Privacy Policy
PRIVACY NOTICE
At HFB Financial Planning Ltd we respect your privacy and the
confidentiality of your personal information.
HFB Financial Planning Ltd
is an appointed representative of Quilter Financial Services Limited and
Quilter Mortgage Planning Limited who are part
of the Quilter Group of companies.
For further details on the companies in our
group, please visit: https://www.quilter.com/about-us/our-brands/
This Privacy Notice explains:
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Who we are
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What personal information we collect
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How we use your personal information
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Who we share your information with and why
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How we keep your information secure
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Your rights
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How to contact us
Who we are
HFB Financial Planning Ltd provide financial planning solutions and advice
through experienced and qualified advisers based in the UK.
Currently, HFB Financial Planning Ltd and Quilter Financial Planning
(Quilter) jointly determine the purposes and means of processing personal
client data relating to giving advice. This means we’re joint data
controllers for these core advice giving activities and therefore responsible
for managing this client data and ensuring compliance.
However, HFB Financial Planning Ltd
is solely responsible for some activities, for example any direct
marketing that we undertake.
What personal information we
collect
Personal information includes your name,
address, or phone number and other information that isn’t otherwise publicly
available. We collect personal information about you when you contact us about
products and services, visit a financial advisor, visit a website we may have
or register to receive one of our newsletters (if applicable).
The type of personal information we collect will depend on the
purpose for which it is collected and includes:
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Contact details
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Information to verify your identity
Ø Family, lifestyle, health
and financial information
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Payment details
We collect personal information directly from you. For example, we
ask for personal information at the start of our relationship and in subsequent
communications, in order to check your identity and protect you from fraud.
This is a legal requirement and is important to help safeguard you against
potential crime.
Special Category Information
In some instances, it is necessary to collect
more sensitive information (such as health or lifestyle information) which is
called special category data. This is to allow us to provide our financial
advice service to you. We will always obtain your consent during the advice
process to gather this data and explain what information we require and why it is
needed. Sensitive personal information will always be processed and stored
securely. You can withdraw your consent at any time to us processing this data,
however, this may mean that you can no longer access the service or product the
information was gathered for.
Cookies
We also collect information about you from other sources. For
example, our website automatically collects information from your computer
using “cookies” which provides us with limited personal information. Cookies
are small text files that are placed on your computer by websites that you
visit. They’re widely used in order to make websites work, or work more
efficiently, as well as to provide information to the website owners. For
further information visit www.aboutcookies.org
or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above
websites tell you how to remove cookies from your browser. However, in a few
cases, some of our website features may not function as a result.
Data retention
We keep your personal information only as long as is necessary for
the purpose for which it was collected and to meet regulatory or legislative
requirements.
Advice data is retained for 50 years to meet
our regulatory requirements.
Personal information will be securely disposed of when it’s no
longer required, in accordance with our Data Retention and Disposal Schedule. A
copy of this is available using the contact details below.
On what basis do we collect data?
The processing of your personal data is allowed under a number of
lawful bases. The data required for the provision of products and services is
processed on the basis there’s a contract with you to do so. Any relevant
marketing activity we undertake is done because, as a firm, we have a
legitimate interest to do so. However, you have rights, as listed below, which
impact how we can use and process your data.
How we use your personal
information
We process your information in order to
support and maintain our contractual relationship with you and to comply with
legal and regulatory requirements. This includes the following:
Ø Providing our advice, products or services to you
Ø Carrying out transactions you have requested
Ø Confirming and verifying your identity for security
purposes
Ø Credit scoring and assessment, and credit management
(where applicable)
Ø Detecting and preventing fraud, crime, money laundering
or other malpractice.
To investigate any complaint or enquiry raised in regards to your adviser or the advice given.
We also process your data for specific
business purposes to enable us to give you the best products and services and
the best and most secure experience. For example, we process your information
to send you marketing that is tailored to your interests.
Our business purposes include the following:
Ø Enhancing, modifying, and personalising our services for
the benefit of our customers
Ø Providing communications which we think will be of
interest to you
Ø Market or customer satisfaction research or statistical
analysis
Ø Audit and record keeping purposes
Ø Enhancing the security of our network and information
systems.
Ø Supporting the testing and maintenance of systems
You have the right to object to this processing
if you wish, please see “YOUR RIGHTS” section below. Please bear in mind that
if you object this may affect our ability to carry out the tasks above for your
benefit.
We may also process your personal data as
part of an acquisition or sale. Should this happen, you will be notified about
any change to processing or data controller arising as a result of this
activity.
Who we share your information with
and why
We share your information with trusted third parties who perform
tasks for us and help us to provide the services you require these include:
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Quilter Financial Planning Limited;
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Other adviser firms in the network for the purpose of providing
you with advice (with your Consent);
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The Quilter Group of companies to enhance the services and
products we can offer you;
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Third parties to verify your identity, in line with money
laundering or other requirements (this may involve carrying out checks with
credit reference databases);
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Third parties who perform tasks for us to help us set up or
service your plan (these third parties may be based in countries outside the UK
but where they are, we’ll undertake an assessment of safeguards in place);
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Other organisations, including regulatory bodies, the police and
fraud prevention agencies, to prevent and detect fraud;
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Third parties where required by law, court order or regulation;
and
Ø Third
parties as part of an acquisition or sale.
Ø The
Quilter group or third parties for assurance or audit purpose
How we keep your information
secure
We’re committed to ensuring the confidentiality of the personal
information that we hold and we continue to review our security controls and
related policies and procedures to ensure that your personal information
remains secure.
When we contract with third parties, we
impose appropriate security, privacy and confidentiality obligations on them to
ensure that personal information is kept secure.
If we work with third parties in countries
outside the UK, we ensure these are countries that the European Commission has
confirmed have an adequate level of protection for personal information, or the
organisation receiving the personal data has provided adequate safeguards.
In limited circumstances, data may be accessed
outside of the UK i.e. by employees when they travel. In these circumstances,
we ensure there are appropriate information security measures in place to
safeguard your information.
Profiling
Basic identifiers about
you (e.g. your name and address) is matched with information from Experian
Marketing Services to create demographics and infer customer ‘types’ so that
Quilter Financial Planning and the Quilter group of companies can define groups
based on factors like interests, age, location and more. This helps Quilter
Financial Planning and the Quilter group of companies better understand our
customers in order to adapt and improve our products and services.
If you would like to know
more about the information we receive from Experian Marketing Services, you can
visit their website (www.experian.co.uk/privacy/consumer-information-portal) which explains who Experian Marketing Services are,
what they do and why.
Your rights
HFB Financial Planning Ltd
tries to be as open as it can be in terms of giving
people access to their personal information and therefore have outlined your
rights below. This privacy notice was drafted with brevity and clarity in mind,
therefore further information can be gathered by contacting us using the
details below, or more information about your data protection rights can be
found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
Marketing
You have the right to opt out of receiving
marketing information and tell us what your communication preferences are by
contacting Quilter Financial Planning using the details provided at the end of
this notice or by using the opt out option below or on any email marketing. You
may opt out at any time if you don’t want to receive any further communications
of this nature.
Individual data rights and requests
Ø The right to be informed – You can request that we
provide ‘fair processing information’, typically through this privacy notice;
Ø The right of access - You may request a copy of the
personal information we hold about you using the contact details found on the
end of this privacy notice;
Ø The right to rectification - The accuracy of your
personal information is important to us. You have the right to ask us to update
or correct your personal information;
Ø The right to erasure – You may
request the deletion or removal of personal data where there’s no compelling
reason for its continued processing;
Ø The right to object – You may object to the processing of
your data based on legitimate interests;
Ø The right to restrict processing - You
have a right to request we ‘block’ or suppress processing of your personal
data;
Ø The right to data portability – You may request to obtain
and reuse your data; and
Ø The right not to be subject to automated decision-making
including profiling.
If you wish to
correct, restrict, delete or make changes to your personal information, or any
of the data subject rights listed above, please contact us at the address or
email listed below.
How to contact us
If you have questions about this notice, need
further information about our privacy practices, or wish to give or withdraw
consent, exercise preferences or correct your personal information, please
contact us using the following details. Quilter will liaise with HFB Financial
Planning Ltd on your behalf to effect your requests.
The Office of Data Protection
Quilter Financial Planning Limited
Senator House
85 Queen Victoria Street
London
EC4V 4AB
QFPDataGuardian@quilter.com
How to complain
If you wish to raise a complaint about how we have handled your
personal data, you can contact The Office of Data Protection who’ll investigate
the matter.
If you’re not satisfied with our response, or believe we’re not
processing your personal data in accordance with the law, you can complain to
our regulator:
Information Governance Department
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
www.ico.org.uk/concerns
