Punter Southall Defined Contribution Consulting Limited (“Punter Southall Aspire”, “we”, “us” or “our”) is committed to protecting and respecting your privacy.
This Policy is meant for individual clients receiving mortgage advice and financial planning services from Punter Southall Aspire and sets out the basis on which any personal data we collect from you, from third parties about you or that you provide to us will be processed by us.
We provide products and services to individuals for the purpose of providing financial advice and/or to administer the products and investments they have. We will act as the Data Controller of your personal data.
Our Data Protection Officer is Richard Garmon-Jones, who you can contact at:
· by email at Richard.Garmon-Jones@puntersouthallgroup.com
· by telephone on: 020 3327 5000
· by post at 11 Strand, London, WC2N 5HR
You can also contact us:
· by email at email@example.com;
· by telephone on 020 3327 5500; or
· by post at Punter Southall Aspire, 11 Strand, London WC2N 5HR
1 - THE TYPE OF DATA WE COLLECT ABOUT YOU, THE BASIS FOR COLLECTING IT, AND HOW WE WILL USE IT
We will collect various types of personal data about you when providing the products and services, depending on our agreement with you. Further details of how we use your personal data are set out below.
Personal data may include the following:
Role of PS Aspire
Basis for collecting the data
Providing guidance, mortgage advice, financial advice and / or administration of your products and investments.
Name, Date of Birth, Residential Address, National Insurance Number, Email Address.
We will initially process your data to enable us to take steps towards putting a contract in place with you. And thereafter we will process data under the terms of our contract with you.
To undertake anti-money laundering checks
Name, Date of Birth, Residential Address, National Insurance Number, Passport Number
We will process your data to meet our legal obligation to perform these checks.
2 - SPECIAL CATEGORIES OF PERSONAL DATA
In order to effectively provide financial advice and / or to administer your products and investments, we may be required to collect, process and disclose Special Categories of Personal Data about you, this may include data about your race, ethnic origin, genetics, biometrics (where used for ID purposes), physical or mental health, sexual orientation, political and religious beliefs, or membership of groups such as trade unions.
For example, we may need to process data about your health in relation to an application for life assurance.
Where we process Special Categories of Personal Data, we will do so with your explicit consent.
If at any time you do not want us to process Special Categories of Personal Data, you can contact us on the details shown above.
3 - DISCLOSURE OF YOUR INFORMATION
We will share your data with other companies to help us provide our services to you. The Recipients set out below may process your data, depending on the services or products we are providing:
Product providers, which may include life assurance companies, mortgage lenders, investment companies, and general and health insurers, depending on your needs. This is so that we can obtain quotations, arrange policies and plans for you, and to help administer them;
Intelligent Office, Enable, JCS, IRESS and Watermark: provide back office systems which help us provide the products and services we are contracted for.
The Exchange and Trigold from IRESS: to obtain quotations on financial products such as annuities and mortgages.
Hubspot and Communigator: to manage how we provide information on services and products and financial news updates that may be of interest to you.
SurveyMonkey: for client satisfaction surveys
Microsoft Teams and Skype for Business for recording video and voice calls. You will be notified if your call is being recorded.
SmartSearch for undertaking anti-money laundering identification checks.
Research, reporting and modelling tools to help us make personal recommendations to you, provided by Prestwood (Truth), Selectapension, Distribution Technology (Dynamic Planner), Synaptics, FE Analytics, Adviser Asset, Paraplanning Online and Voyant.
We enter into agreements with these third parties, part of which is to ensure that they respect the security of your data and use it only in accordance with data protection laws.
We will also disclose your personal data to third parties:
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
4 - COLLECTION OF PERSONAL DATA ABOUT OTHER PEOPLE (E.G. YOUR SPOUSE/PARTNER/DEPENDANT)
To allow us to provide tailored advice, we will collect personal data about you, and may collect personal data about other people you wish us to consider in the planning process such as a spouse, partner, dependant or beneficiary (third party personal data). We will process this third party personal data on the basis that you have the authority to share that data with us. Some of this data may be special category data, for example information about relevant health conditions. Where you provide special category data to us in this form, you consent to us processing this data for the purpose of providing our services to you.
5 – CALL RECORDING
We may record our audio or video conversations with you but only where you have consented to us doing so. This is to ensure that we have an accurate record of your instructions, which we may refer to in the future to confirm what was discussed, and to help us to provide products and services that are suitable for your needs. The recording may also be used for internal training and monitoring purposes.
We’ll keep the recording secure and restrict access to it to those of our staff who need for the reasons I’ve just outlined. We’ll only retain it for as long as we need to for those purposes and then it will be securely deleted.
We don’t use the recorded data for marketing purposes.
6 - INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA
It is not intended that your information be transferred outside the European Economic Area (EEA), but if it is, Model Clauses or other mechanisms approved by the European Commission or the Information Commissioner's Office (ICO) will be put in place prior to us processing your information. Where required we will also obtain your consent.
You can obtain further information regarding the mechanisms used to safeguard your data by contacting our Customer Care team or Data Protection Officer at the contact details listed above.
7 - STORAGE OF YOUR PERSONAL DATA
We will only keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Policy, and thereafter for as long as we need to keep it for legal purposes. Generally we will delete your records six years after our relationship with you comes to an end. However, we are obliged to retain some data for longer, for regulatory purposes. For more information about how long we will keep your personal data, please contact us at the details shown above.
We take the security and confidentiality of your personal data very seriously. We will use strict procedures and security features to aim at preventing unauthorised access, disclosure, alteration or deletion of your data. This includes restrictions on who can access data, using encryption to protect data when it is being transferred or stored, and maintaining corporate firewalls to safeguard against unauthorised access. For full details of the security measures we have in place, please contact us using the details shown above.
8 - YOUR RIGHTS
Data protection laws provide you with the following rights to:
be informed: at the time your information is collected, you should be given, or can ask for information about how your information is collected and used;
request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected in certain circumstances;
request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. A reason we may not be able to comply is where we have a legal obligation to retain your data; an example of this is where we give pension transfer advice and the Financial Conduct Authority requires us to keep these records indefinitely. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
request the restriction of processing of your personal data, for example if you want to establish its accuracy or the reason for processing it; and
request the transfer of your personal data to another party.
You also have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights above). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive, for example if you keep requesting copies of the same data. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. They can be contacted at:
The Information Commissioner's Office
Telephone: 0303 123 1113 or 01625 545745
Fax: 01625 524510
Any changes we make to our Policy in the future will be posted on this page and, where appropriate, notified to you. Alternatively please check back frequently to see any updates or changes to our Policy.
10 - CONTACTING US
If you have any queries, comments or requests regarding this Policy or you would like to exercise any of your rights set out above, you can contact us in the following ways:
by email at firstname.lastname@example.org
by telephone on 020 3327 5500; or
by post at Punter Southall Aspire, 11 Strand, London WC2N 5HR