During the course of your engagement with Hood Financial Planning, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history. This information is referred to as ‘Personal Data’.
This statement has been created to allow us to describe how we will use your Personal Data, and the various rights you have in relation to your Personal Data.
Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
In the context of providing you with assistance in relation to the requested financial service, 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 investment, pension, mortgage, protection/insurance or equity release products and the terms and conditions relating to these.
How we use your information?
This privacy notice tells you how we, Hood Financial Planning, will collect and use your personal data for providing further information regarding the provision of independent financial advisory services.
Why does Hood Financial Planning need to collect and store personal data?
In order for us to provide our Clients with financial planning services, we need to collect personal data in order to provide this service. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
What other personal data may we need?
In order to provide our service to you effectively, we may need to gather personal information about your close family members and dependents. 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.
Will Hood Financial Planning share my personal data with anyone else?
Dependent on the financial service being requested, we may pass your personal data on to third-party service providers to Hood Financial Planning. Any third parties that we share your data with are obliged to keep your details securely, and to use them only to quote for, or provide the requested investment service – for example an insurance policy.
When they no longer need your data to fulfil this service, they will dispose of the details in line with Data Retention best practice and internal policy. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, or unless we are legally required to do otherwise.
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 will Hood Financial Planning use the personal data it collects about me?
Hood Financial Planning will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
The security of your Personal Data is paramount to us and we have invested in a number of Cyber Security and Privacy initiatives to ensure we have the right level of protection in place.
We will always take reasonable steps to safeguard your Personal Data against it being accessed unlawfully or maliciously by any third party.
How long will Hood Financial Planning retain the data it collects about me?
Hood Financial Planning is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices, such as the Financial Conduct Authority (FCA) which stipulates the minimum retention periods required for financial data. These are:
- Five years for investment business
- Three years for insurance business
- Indefinitely for pension transfers and opt-out business
These are minimum periods, during which we have a legal obligation to retain your records. We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so.
Under what circumstances will Hood Financial Planning contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Hood Financial Planning at your request, can confirm what information we hold about you and how it is processed. If Hood Financial Planning does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the GDPR Owner, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Hood Financial Planning or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access personal data?
Hood Financial Planning accepts either Passport or Driving Licence as valid forms of ID when information on your personal data is requested. This is to ensure that we are able to verify your identity before disclosing any personal information.
Cookies
Our website does not collect personal data and currently has no tracking cookies to track visitor use of the website and to compile statistical reports on website activity.
For further information visit http://www.allaboutcookies.org.
Marketing
If you agree, we may email you about other products or services that we think may be of interest to you and may suit your needs and circumstances.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by telephone, email or post.
We will not share your information for marketing purposes with other companies.
Google Analytics
Hood Financial Planning, like many other organisations, may use Google Analytics to provide us with analytical data on our website traffic and user behaviour. You can refer to privacy.google.com/businesses to learn more about Google’s data privacy policies and approach.
Changes to our privacy policy
We keep our privacy policy under regular review and we will inform you of any changes when they occur. This privacy policy was last updated in May 2018.
Contact details of the GDPR Owner:
For any GDPR queries please contact Mark Anderson of Hood Financial Planning on:
Tel: 0161 631 2710
Email: info@hoodfp.com
Address: Centurion House, 129 Deansgate, Manchester, M3 3WR.
The right to lodge a complaint with a Supervisory Authority
Hood Financial Planning are committed in protecting your personal information, however if you have any concerns regarding the way that we are storing or processing your personal information, you have the right to lodge a complaint with a supervisory authority. In the UK this is the Information Commissioners Office (ICO) and more information can be found on their website, www.ico.org.uk.