Who we are?
Your privacy is very important to us. This notice is provided by Pensure Financial Management Ltd. We are a controller and processor of your personal data under the Data Protection Act 2018. This privacy notice tells you what to expect when Pensure Financial Management Ltd collects personal information.
Whose personal data do we collect?
We collect and process data about individuals who may be current, prospective or former clients and, where relevant, their spouses/civil partners, employees, accountant or GP.
What kind of personal data do we collect about you?
We collect and process your personal data such as your name, date of birth, residential and email address, your income and financial details, details of your policies and investments together with transactions, details of your health, country of residence for tax purposes as well as any other information we deem necessary in order to be able to provide you with the agreed service.
How we collect your personal data
Information that you provide to us by telephone; e-mail or face to face. We will collect personal data about you in our Fact Find. If you contact us, we may keep a copy of that correspondence.
People who email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
Visitors to our website
When someone visits www.pensurefinancial.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Do we collect personal data about you from third parties?
We may collect personal data from providers regarding your policies and investments together with transactions, and from publicly accessible sources e.g. to establish and verify your identity to meet our Anti Money Laundering responsibilities.
How we will use your personal data
Pensure Financial Management Ltd provide a range of Financial Services to Data Subjects. We process data provided by the data subject and other sources in order to deliver the appropriate products and services to Data Subjects.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a review of their retirement planning to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services, they can cancel their subscription at any time and are given an easy way of doing this. They are able to do this using the details provided in the “How to contact us” section of this notice.
Who do we share your personal data with?
We may share your personal data with life and investment companies in order to facilitate an agreed transaction and in order to facilitate any ongoing service agreed.
Use of data processors
Data processors are third parties who provide elements of our service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Our Data processors / Third parties that we use include:
- Banking arrangements: Barclays Bank
- Regulatory and Compliance opinion where required: Compliant Solutions Limited
- Back Office Systems: The Exchange, Mortgage Brain, Paraplanning Online, O&M Profiler
- Secure Destruction: Clarks Advanced Shredding
- Complaints: Collegiate Underwriting
- Financial Conduct Authority, Financial Ombudsman Service, Law Enforcement & HMRC
How do we protect your personal data?
To protect the security of your personal data, we have in place appropriate systems, controls and procedures to ensure your data is protected. These procedures are regularly reviewed and tested.
How long do we hold your personal data for?
We will retain your personal data as long as it remains necessary in relation to the agreed service and to ensure we can defend any complaint, can meet our contractual, legal and regulatory obligations.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.
We will only use the personal information we collect to process the complaint and to check on the level of service we provide.
We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute.
We usually have to disclose details of the complaint to our Professional Indemnity Insurance Broker and Insurer.
We may be required to provide a copy of our file to the Financial Ombudsman Service should an adjudicator be required to consider the complaint case.
We are required to disclose to The Financial Conduct Authority (FCA) high level analytics concerning the number and nature of complaints received. This data does not include names or details that identify the specific data subject.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for 99 years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Under the Data Protection Act 2018, you have rights as an individual which you can exercise in relation to the information we hold about you.
Access to personal information (Portability)
Data Subjects may submit a Subject Access Request – in order to obtain a copy of the personal data that we hold about them in a structured and portable manner. All SAR requests should be sent to: Caroline Elliott, Data Protection Officer at: email@example.com
Confirmation of whether, and where, the controller is processing their personal data
Pensure Financial Management Ltd is the Data Controller and a Processor. Pensure Financial Management Ltd undertakes data processing within the EEA.
Right of Data subjects to erasure (Right to be forgotten)
Data Subjects may notify the Firm if they wish to exercise their right to erasure. Such a withdrawal of Consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data Subjects that exercise this right will be removed from any marketing or future contact.
Pensure Financial Management Ltd may retain a copy of any personal data, which will be retained by the Controller, if the processing is necessary for the establishment, exercise or defence of legal claims. This means that information relating to a complaint will be retained for 99 years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Right of rectification
Pensure Financial Management Ltd will seek to ensure that inaccurate or incomplete data will be rectified.
Data Subjects have the right of rectification.
Disclosure of personal information
In most circumstances we will not disclose personal data without your consent. However, for example, when we investigate a complaint, we will need to share personal information with the organisation concerned and with other relevant bodies.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 24th May 2018.
How to contact us
Pensure Financial Management Ltd
38 High Street