Client Privacy Notice

The Wilcox Young Partnership is a trading style of Investment & Tax Advisory Services Limited, which is part of The WAY Group Limited and provides independent financial planning services to its clients across the south coast. Your privacy is important to us and we will keep your personal data secure in accordance with our legal responsibilities

 

Why should you read this document?

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.

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 or 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.

In the context of providing you with assistance in relation to all your financial planning services provided by us, 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, finance, insurance or other products and the terms and conditions relating to these

The basis upon which our firm will deal with your personal data

When we deal with you about your financial planning requirements we do so on the basis that both parties are entering a contract for the supply of services.

In order to perform that contract, and to arrange the products you require, we will 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 product and insurance providers or our compliance service consultants 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 needs, in particular life insurance or 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 providers in relation to insurance products that may meet your needs and to provide you with advice 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 do we collect Your Personal Data?

We will collect and record your personal data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our discussions and meetings with you to establish your circumstances, needs and preferences in relation to the financial planning services that we are providing, or intend to provide to you. You may provide information to us verbally and in writing, including email.

 

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 do not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to your personal data when it is disclosed to us?

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. 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 investment, pension 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 our financial planning services or any product  or 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.

Sharing Your Personal Data

From time to time your personal data will be shared with:

  • Investment, pension and 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 consultants, introducers, product specialists, providers of legal services such as  your solicitor, estate state planners, conveyancing, surveyors and valuers  (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 customer privacy notice, i.e. to progress your financial planning service enquiry or 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 notice.

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.

Security and retention of Your Personal 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.

Your rights in relation to your personal data

You can:

  • request copies of your personal data that is under our control
  • ask us to further explain how we use your personal data
  • ask us to correct, delete or require us to restrict or stop using your personal data (details as to the extent to which we can do this will be provided at the time of any such request)
  • ask us to send an electronic copy of your personal data to another organisation should you wish
  • change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

 

How to make contact with our firm in relation to the use of your personal data

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

 

The Data Protection Office

The WAY Group Limited

Cedar House

3 Cedar Park

Cobham Road

Wimborne

Dorset

BH21 7SB

 

Email: DPO@Wayfunds.com

Tel: 01202 855856.

 

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 https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Cookie Policy

Cookies are used on our site to ensure that we give you the best experience on our website. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on our website.

Some cookies are essential so you can move around the website and use its features. Without these cookies, some services you’ve asked for can’t be provided. These cookies don’t gather information about you that could be used for marketing or remembering where you’ve been on the internet.

What are cookies and how do they work?

Cookies are small bits of text that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognise you and can then tailor what you see on the screen.

Some of the cookies we use

Certain cookies are necessary in order for you to use our websites. These are used ‘in-session’ each time you visit and then expire when you leave the site. They’re not stored on your computer and they don’t contain any personal data. However, you can delete them via your browser if you wish to, but this will restrict the functions that you’re able to carry out on our sites.

Session cookies

These enable you to carry out some essential functions on our sites, such as maintaining log in details for the session or a transaction. They also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session or logout of certain areas.

Secure cookie

A secure cookie is only used when a browser is visiting a server via HTTPS, ensuring that the cookie is always encrypted when transmitting from client to server. This makes the cookie less likely to be exposed to cookie theft via eavesdropping.

Persistent cookies

These are used to persist a user’s preference across e.g. setting items such as the open status of the carousel, and remain until the expiry date and time set by the web server (or otherwise manually deleted by the user).

Analytics

We like to keep track of what pages and links are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. It’s also very useful to be able to identify trends of how people navigate (find their way through) our sites and help us provide a more friendly solution.

Third-party cookie

Google Analytics tracking (and most web tracking software) uses cookies in order to provide meaningful reports about site visitors. However, Google Analytics cookies do not collect personal data about website visitors.

Managing your cookies

You’ll find more information about cookies at www.allaboutcookies.org, which gives details on how to delete cookies from your computer. For information on how to do this on your mobile phone browser, please see your handset manual.

 

Want to know more:

Wimborne 01202 854869

Dorchester 01305 269369