Investment Technique Limited is committed to being transparent about how we collect and process your personal information. When using the term “personal information” in our privacy policy, we mean information that relates to you and allows us to identify you, either directly or in combination with other information that we may hold.
This privacy notice explains our company policy regarding the use of any personal information collected from you in line with the requirements under the GDPR (General Data Protection Regulations) which came into effect in May 2018 and superseded the Data Protection Act 1998.
Why we collect your personal information and how we use it
We collect personal information from you to provide the basis for any advice we give to you and also to fulfil our legal responsibilities under the Financial Conduct Authority (FCA) regulations. We may also receive information about you from third parties appointed by you. We will use your personal information to:
- Identify you internally
- Ascertain your financial & personal circumstances with a view to providing you with appropriate and suitable advice.
- Provide information to third party product providers in the event that our advice leads to the necessary purchase of a financial product or to set-up an account in your name and only to the extent it is necessary.
- Comply with our legal obligations as an authorised independent financial advisor. This includes checking your personal details in order to meet our obligations relating to the prevention of money laundering, fraud or other financial crime.
We will rely on the following legal basis to process your data:
- Necessity for the performance of a contract to which you as the data subject is party or in order to take steps at the request of you as the data subject prior to entering into a contract.
- Necessity for compliance with a legal obligation to which we as the “Data Controller” are subject.
These provisions are detailed in sections 1(b) and 1(c) of Article 6 of the General Data Protection Regulation (GDPR) respectively.
How we store and share your information
Any personal information you provide to us is subject to protection under the GDPR. Every attempt is made to keep your personal information safe guarded and protected at all times. All information is kept on encrypted servers. We employ the use up to date virus protection to minimize the chance of any data breaches by way of data attacks.
It is entirely possible as a result of advice given that it will be necessary to share your personal details with a third party product provider to facilitate the purchase of a financial product or to set-up an account in your name. As a company, Investment Technique Limited will endeavour to process and share your data in a safeguarded manner and will apply all
practical due diligence to any third party involved to make sure your personal information remains safe and your privacy maintained. All personal information sent to a third party via electronic means such as email will be sent using password encryption to again reduce the chance of any data breaches.
It is also possible that your personal information will be shared with our regulatory body (FCA) or law enforcement agencies if we are legally obliged to do so.
From time to time our back office system may require maintenance or upgrading. At such times it is possible that a third party IT consultant may be employed to facilitate this process. Every attempt will be made to protect the privacy of your personal information should this occur and any third party consultant will be supervised at all times.
Special Category Data
The processing of special category data which is personal information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation will require us to further satisfy the GDPR we will do this through obtaining your written consent. It is most likely that we will require health details for instance when facilitating the purchase of an annuity or a life assurance policy where this information
is likely to have a material impact on the terms offered.
How long will we hold your data?
Under GDPR in line with the rules regarding retention periods, we will not keep your information longer than is necessary or we are legally obliged to do so. The legislation sets out that we cannot keep subject personal information longer than is necessary. As a regulated financial firm we are legally obliged to maintain your records for minimum periods depending on the type(s) of business we advised upon assuming you proceed with our advice
as follows:
- Pension Transfer, Pension Conversion, Pension Opt-out or FSAVC – Indefinitely
- Life Assurance, Personal Pension Scheme, Stakeholder Scheme – 5 Years
- Any other Business – 3 Years.
If as part of your contract with us you are receiving regular ongoing advice we will retain your personal information as is necessary for the continuation of our contract. In the event that the relationship comes to an end either by your choice or via a decision made by Investment Technique Limited, your records will be maintained as per the time limits set by the FCA starting from and including the day our relationship officially comes to an end.
Your Rights under GDPR
Under the GDPR you as the data subject are afforded multiple rights protected under the legislation, these rights are as follows:
- The right to be informed – This Privacy Notice details which information we will be processing, how we will process it and why we will process it, along with all other relevant information. We will notify you if we need to process your data via a different method or for a different purpose in advance.
- The right of access – You have the right to access any and all personal information we hold about you, you can do this by telephone, email or in writing. We have one month to comply but will endeavour to provide this information as soon as possible. Whilst this service is free, we do reserve the right to make a charge in the event of repetitive or manifestly unfounded requests.
- The right of rectification – You have the right to have us amend any data about yourself, that we hold, that you believe to be inaccurate. If you wish us to do this please communicate this to us either by telephone, email or in writing. Assuming we have no reason to doubt the amendment we will update your information.
- The right of erasure – This is also sometimes known as the right to be forgotten, You have the right to notify us by telephone, email or in writing of your wish to be forgotten and to have your personal data erased. However this is not an absolute right and due to the obligatory retention periods set out above may not be accepted. The reason for this is that we are unable to comply with such a request if it contravenes a legal obligation.
- The right to restrict processing – This right will stop us using your data further but stops short of a request for erasure. Many of your other rights once activated will result in this right automatically kicking in. One example would be a request to “Rectification”, it this case if we couldn’t immediately agree to update your information we would restrict processing for your data until the situation could be resolved. You can request that we restrict the processing of your data by telephone, email or in writing. We may refuse to accept your request if it is manifestly unfounded, excessive or it would inhibit our ability to comply with a legal obligation.
- The right to data portability – You have the right to request that we provide you with any personal data you have provided us with in a Structured, Commonly used and Machine readable format. This will be provided in an .xml format unless a request is made for it to be either in a word or a .pdf document at the time of the request. You can also make a data portability request to us to provide such data in the same format to a third party of your choice. You will need to provide this request by telephone, email or in writing and it may be refused only if the request is manifestly unfounded or excessive.
- The right to object – The right to object is primarily used to avoid direct marketing which is not relevant to our business model. As we are not processing your data under Article 6 Section 1 (e) or (f) of the GDPR this right is not extended to you.
- Rights in relation to automated decision making and profiling – We do not use systems designed to make decisions about you as the data subject or used to profile you without any human input therefore your right to object to automated decision making whilst still afforded to you is irrelevant in this case.
In the event that you notify us that you wish to invoke either your right to access, your right to rectification, your right of erasure, your right to restrict processing or your right to data portability you will receive a confirmation call back from a representative of Investment Technique Limited as a security measure.
Your Right to Complain
If you believe that we have not complied with your data protection rights please contact us and we will endeavour to resolve this with you. If you remain dissatisfied you can complain to the Information Commissioner. Details can be found via their website, https://ico.org.uk/concerns/.
Or alternatively you can contact them by telephone on 0303 123 1113.
Any Questions?
Our data protection officer is Mark Stephenson, who can be contacted on 01482 320136 or at mark@investment-technique.co.uk.
Future Changes to our Privacy Notice
We keep this privacy notice under regular review and we will make you aware of any changes 90 days in advance, subject to this being possible.