DATA PRIVACY NOTICE
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
A Glossary of Terms can be found at the end of this document.
WHO WE ARE?
Carrington Wealth Management collects uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation, and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “Carrington Wealth Management or Carrington”, “we”, “us” or “our” we are referring to Carrington Investment Consultants Limited.
Carrington is a company registered in England and Wales (company number 3193939) whose registered office is at One Chapel Place, London, W1G 0BG. Carrington Investment Consultants Limited is authorised and regulated by the Financial Conduct Authority. Carrington Investment Consultants Limited Financial Services Register number is 566 946.
We provide you with intermediary services.
THE PERSONAL DATA WE COLLECT AND USE
While providing our service to you we may collect the following personal data when you provide it to us:
- Contact information
- Identity information
- Financial information
- Employment status
- Lifestyle information
- Health information
- Details of any vulnerability
- Details of your dependents and/or beneficiaries under a policy (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below).
- Product details
WHAT DATA WE COLLECT
- Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
INFORMATION COLLECTED FROM OTHER SOURCES
We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
The personal data we obtain from other sources may include the following:
- From lenders and/or product providers:
- Product details
- Financial information
- Contact and identity information
- From identification and verification checking agencies:
- Identity information
- sanction check information
HOW WE USE YOUR PERSONAL DATA
The below table overleaf sets out:
- How we use your personal data
- The lawful bases upon which we collect and use your personal data
- Who we routinely share your personal data with
- 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’ll 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’ll only act in accordance with our written instructions.
SPECIAL CATEGORY DATA
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process:
- health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
In addition to the lawful basis for processing this information set out in the above table, we will be processing it either
(i) for the purpose of advising on, arranging or administering an insurance contract or
(ii) for the establishment, exercise or defence of legal claims.
In the course of our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information set out in the above table, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.
We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent or have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.
You can opt-out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us:
By phone: 020 7078 4849
By email: email@example.com
By Post: One Chapel Place, London, W1G 0BG
In addition, you can opt-out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every email.
WHETHER INFORMATION HAS TO BE PROVIDED BY YOU, AND IF SO WHY
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.
HOW LONG YOUR PERSONAL DATA WILL BE KEPT
We will retain personal data to enable us to fulfil our obligations to you as a client or contact, and our professional risk management and regulatory obligations. This data will be retained so far as it remains relevant to the services that we provide (or have provided) to you and any superfluous data will be cleaned from our systems regularly.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- 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 data for longer where we believe it’s in our legitimate interests to do so.
For further information visit http://www.allaboutcookies.org/
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.
TRANSFER OF YOUR INFORMATION OUT OF THE EFA
We utilise third parties that may store your personal data in the following countries which are located outside the European Economic Area (EEA) as follows:
- USA is used to process and store data;
- Australia is used to process and store data;
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA. All third parties who do process and store data outside of the UK and EEA will be subject to due diligence to ensure they adhere to the requirements of GDPR and that sufficient processes and policies are put in place to help safeguard your data and privacy rights and give you remedies in the unlikely event of a misuse of your personal data. To obtain copies or links to such third-party policies, please contact us at firstname.lastname@example.org.
You have a right to ask us for more information about the safeguards we have put in place as mentioned above. To learn more, please see ‘Your rights’ below.
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:
- To access personal data
- To correct/erase personal data
- To restrict how we use personal data
- To object to how we use personal data
- To ask us to transfer personal data to another organisation
- To find out more about how we use personal data
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.
We will charge a fee if we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
To access personal data
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.
To rectify/erase personal data
You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
To restrict our use of personal data
You can ask that we restrict our use of your personal data in certain circumstances, for example:
- Where you think the information is inaccurate and we need to verify it;
- Where our use of your personal data is not lawful, but you do not want us to erase it;
- Where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
- Where you have objected to our use of your personal data, but we still need to verify if we have overriding grounds to use it.
We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
To object to the use of personal data
You can object to any use of your personal data which we have justified on the basis of our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
To request a transfer of personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).
You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
You can contact us for more information
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.
If you would like to exercise any of the above rights, please:
- Email or write to our Data Protection Team at email@example.com or One Chapel Place, London, W1G 0BG
- Let us have enough information to identify you, e.g. name, address, date of birth;
- Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
Let us know the information to which your request relates.
KEEPING YOUR PERSONAL DATA SECURE
We have appropriate security measures in place 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.
OUR SUPERVISORY AUTHORITY
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office (ICO). It has enforcement powers and can investigate compliance with data protection regulations (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before the ICO.
Information Commissioner’s Office
HOW TO CONTACT US
Please contact our Data Protection Team if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact them please send an email to firstname.lastname@example.org or One Chapel Place, London, W1G 0BG.
|Rationale/Reason for Processing
|Lawful Basis for Processing
|Third party recipients linked to that activity
|To provide you with intermediary services
|Performance of a contract
|Bankhall Support Services
Posix Limited (IT Support)
Voyant Cashflow Software
|To apply for investment products on your behalf
To apply for decisions in principle for and/ or quotations for protection products on your behalf
|Performance of a contract
|Product providers and lenders
|To refer you to third party advisers to provide you with advice in relation to specialist advice (pension transfers/ general insurance), tax and legal advice
|Providers with whom we would disclose and discuss their relevance with you, prior to sharing your details.
Please contact us for a list of our current professional connections.
|To send you marketing communications – newsletters, market commentaries, event invitations
|Performance of a contract
|Campaign Monitor email system
Flamme Rouge Consulting
|To retain records for any services or advice provided to you by us in order to defend potential legal claims or complaints
|Intelliflo back office system
Sprint Enterprise (Fastrak)
Virtual Cabinet CRM