This privacy notice explains how David Williams IFA Ltd and its Appointed Representatives use the personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage us for financial planning, financial advice, mortgage advice and investment management services. This information will relate to your personal and financial circumstances. 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.
We may also collect information when you complete client surveys or provide feedback to us.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us.
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. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data, we would also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we will obtain your explicit consent in order to collect and process this information.
Where necessary, we will process children’s personal data on a ‘legitimate interest’ basis. We will assess our legitimate interests against the interests, rights and freedoms of the child considering the nature and purpose of the processing and the potential risks it poses to the child. This policy will be clearly documented.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest.
We will not share your information for marketing purposes with companies outside our group of companies or other organisations.
In order 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.
Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit. This will include secure messaging, password protection and/or encryption of data.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
In principle, your personal data should not 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 also 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. Where regulation permits, we will not normally retain your personal data for longer than 30 years past our relationship ending.
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, however this is likely to result in us no longer being able to provide a service to you.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below.
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.
We may wish to send you information about our products and services and those of other companies in our group which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email, post or telephone.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate)
How to contact us
Or write to us at David Williams IFA Limited, 5 Waterside Way, Northampton, NN4 7XD