All data held by Chelwood Financial Management is treated in the utmost confidence and in accordance with our Privacy Policy, shared only with third parties by request or in the execution of your directives and services.
Chelwood Financial Management collects uses and is responsible for 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 of that personal data for the purposes of those laws. When we mention “we”, “us” or “our” we are referring to Chelwood Financial Management. This privacy policy explains how we use any personal information we collect about you.
How to contact us
We have appointed a Data Protection Officer to oversee compliance with this policy. If you have any questions about this policy or how we handle personal information, please contact the CODP in writing using the details below.
By email: chelwood@aol.com
In writing to:
The Data Protection Officer,
Chelwood Financial Management,
The Coach House
Wood Lane
Parkgate
Cheshire
CH64 6QU
Registrations
Our FCA Registration number is 430755
Our ICO Registration Number is Z4821931
Changes to our privacy policy
We keep our privacy policy under regular review and we reserve the right to update this policy at any time and we will provide you with a new policy when we make substantial updates
This privacy policy was last updated on 25/05/2018.
What information do we collect about you?
We collect information about you when you engage us for financial planning and our related services. This information will relate to your personal and financial circumstances E.G. name, title, job title, address, telephone number, email address, photographic identification, date of birth, bank account details etc. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. We may also, where it is necessary, use personal information to pursue our legitimate interests (or those of a third party) and we believe that using personal information in that way is not overridden by the interests or fundamental rights of the person to whom the information relates. The information that we collect about you is essential for us to be able to effectively carry out the services that you require from us. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
How will we use the information about you?
We collect information about you to provide you with the services for which you engage us. Many of our services are broad and our objective is to meet your expectations through proactive communications across the range of your financial planning requirements.
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 collect, store and use the following ‘special categories’ of more sensitive personal information:
- health information and lifestyle information when providing intermediary services in relation to a protection insurance product.
Who might we share your information with?
We won’t share your information for marketing purposes with other companies. We may, with your explicit permission pass details to firms you have agreed may call you about a product or service aligned with (but not part of) our financial planning.
To deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
All third parties are required to take appropriate security measures to protect your personal information in line with General Data Protection Regulation, to ensure that the nature and purpose of the processing is clear. Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
How long do we keep hold of your information?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
Changes to your data
It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your working relationship with us. If your personal information changes, please contact us.
How can you access the information we hold?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all your personal information, please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Marketing
We will not use your personal information for marketing.
Transfer of information outside of European Economic Area (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.
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.
Your rights
You have legal rights under data protection regulation in relation to your personal data. You have the right to:
- Request access to your personal information. This is commonly known as a subject access request. This enables you to receive a copy of the personal information we hold about you and to check that we are processing it lawfully.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to how we use / are processing your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it
- Request the transfer of your personal information to another party.
- Request the reconsideration of an automated decision. This enables you to ask us to reconsider a decision that was made solely by automated means or to ask for human intervention.
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.
What can you do if you are unhappy with how your personal data is processed?
If you have any concerns over how we use your data, please contact our Data Protection Officer (as detailed on page 1). If you are not satisfied that we have addressed your concerns adequately, you have the right to lodge a complaint with our supervisory authority – the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation. We ask that you please attempt to resolve any issues with us before contacting the ICO. The ICO contact details are below:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113
Web: www.ico.org.uk