respond fully to any question, complaint or claim, whenever it arises, and to meet our regulatory record-keeping obligations, including those relating to pensions.
Records we hold are kept securely in line with this notice, and you may still exercise your rights over them, as set out below.
Cookies
When you visit our website or use our other online services, we may automatically collect information about your usage of our websites and online services using cookies. To find out more about how we use cookies, please see our cookie policy.
Your rights
Access to your information — you have the right to request a copy of the personal information about you that we hold.
Correcting your information — we want to make sure that your personal information is accurate, complete and up to date, and you may 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;
- we are using that information with your consent and you have withdrawn your consent — see "Withdrawing consent" below;
- you have validly objected to our use of your personal information — see "Objecting to how we may use your information" below; or
- our use of your personal information is contrary to law or our other legal obligations.
Objecting to how we may use your information — you have the right at any time to require us to stop using your personal information for direct marketing purposes. Where we use your personal information to perform tasks carried out in the public interest, or on the basis of our or a third party's legitimate interests, we will stop using that information if you ask us to, unless there are overriding legitimate grounds to continue.
Restricting how we may use your information — in some cases, you may ask us to restrict how we use your personal information — for example, while we check the accuracy of information we hold, or assess the validity of an objection you have made. Where this right is exercised, we may only use the relevant personal information with your consent, for legal claims, or where there are other public interest grounds to do so.
Portability — where we process personal information you have provided to us on the basis of consent, or because it is necessary for the performance of a contract, and that processing is carried out by automated means, you have the right to have that information transmitted to you in a machine-readable format, and, where technically feasible, transmitted directly to another controller.
Automated processing — if we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right applies only where we use your information with your consent or as part of a contractual relationship with you.
Withdrawing consent — where we use your personal information with your consent, you may withdraw that consent at any time, and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out below if you wish to exercise any of these rights.
Changes to our privacy policy
We keep this privacy policy under regular review and will place any updates on this website. Paper copies of the privacy policy may also be obtained on request.
This privacy policy was last updated on 23rd October 2026.
Complaints
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:
- Online: ico.org.uk/global/contact-us/email
- By phone: 0303 123 1113
- By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Contact information and further advice
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to:
Charlotte Scott
Data Protection Officer
Independent Advice Ltd.
Suite C
Futura One
Aspinall Way
Middlebrook
Bolton
BL6 6PG
Alternatively, email Charlotte at charlotte@hjscott.co.uk.
