Privacy Policy

Why should you read this?

During the course of dealing with us, 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 (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

The policy

Your right to privacy is incredibly important to us. This policy will explain your privacy rights and how we process, collect, manage and store those details and how your rights under the General Data Protection Regulation (GDPR) are adhered to. We only ask for personal information when we truly need it to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. We don’t share any personally identifying information publicly or with third-parties, except when required to by law. We will never pass your personal data to anyone else, without your explicit permission.

What do we mean by ‘Your Personal Data?’

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

The type of personal data we collect about you and how it is used depends on what contact you have with us, your needs, the relationship you have with us and the products and services you hold or enquire about.

The following is information which we will need to obtain about you:

  • Title, name, date of birth, marital or civil status, gender, contact details, addresses, nationality. This also extends to documents that will help us to verify your identity.
  • Employment and remuneration information, including salary, bonus schemes, any overtime, sick pay, other benefits and employment history.
  • Bank account details, loans and other liabilities, tax information, income and expenditure, family circumstances and details of any dependents.
  • Health status and history, details of treatment and prognosis and medical reports.

It can also include information which either you give to us or which we obtain about you. We may also gather data from our website’s ‘contact us’ form, used to enquire about our services or from when you voluntarily complete client surveys.

Why do we collect this data?

The main reason we collect this data is to complete the services you have entered into a contract with us for. Without knowing any of this information, we would be unable to fulfil our legal and regulatory obligations. Therefore, it is essential we collect this information.

In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist you with for example your insurance / ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance / investment providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

How will we collect your data?

We will collect and record your data from a variety of sources, however, we rely mostly on this information coming directly from you. We will collect this information usually over a series of meetings, but most of this will be collected during our fact-finding meeting.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to the data you provide us with?

In the course of handling Your Personal Data, we will:

  • Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
  • Submit Your Personal Data to product providers and/or insurance product providers both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
  • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment/finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

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 it. We have several procedures in place to help prevent any breach of any data which all members of staff and external contractors are aware of and receive training on.

Sharing your data

From time to time Your Personal Data will be shared with:

  • Investment providers / Insurance providers.
  • Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers and product specialists (in each case where we believe this to be required due to your particular circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this Client Privacy Policy, i.e. to progress your investment and/or insurance enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Client Privacy Policy.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Your rights

Your rights under the General Data Protection Regulations are briefly as follows:

  • To be informed about the collection and use of your personal data,
  • To have inaccurate personal data rectified, or completed if it is incomplete,
  • To have personal data erased (in certain circumstances),
  • To request access to information held about you,
  • To request the restriction or suppression of your personal data,
  • To obtain and reuse your personal data for your own purposes across different services,
  • To object to the processing of your personal data in certain circumstances.

How long will we hold your data?

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.

Accessing the data we hold on you

If you have any questions or comments about this policy, or wish to make contact in order to exercise any of your rights set out within it please contact:

Name: Benjamin Mitchell

Role: Director/Data Protection Officer

Contact Email:

Telephone No: 07746947594

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at

Or by writing to:

Information Commissioner’s Office

Wycliffe House

Water Lane, Wilmslow




As a client of the firm we would like to send you marketing material to keep you up to date with information we believe is important for you to know or to provide you with information on other products and services which we believe may be of interest to you. We will ask for your consent and your preferred method of contact before sending you anything.

Just because you have given us consent at the beginning, doesn’t mean you can’t withdraw this at any time. If you would like to, our emails have the option to unsubscribe from them or you can contact us to have your name removed from our marketing list. We will not send you any further marketing after this point.

Review of this policy

We reserve the right to update this privacy policy at any time. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data.

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