We, as the “data controller”, collect and use personal information about you in order to provide our services. Please read the following carefully to understand how we use and protect the information that you provide to us. It is important you 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 such 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
- Prevent and detect crime, fraud or corruption
We use this information to provide you with a better service, and in particular for the following reasons:
At the time you provide us with any information in response to a request from us, our request will provide you with specific information as to how we will use such information.
We may contact you by e-mail, phone, fax or mail in relation to the purposes set out in this section and by providing such information you are deemed to have agreed to us contacting you by these methods of communication. We will continue to contact you by way of such methods until you advise us in writing that you no longer wish to be contacted by certain methods. Please note you are required to accept at least one of the above methods as your chosen method of receipt of communication from us.
We will not pass your details to anyone else (other than on the basis set out below and in accordance with appropriate disclosure requirements we may be subject to).
- 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
- Information collected automatically via cookies when you visit one of our websites
- Information relating to your health, marital or civil partnership status (only where it is necessary to provide the product or service you have requested or if required to comply with our legal obligations)
We will not transfer, disclose, sell, distribute or lease your personal information to third parties other than on the following basis:
- where we have your permission
- where we are required to do so by law
- where it is needed by our recommended product 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.
This process may include sending personal information to other countries, whose data protection laws may not be as extensive as in the European Economic Area. However, we have taken appropriate steps to ensure the same level of protection for the processing carried out in these countries as within the European Economic Area.
Where you have contracted for our services, we may process personal information about you in order to facilitate the contractual relationship in place between us and to provide you with our services.
To provide our services to you in an effective and efficient way, we require to process personal information about you. This information may come from you directly, from other professionals who you have given your permission to share information with us, credit reference agencies and HMRC.
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 then we will be unable to provide you with our services.
The reason and legal basis we rely on for using your personal information will depend on the circumstances and is explained in more detail below.
Reason for processing your personal information
- Make a decision to engage with you as a client
- Make decisions about your continued status as a client on an on-going basis and make arrangements for the termination of our contract if appropriate
- Contact you
- Administer our contract with you and exercise our rights
- Ensure compliance with our terms and conditions
- Process payments and deducting fees
- Business management and planning, including accounting or auditing
- Making improvements to our services
- Monitor your use of our IT and communications systems
Legal bases for processing
- To enter or carry out the contract (our terms and conditions)
- To comply with our legal obligations
- Legitimate interests
- Letting you know about our other products and services
We only keep information for as long as is necessary in order to discharge our statutory and legal obligations. This will vary depending on the particular circumstances. As a general rule, we will retain records for a period of six years following the termination of the contractual relationship between us, unless there are circumstances which mean we must retain the records for longer periods. There are various reasons why we must keep records for longer time periods, such as where the record is relevant to legal proceedings, a criminal investigation or where the record is subject to a statutory retention period (for example, data in relation to pensions).
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 to using your information' below
- You have validly objected to our use of your personal information – see 'Objecting to how we may use your information' below
- 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. In addition, where we use your personal information to perform tasks carried out in the public interest or pursuant to the legitimate interests of us or a third party then, if you ask us to, we will stop using that personal information 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. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where we no longer have a basis for using your personal information but you don’t want us to delete the data. Where this right to validly 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 - If we process personal information that you provide to us on the basis of consent or because it is necessary for the performance of a contract to which you are party, and in either case that processing is carried out by automated means, then you have the right to have that personal information transmitted to you in a machine readable format. Where technically feasible, you also have the right to have that personal information 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 only applies where we use your information with your consent or as part of a contractual relationship with you.
Withdrawing consent using your information – 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 in the Contact information and further advice section if you wish to exercise any of these rights.
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
All comments, queries and requests relating to our use of your information are welcomed and should be addressed to:
Data Protection Officer
Independent Advice Ltd.
15 Chorley New Road
Telephone: 01204 559696