We understand that your privacy and the security of your personal information is extremely important. This notice sets out what we do with your personal information, what we do to keep it secure, from where and how we collect it, as well as your rights in relation to the personal information we hold about you. This notice contains some important information so please read it carefully.
Here are the things we think you’d really want to know:
Mercia Financial Planning Ltd is a firm of Independent Financial Advisers.
We aim to provide all our clients with clear financial direction. This is achieved by having a full understanding of your current financial position, your objectives and identifying your needs and requirements. This enables us to provide suitable and specific solutions for you.
We offer a wide range of specialist services to retail and corporate clients that include advice on:
• Tax efficient investments
• Protection – Life cover & Income Protection
• Inheritance tax planning
• Workplace pensions
• Long Term Care
• Equity Release
We believe in providing a high-quality service, with the emphasis on building a trusted, long-term relationship with our clients.
Who are we?
When we say ‘we’ or ‘us’ in this policy, we’re referring to the separate and distinct legal entity that makes up Mercia Financial Planning Ltd.
If you would like more information about how Mercia processes and controls your data, you can contact us by one of the means set out in the “Contact Us” section below.
You can contact us in the following ways:
Our address: 95 Long Street, Atherstone, CV9 1JL
• By writing to The Compliance Manager at the above address
• By emailing us at firstname.lastname@example.org
• By telephoning us on 01827 718 165
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Pension, Investment, Mortgage or Insurance requirements Your Personal Data may include:
• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing Pension, Investment, Mortgage or Insurance products and the terms and conditions relating to these.
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Pension, Investment, Mortgage or Insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to your Pension, Investment, Mortgage or Insurance. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
• Submit Your Personal Data to Product Providers, Mortgage Lenders, Insurance Product providers both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any pension, investment, mortgage or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
Our legal basis for processing your personal information.
Whenever we process your personal information we have to have something called a “legal basis” for what we do. The different legal basis we rely on include:
Consent: You have agreed to us processing your personal information for a specific purpose;
Legitimate interests: The processing is necessary for us to conduct our business, but not where our interests are overridden by your interests or rights.
Performance of a contract: We must process your personal information to meet the terms of your contract with us;
Prevention of fraud: Where we are required to process your data in order to protect us and our customers from fraud or money laundering;
Vital interests: The processing of your personal information is necessary to protect you or someone else’s life;
Legal claims: The processing of your personal information is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity; and
Legal obligation: We are required to process your personal information by law.
How do we use your information?
There are a number of ways in which we use your personal information, depending on why you are interacting with us.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
• Investment Providers, Mortgage lenders and insurance providers.
• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your pension, investment, mortgage or insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
• request copies of Your Personal Data that is under our control
• ask us to further explain how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety
If you are one of our suppliers
In order to work with our suppliers, we will collect information such as the names, contact numbers and email addresses of relevant employees discuss your services, to manage our contractual obligations and billing arrangements. This information may be shared with colleagues within Mercia that are involved in our supply chain including finance team members, contract managers and service users.
Transfer of personal data outside the European Union (EU)
We are committed to implementing technical and organisational measures that, by default meet the requirements of the data protection legislation and the appropriate level of security. We will not share your personal data with a third party organisation without a valid business reason, a contract or Data Sharing Agreement in place, or without your consent. We will not transfer your personal data to organisations outside the European Union (EU) unless that country or territory can ensure an adequate level of protection in relation to the processing of your personal data.
Automated decision making including profiling
Your personal data is not subject to automated decision-making, including profiling.
How long do we keep your data?
We retain your data primarily to meet statutory and regulatory obligations; secondly, your data is retained to enable us to pursue our legitimate business interests in relation to our clients, current and future requirements. Our retention schedules are available on request.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you; in such circumstances we may use such information without further notice to you.
You have a number of rights under data protection legislation which, in certain circumstances, you may be able to exercise in relation to the personal information we process about you. These include:
• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
Where we rely on consent as the legal basis on which we process your personal information, you may also withdraw that consent at any time.
If you are seeking to exercise any of these rights, please contact us using the details in the “Contact Us” section below.
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Mark Keenan – email@example.com
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
Requests, complaints or queries
We try to meet the highest standards when processing personal information. For this reason, we take any requests, complaints or queries we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate.
This privacy notice does not provide exhaustive detail of all aspects of our processing of personal information. However, we are happy to provide any additional information or explanation needed.
If you want to make a query, request, or a complaint about the way we have processed your personal information you can contact us directly:
• By writing to us at our registered address (above)
• By emailing us at firstname.lastname@example.org
• By telephoning us on 01827 718 165
Alternatively, you have the right to lodge a complaint with the regulator which oversees data protection law:
Information Commissioner’s Office
Tel: 0303 123 1113
Website address: https://ico.org.uk/global/contact-us/
Changes to this privacy notice
We keep our privacy notice under regular review. Notifications of changes to this privacy notice will be via email. This privacy notice was last updated in May 2018.