Padstone Financial Management Ltd

1. Appendix III. Data Privacy Notice Addendum

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.

WHO WE ARE

Padstone Financial Management Limited collects, processes and stores certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller for that personal data for the purposes of compliance with those laws.

When we mention "Padstone”, "we", "us" or "our" we are referring to Padstone Financial Management Limited, Court View, Preston Wynne, Hereford HR1 3PE.

Padstone is a company registered in England and Wales, Padstone Financial Management Limited company number 04366170 whose registered office is at Court View, Preston Wynne, Hereford HR1 3PE. Padstone Financial Management Limited is authorised and regulated by the Financial Conduct Authority (FCA). Padstone Financial Management Limited Financial Services Register number is 430531.

We provide :

Independent advice – We will advise and make a recommendation for you after we have assessed your needs. Our recommendation will be based on a sufficient range of retail investment products, financial instruments and structured deposits.

A ‘sufficient range’ means that the products that we will advise on and recommend will be sufficiently diverse with regards to their type and issuers or product providers to ensure that our clients investment objectives can be suitably met.

Ongoing services – We may also provide you with an ongoing service, if we have agreed this with you up front.

THE PERSONAL DATA WE COLLECT AND USE

In the course of providing our services to you we may collect the following types of personal data when you provide it to us:

  • Contact information, including your name, address, telephone and mobile numbers

  • Identity information, which may include copies of documents such as your passport

  • Proof of address, for example, a copy of your driving licence or utility bills

  • Financial information, including information about your bank / building society

  • Employment status, for example what work you do, who you work for and for how long

  • Information regarding inheritance tax and whether you hold a valid Will and your wishes on death

  • Lifestyle information, for example, whether you have recently smoked (so as to make the necessary disclosures to providers), what your intended retirement age is

  • Information regarding any vulnerability you may have which allows us to provide our services to you in the best way in which we can

  • Information regarding existing products you have with providers

  • Information regarding any complaints you make or concerns you may raise

  • Contractual information.

Records of calls and electronic communications

We also make records of conversations that take place with you and retain copies of electronic communications that take place in relation to some types of investment products. We explain this prior to providing those investment services.

Information regarding dependents, beneficiaries and other third parties

We collect information about you and your family during our initial and other meetings with you. We collect the data through note-taking and filling in of fact-finds and questionnaires about you and your family’s circumstances.

We collect this information to enable us to provide our services to you. For example, we may collect information about children and grandchildren, for example, for school fees planning and to invest for their future. We take care to minimise the amount of data we collect for these purposes.

Please note that, if you are providing information about another person, for example a spouse, you should ensure they know that you are doing this and are content for their information being provided to us. We would suggest that you show them this Data Privacy Notice and if they have any concerns please contact us in one of the ways described in this notice.

INFORMATION COLLECTED FROM OTHER SOURCES

We also obtain personal data from other sources in the course of providing our advice and, where appropriate, intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

We may also make checks with organisations with whom you have policies of insurance and investments and with your mortgage provider. These checks are to help us with our legal obligations and to ensure that we provide you with advice that suits your circumstances.

The scope and extent of the gathering of information from third parties depends on what type of service you are being provided with.

The personal data we obtain from other sources may include the following:

  • From product providers:

    • product details; for example, valuations, terms, exit charges

  • From identification and verification checking agencies:

    • sanction check information

  • From companies that may introduce you to us such as Solicitors, Mortgage Advisors or Accountants

  • From your employer; for example, to obtain information about your employment in the course of providing pension advice

  • From other Advisors, for example, if you have sought our services having previously been given advice elsewhere.

Information which is available publicly:

Your personal information may be available to us from external publicly available sources: for example, information from public registers such as listed directorships, information from HM Treasury’s financial sanctions targets lists.

HOW WE USE YOUR PERSONAL DATA

This section explains in more detail how we use your information and in particular the legal grounds on which we rely when doing so.

We use the information we collect about you for a number of purposes, including:

  • To deliver our financial advice services to you

  • To identify you and verify your identity

  • To manage our relationship with you and to communicate with you

  • To respond to any concerns or complaints you may have and to seek to resolve them

  • To communicate with our regulators and other law enforcement bodies

  • To train our staff and measure the quality of the advice and services we give to you

  • To comply with laws and regulations that apply to us.

The Legal grounds we rely on to process your information

The legal grounds on which we rely are:

  • To fulfil our contractual obligations (for example in order to provide you with the financial advice service requested and to contact you if a problem arises

  • To pursue our legitimate interests (for example, please see list below)

  • Your consent

  • To fulfil a legal duty.

Legitimate interests

We rely on our legitimate interests for the purpose of:

  • Keeping our records up to date

  • Charging for our services

  • Administering our website and keeping it safe and secure

  • Complying with legal and / or regulatory requirements.

Sharing your data

We, or one of the individuals or companies working on our behalf, may share your personal information with third parties. We have described below the specific categories of third party and given examples, however, due to the nature of our business, there are many third parties we may share data with. For example, we regularly share data with many different product providers. If you require more information about who we share data with, please ask us:

Data processors

To help us to fulfil our obligations to you and to pursue our legitimate interests, we may share your information with third parties who provide services to Padstone Financial Management Ltd. Or who act on our behalf. This includes, for example, IT service providers, payment processors, financial institutions, compliance consultants, paraplanners and other experts such as accountants.

We do not authorise these processors to use or disclose your personal information except for the purpose of providing the service we request of them. All our data processors are based in the European Economic Area (EEA).

Joint Controllers

We may share your information with third parties who are defined as joint controllers these are usually product providers (for example, investment institutions and investment platform providers; insurance companies; banks and building societies; credit institutions; employers and pension providers.

Other

We may also share information with local and foreign regulators (for example, the Financial Conduct Authority and Information Commissioner), government and law enforcement bodies, courts and arbitrators (for example the Financial Ombudsman Service) when we have a legal obligation to do so or when we believe our compliance with the request to be fair, reasonable and lawful (for example to detect, prevent or investigate security breaches, fraud, money laundering or other crimes).

We may also disclose information to establish, exercise or defend legal claims (for example; to enforce our terms and conditions).

SPECIAL CATEGORY DATA

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

We may also collect, process and store special category data, such as:

  • Health information, for example, whether you have any health conditions that may impact on the advice we give you or that must be disclosed to providers

In addition to the legal basis for processing this information set out above table, we will be processing it either (i) with your consent or (ii) for the establishment, exercise or defence of legal claims.

MARKETING

We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. Please note, we will always treat your personal details with the utmost care and will never sell them to third parties for marketing purposes

Enhanced and Standard Service Clients (see service status)

We will only do so where we have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us. This means that we will send you material (normally a regular newsletter) as part of the service agreement you originally signed up to. However, you may opt out of receiving our newsletter at any time – see below.

Transactional Clients (see service status) and Other Parties

We will only do so where we have obtained your direct consent and will do so in accordance with any marketing preferences you have provided to us.

How to opt-out

You can opt-out of receiving marketing / newsletters at any time. If you wish to opt-out or amend your marketing preferences (for example, asking us to send information by post rather than email) please contact us:

By phone: 01432 820710

By email: leah@padstone-fm.co.uk

By Post: Padstone Financial Management Ltd., Court View, Preston Wynne, Hereford, HR1 3PE

WHETHER INFORMATION HAS TO BE PROVIDED BY YOU AND, IF SO, WHY

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with our services.

HOW LONG WILL YOUR PERSONAL DATA BE KEPT?

Whenever we collect or process your personal data, we will only keep information about you for as long as we need to fulfil the purposes for which we are processing your information. At the end of that retention period, your data will either be deleted or anonymised.

  • The nature and duration of our relationship with you.
  • The nature, type and duration of products and services we have supplied, or recommended, or arranged and administered for you.
  • Any regulatory or legal obligations imposed upon us.
  • Any legitimate interests we may have (for example, to defend any claims or complaints).

TRANSFER OF YOUR INFORMATION OUTSIDE OF THE EEA

We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

YOUR RIGHTS

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

  • To access personal data

  • To correct / erase personal data

  • To restrict how we use personal data

  • To object to how we use personal data

  • To ask us to transfer personal data to another organisation

  • To find out more about how we use personal data

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.

We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data

You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but we may need to verify the accuracy of the information first.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation with our regulator, the FCA or where we need to use your personal data to establish, exercise or defend legal claims.

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances, for example

  • where you think the information is inaccurate and we need to verify it;

  • where our use of your personal data is not lawful but you do not want us to erase it;

  • where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or

  • where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

To object to use of personal data

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).

You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

You can contact us for more information

If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, how we protect it, how long we keep it for, what rights you have, how you can make a complaint and where we got your data from.

If you would like to exercise any of the above rights, please:

  • email or write to Mark Young at mark@padstone-fm.co.uk or write to us at Padstone Financial Management Limited, Court View, Preston Wynne, Hereford HR1 3PE

  • let us have enough information to identify you, e.g. name, address, date of birth;

  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

  • let us know the information to which your request relates.

KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

OUR SUPERVISORY AUTHORITY

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).

We ask that you please attempt to resolve any issues with us before the ICO.

HOW TO CONTACT US

Please contact Mark Young if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact Mark Young please send an email to mark@padstone-fm.co.uk or write to us at Padstone Financial Management Limited, Court View, Preston Wynne, Hereford HR1 3PE.

GLOSSARY OF TERMS

we, us or our

 

Padstone Financial Management Limited

Is a company registered in England and Wales (04366170) and having its registered office at Court View, Preston Wynne, Hereford HR1 3PE.

Beneficiaries

 

Any person who gains an advantage and/or profits from something. In the financial world, a beneficiary typically refers to someone who is eligible to receive distributions from a trust, will or insurance policy. Beneficiaries are usually named specifically in these documents or have met the stipulations that make them eligible.

Complaints

 

As defined by the FCA is ‘any expression of dissatisfaction, whether oral or written, and whether justified or not, from or on behalf of an eligible complainant about the firm's provision of, or failure to provide, a financial service'.

contact information

 

These are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address.

Contractual information

 

Details about the products and services we provide to you including service status and fee models.

data controller

 

Means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services.

data protection regulation

 

Applicable data privacy and protection laws.

Dependants

 

is an individual who relies on another individual as a primary source of income. For example, minors (children who are under the age of majority) are dependants of their parents or legal guardians.

employment status

 

This is information about your work, if you are employed, self-employed, unemployed, a student, retired, in education or on job seeker allowance. This may include start date, end date and salary information.

FCA

 

The Financial Conduct Authority, being the independent watchdog that regulates financial services.

financial information

 

This is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60, bank and Building Society information.

health information

 

This is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history.

identity information

 

This is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number, social security number and tax identifier numbers.

inheritance tax

 

Inheritance Tax is a tax on the estate (the property, money and possessions) of someone who's died. This will form part of estate planning and will be concluded on a case-by-case basis.

lifestyle information

 

This includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, and retirement age and exercise habits.

product

 

This is an investment, pension, mortgage, protection and/or general insurance product in respect of which we provide advice to you. This could also include details of any existing products you may have.

product provider

 

A company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above).

service status

 

A client’s service status is defined in relation to their individual requirements and circumstances.

sanction check information

 

This is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering.

Vulnerability

 

A vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence).

Will (valid)

 

A will is a legal document that sets out your wishes regarding distribution of your property and care of your dependants when you die. A will must be voluntarily entered into and signed by the testator. A will must properly dispose of the testator's property.

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Padstone Financial Management Ltd is authorised and regulated by the Financial Conduct Authority, and is entered on the FCA register (www.fca.org.uk/register) under reference 430531.

The Financial Conduct Authority does not regulate taxation and trust advice will writing and some aspects of buy to let mortgages.

Contact Us
Email: mark@padstone-fm.co.uk
Telephone: 01432 820710
Fax: 01432 820701
Address: Court View, Preston Wynne, Hereford HR1 3PE

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