Privacy Policy

Introduction

We recognise our responsibility to treat your personal information with care and to comply with all relevant legislation, the Data Protection Act 2018 and the EU General Data Protection Regulation (GDPR) which we refer to as the “legislation” in this document. This notice covers our requirement to provide you with information on how and why we use your personal data and of your rights under the legislation.

Data Controller

We provided you with advice and the means to manage your investments, your pension arrangements and meet your protection needs. In addition, we offer regulated lending and other credit related products. Consequently, we are classed as the “data controller” which means we process your data. The contact details are shown at the foot of this notice. Your personal data which is limited to the details provided on our data gathering forms, outputs from fund managers, insurance companies and lenders in accordance with the products that you purchase through this business. The data is passed to these organisations who may issue you with their own Data Protection Privacy Notices.

If you proceed with implemention, fees can be charged directly to your new product(s) or invoiced directly to you, if you prefer.

Personal Information

We will use personal information about you mainly to:

• Provide advice and recommendations on investment strategy, protection needs and retirement planning
• Provide advice on estate planning and the tax implications of the arrangements
• Arrange and administer your investments, pensions and insurances
• Arrange Equity Release mortgages through an associated company – Mushroom Ltd.
• Inform you about our products and services
• Implement anti-money laundering processes
• Statistical analysis and management information to improve our service proposition.

Some of the personal information we ask you to provide may be regarded as being sensitive as defined in the legislation, e.g. medical data, health data, and about your occupation. This information is required to support applications made to secure the products of your choice, without which the application cannot be completed.

If you give us information about another person you confirm that they have given you permission to provide it to us and that we may use their personal data in the same way as your own as set out in this notice.

Legal Basis for processing your personal information

We are required to have a lawful basis (as defined in the legislation) to process your personal data and the relevant bases which we use are show in the table below.

Marketing

We may contact you by email, text, telephone, mail or other agreed means to keep you up to date about our products and services. This may include products and services from Weybridge Financial Services and Mushroom Ltd both an associated company. When you do any new business with us you will be asked to sign a new client agreement which incorporates our privacy statement.

The legislation allows us to do this in our own commercial interests for certain communications with previous customers. In other circumstances we can only do so with your explicit consent. In all cases you can opt out from receiving such communications at any time.

Disclosure of your Personal Information

As a necessary part of providing you with the services described above we may need to disclose your personal data to other third parties. These include product providers (including fund managers, insurance companies and investment providers). We may be required to disclose personal data to regulatory authorities and the police or other law enforcement bodies that assist with fraud prevention and detection.

We may give access to your personal data to third party contractors including our compliance support firm as part of their role to monitor regulatory adherence within the firm. Appropriate confidentiality agreements are in place. Other third parties including our accountants and IT specialists may also gain access to our data as part of their role to support Salisbury Financial Services Ltd and Weybridge Financial Services businesses.

Where applicable and with your consent we may pass your personal data to a specialist equity release adviser. (Mushroom Ltd).

These are the only circumstances where we share data, we do not provide your personal data to third party for marketing purposes and take reasonable steps to prevent data loss. Our third-party suppliers confirm that shared data gained from this firm will not be used for marketing purposes.

Retention Period

Your data will not be retained for longer than is necessary and will be managed in accordance with our data retention policy. In most cases the period will be for a maximum of 7 years following the dis-investment and closure of your account with the firm. We may be required to retain the data for a longer period due to business, legal or regulatory requirements.

International transfers of data

We do not presently transfer your personal data to destinations outside the European Economic Area (EEA).

Your Rights

Under the legislation you have the following rights in relation to our processing of your personal data: -

1. The right to be informed about how we use your personal data (This Privacy Notice);
2. The right to see a copy of the personal information we hold about you. (In most cases this will be free of charge);
3. The right to have personal information rectified if inaccurate or incomplete;
4. The right of erasure of your personal information where there is no compelling reason for its continued processing;
5. The right to restrict processing in certain circumstances, e.g. if its accuracy is being contested;
6. The right to data portability which, subject to certain conditions, allows you to obtain and reuse your personal data across different services;
7. The right to object to certain processing including for the purposes of direct marketing;
8. Rights to information in relation to automated decision making and profiling.

Complaints/Contact us

If you have a complaint about how we use your personal information, please contact us at the address below. You also have the right to lodge a complaint with the Information Commissioner’s office at any time.

For further information on this Privacy Notice, to access your personal information or to exercise any of your other rights, please contact The Data Protection Officer, Mr Tom Beckett, 36a Packhorse Road, Gerrards Cross, Buckinghamshire SL9 8EB or by email to financialadvice@salisbury.co.uk or by calling 01753 889090