Fraser Wealth Management
PRIVACY AND COOKIES POLICY
Fraser Wealth Management is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (together with and any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to us will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation the Data Controller is Fraser Wealth Management Limited
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all the following types of information from you in the course of providing our financial planning services:
- Information that you provide by corresponding with us by telephone, email, letter, social media or other means, applying for our services, using our website or online client portals, in discussion with one of our advisers or other authorised representatives or by participating in feedback or surveys.
- Contact details such as name(s), address(es), telephone number(s), email address(es).
- Identification information such as such as signature, date of birth, gender, nationality, residency, national insurance number or other national identity numbers such as a passport number, driving license, tax identification numbers and tax rate, income and financial details, bank or building society account details, policy details, marital status, occupation, benefits and entitlements, employment status, employer and job title.
- Information for advice services such as investment goals, assets, liabilities, income protection and care needs, current or desired lifestyle and cash flow information.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
The provision of your name, address and date of birth, as well as other personal data is required from you to enable us to fulfil our regulatory and legal obligations. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
Information we collect from other sources
We may also obtain personal data from other sources as follows:
- We may receive information from third parties, such as your appointed representative, other financial advisers you may have, tax advisers, financial service providers such as a pension provider or insurance company, healthcare professional, trustees or your employer.
- We may receive information from companies we use to verify your identity and/or to prevent fraud such as credit reference agencies (please note such companies may record details of the search) including the electoral register and credit information, in accordance with our legal obligations.
- We may also receive information from third parties who contact us such as Her Majesty’s Revenue & Customs (HMRC), the Department for Work & Pensions (DWP), the police or other government agencies.
- We may obtain personal data from public sources such as Companies House.
We also collect, store and use personal data where you have provided this to us in respect of third parties, such as beneficiaries, spouses, civil partners or dependants. If you do so, you confirm that you are responsible for and entitled to provide us with this information and that you have informed those third parties of our identity and the purposes for which their personal data (including sensitive personal data) will be processed. We will not use such information except for the purpose for which you have provided it.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you and to comply with our legal obligations. 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’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information. Special category data is defined as;
- Ethnic origin
- Trade union membership
- Biometrics (where used for ID purposes)
- Sex life
- Sexual orientation
Purposes of processing
We use information held about you in the following ways:
- To perform the contract we have entered into with you. For example to:
- provide an investment proposal or financial advice;
- set up and administer any services you should receive from Fraser Wealth Management as part of our agreement with you, such as reviews, report writing, valuations, cash flow modelling;
- manage your investments;
- confirm your identity and communicate with you; and
- exercise our rights in our agreements.
- To comply with a legal obligation. For example:
- where we are required to use your personal data and maintain records of our dealings with you by our regulators;
- to prevent, investigate and detect fraud and carry out fraud, credit and anti-money laundering checks;
- to respond to complaints and data subject access requests; and
- where it is needed in the public interest such as the investigation, prevention or detection of criminal activities.
- Where it is necessary for our legitimate interests (or those of a third party) provided your interests and rights do not override those interests. For example:
- to establish, exercise or defend our legal rights where we are faced with any legal claims or where we want to pursue legal claims;
- to respond to and manage ad hoc enquiries and complaints;
- to provide management information to enable us to monitor our performance and understand our business, to maintain our business records, manage our business position and capabilities, to receive professional advice, to improve our services and for training purposes;
- for accounting, auditing, and corporate governance purposes;
- to assist debt recovery;
- to provide and improve client support; and
- to manage risk for us and our clients.
- Where we have obtained your explicit consent to do so. For example:
- to process sensitive personal data or criminal offences information;
- to provide you with marketing services.
In addition to the above uses we may use your information to notify you about goods or services which may be of interest to you. We will only do this if you have consented to such communication. If you later decide that you do not want us to use your data in this way please inform us at any time.
We will not sell your details to any third party. We will not use your personal data for marketing purposes without your explicit consent.
DISCLOSURE OF YOUR INFORMATION
We routinely disclose your personal data to third parties as follows:
- We may share your data with third parties who we use to provide our services such as product providers; insurers; custodians, administrators, fund providers, investment platforms and exchanges, banks, brokers, investment managers, trustees, risk profile software, cash flow software, in accordance with our contractual and legal obligations.
- We may share your data with other third party service providers who support the provision of our services, such as IT and back office administrations services; compliance or audit services; software for anti-money laundering, anti-fraud, credit or identity verification checks; transaction reporting; direct debit schemes; underwriters; healthcare providers.
We may also disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- if all or substantially all our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our client agreement/service charter; or
- to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you; or
- with a person or company you have authorised to deal with us on your behalf.
Other than as set out above, and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing this data through your wealth platform portal if you have one, informing your adviser or by writing to the address below. If you have any questions about how we use data collected which relates to you, please contact us by writing to Data Protection, Fraser Wealth Management, Exchange Station, Tithebarn Street, Liverpool L2 2QP.
We will endeavour to update your personal data within seven working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.
How long we keep your personal data
We will hold personal data in line with our regulatory and legal obligations as set out by our regulator. We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.
Where we store your personal data
Fraser Wealth Management does not typically transfer personal data outside of the EEA. All of the information that we hold about you is stored on our secure servers and back office system within the EEA.
If for any lawful or contractual reason we need to transfer any information outside of the EEA, we will take the appropriate steps required by applicable data protection laws to ensure your personal data is protected and ensure your data is treated consistently with EEA and UK data protection.
We will not otherwise transfer your personal data outside of the United Kingdom OR EEA 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.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- Access to your personal data and to certain other supplementary information that this Policy is already designed to address
- Require us to correct any mistakes in your information which we hold
- Require the erasure of personal data concerning you in certain situations
- Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal data concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal data
- Otherwise restrict our processing of your personal data in certain circumstances
- Claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation at www.ico.org.uk.
If you would like to exercise any of those rights, please send it in writing to Data Protection, Fraser Wealth Management, Exchange Station, Tithebarn Street, Liverpool L2 2QP.
We may need specific information from you to help us confirm your identity to ensure your right to access the information or exercise any rights to the data. Please let us know the information to which your request relates, such as policy numbers if you have them.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We may collect information about your mobile phone, computer or other device from which you access our Website including where available your IP address, operating system and browser type, for systems administration and to report aggregate information to third parties affiliates. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual. We may, however, use such information in conjunction with the data we have about you in order to track your usage of our services.
A Cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
The cookies we use include:
- “Analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to Data Protection, Fraser Wealth Management, Exchange Station, Tithebarn Street, Liverpool L2 2QP.