Investors Planning Associates Limited (‘IPA’) is committed to protecting your personal information.
This privacy notice explains how we use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage us for our financial planning services. This information will relate to your personal and financial circumstances. This will include:
- Information about who you are – for example your name, date of birth, national insurance number, nationality and contact details;
- Information connected to your service with us – for example your bank account details and details of your financial plans, assets and liabilities;
- Information classified as ‘sensitive’ personal information (‘special category information’) – for example relating to your health. Depending upon the nature of the services that you engage us for, in order to ensure that our financial planning is suitable for your personal requirements, we may need to obtain your sensitive personal data in relation to your health. This information may also be required by providers in order to carry out their underwriting assessments. Where we collect any special category information about you, we will seek your explicit consent prior to processing it. If you do not give us your explicit consent, we will not be able to provide those services to you;
- Information on children – for example where a child is named as a beneficiary on a policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name and date of birth);
- Information about your contact with us – for example meetings, phone calls, letters, and electronic messages;
- Information that is automatically collected – for example via cookies when you visit our website. We will use your information collected from the website to personalise your repeat visits to the site;
- Information if you visit one of our offices – for example visual images collected via CCTV.
Information about connected individuals
We may need to gather personal information about your close family members, dependants, beneficiaries and business partners in order to provide our services to you. 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. We will provide a copy of this Privacy Notice to them or, where appropriate, ask you to pass a copy of this Privacy Notice to them.
Why do we need to collect and use your personal information?
The primary legal basis that we intend to use for the processing of your personal information 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, as well as ensuring that we can fulfil our legal and regulatory obligations.
Where special category information is required, we will obtain your explicit consent in order to collect and process this information. If you do not give us your explicit consent, we will not be able to provide our services to you
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?
In order to deliver our services to you effectively, we may send your details to third party providers of professional services such as those that we engage for administration, 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.
Who might we share your information with?
Where it is necessary for your personal data to be forwarded to a third party or returned to you, we will use appropriate security measures to protect your personal data in transit, which will include (but is not limited to) encryption of all data sent electronically.
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.
If you explicitly consent, we may contact you about other services that we provide that we think may be of interest to you. We will not share your information for marketing purposes with other companies.
You have the right at any time to stop us from contacting you for marketing purposes by writing to or emailing the Chief Executive of IPA (email@example.com or see the contact details at the end of this Privacy Notice).
How long do we keep hold of your information?
During the course of our relationship with you, we will retain your personal data which is necessary to provide our services to you effectively. We will take all reasonable steps to keep your personal data up to date throughout our relationship. We are also subject to regulatory requirements to retain your personal data for specified minimum periods. These are:
- Five years for investment business;
- Three years for mortgage business;
- Indefinitely for pension transfers and opt-out business;
- Three years for insurance business.
These are minimum periods during which we have a legal obligation to retain your records.
We reserve the right to retain your data for longer than those minimum periods where we believe it is in our legitimate interests to do so. For example, we will retain your data in order to be able to investigate any complaints in the future that may be made about the advice or services we have provided for you. In deciding the period that we will retain your data on those grounds, we will refer to the Financial Ombudsman Services rules on time limits for complaint handling.
In all cases, we will not retain your personal data for longer than six years past the date of first becoming aware of your death (or of first becoming aware of the death of the last holder of a jointly held plan).
As noted below, you have the right to request erasure of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
What are your individual rights?
You have several rights in relation to how IPA uses your information.
1. Right to be informed
You have a right to receive clear and easy to understand information about what personal information we have, why we have that information and who we share it with. We do that in this Privacy Notice.
2. Right of access
You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a Data Subject Access Request to the Chief Executive of IPA either verbally or in writing (using the contact details at the end of this Privacy Notice). Such requests will be acted upon by secure means within one month of receipt.
3. Right to request that your personal information be rectified
We have an obligation to ensure that your personal information is accurate and up to date. If your personal information is inaccurate or incomplete, you can request that it is corrected. Any such Data Rectification Request should be made to any employee or Associate of IPA either verbally or in writing. Such requests will be passed on immediately to the Chief Executive of IPA and acted upon within one month of receipt.
4. Right to request erasure
You have the right to request erasure of your personal data (also known as ‘the right to be forgotten’). We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above (under ‘how long do we keep hold of your information’). In order to request erasure of your personal data, you need to submit a Data Erasure Request to any employee or Associate of IPA either verbally or in writing. Such requests will be passed on immediately to the Chief Executive of IPA and acted upon within one month of receipt.
5. Right to restrict processing
You have the right to ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information, but must ensure that we do not use it in the future for those reasons you have restricted. Any such Data Processing Restriction Request should be made to any employee or Associate of IPA either verbally or in writing. Such requests will be passed on immediately to the Chief Executive of IPA and acted upon within one month of receipt.
6. Right to data portability
You have the right to ask for a copy of your personal information that we process electronically to be transferred to another organisation for their use. This enables you to reuse your personal information for your own purposes across different services – for example if you were moving your financial planning services to another financial adviser. In order to request a transfer of your personal information to another organisation, you need to submit a Data Transfer Request to the Chief Executive of IPA either verbally or in writing (using the contact details at the end of this Privacy Notice). Such requests will be acted upon by secure means within one month of receipt.
7. Right to object
You have the right to object to IPA processing your personal information for direct marketing purposes. Any such objection should be made to the Chief Executive of IPA either verbally or in writing (using the contact details at the end of this Privacy Notice). Such requests will be acted upon immediately.
Our website contains links to other websites. This privacy notice only applies to our website so when you link to other websites you should read their own privacy policies.
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
What can you do if you are unhappy with how your personal data is processed?
We will always endeavour to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please contact the Chief Executive (firstname.lastname@example.org or see contact details below).
You also have a right to lodge a complaint with our supervisory authority. Their contact details are:
Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
0303 123 1113 (local rate)
Changes to our Privacy Notice
We keep our privacy notice under regular review and we will place any updates on our website and in your Personal Finance Portal (if applicable). If there are important changes such as changes as to where your personal data will be processed, we will contact you to let you know.
This Privacy Notice was last updated on 1 May 2018.
How to contact us
If you have any questions about our Privacy Notice or the information we collect or use about you, please contact:
The Chief Executive
Investors Planning Associates Limited
Sterling House 175 High Street Rickmansworth WD3 1AY