The Boring (but important legal) Bit:
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 your personal and financial circumstances when you engage us for financial planning. This may include special categories of personal data such as health, if necessary for the provision of our services. We may also collect information when you voluntarily complete client surveys or provide feedback.
Information about connected individuals
We may need to gather personal information about your close family members and dependents to deliver our service. 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. You may copy this privacy information to pass onto them, or request another copy from us.
Why do we need to collect and use your personal data?
The primary legal basis for the processing of your data is for the performance of our contract with you. The information we collect about you is essential to provide you with a superior service. Without collecting your personal data we’d also fall short of our legal and regulatory obligations. Our policy is to process only the data which is necessary for us to deliver our services and prevent money laundering or terrorist financing.
Who might we share your information with?
We won’t use your information for marketing purposes or authorise any third party to do so. To deliver our service, we may send your details to third parties such as those we engage for professional compliance, accountancy or legal services as well as providers we use to arrange your financial products.
Where third parties are involved in processing your data, we will have a contract in place with them to ensure; the nature and purpose of the processing is clear, they are subject to a duty of confidence in processing your data and they’ll only act according to our written instructions.
These third parties also have their own obligations to deal with your personal information appropriately. Sometimes a product or service may be administered from a country outside Europe. If this is the case, the third party must ensure that your information is adequately protected by a contract.
Where we need to forward your personal data to a third party, we’ll use appropriate security measures to protect your data in transit, including password protecting email attachments.
To fulfil our responsibility to prevent 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 shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re 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. You have the right to request deletion of your personal data. We will comply with such requests, subject to our regulatory obligations and legitimate interests noted above.
How can you access the information we hold about you?
You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please contact us using the 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 you think is incorrect.
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What if you are unhappy with how your data is processed?
You have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office
How to contact us
Telephone: 01592 641 612
In Writing: The Operations Director, Cairn Independent Ltd, Priory View, Victoria Road, Kirkcaldy KY1 2SA
Special categories of personal data
There are certain categories of personal data that are sensitive by nature. The categories include; data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and health data. Depending on the nature of the products and services you engage us for, we may need sensitive personal data particularly in relation to health. We will only gather special category personal data with your explicit consent.