Last updated 24th May 2018
1. Who, What & Why?
This Privacy Notice is produced by QS Financial Planning Solutions Ltd (“we”) for users (“you”) of our products and services (“services”). You should not use our services unless you are happy you’re your data to be processed in the manner laid out in this document.
We intend only to collect or use information at the level needed in order for us to deliver our services, to understand and improve our business and for any legal requirements. We are the data controller and responsible for data you provide to us. We will take all reasonable steps to maintain its security and privacy.
2. Your Responsibilities?
It is vital that the information we hold about you is accurate and current. You agree to keep us informed of any changes that happen in the information you have provided to us – for example your contact details. You must not provide us with any personal information if you do not agree in full with this document.
If you provide any information on behalf of someone else, you must have their consent.
3. Types of Information
In order to carry out our services, we must collect a wide array of personal and sometimes sensitive information. Personal data is classified as that where an individual can be identified but does not include anonymous data. Sensitive data is those categories which are deemed to require special protection. The data we process may include, as a non-exhaustive list:
Name, National Insurance Number, Address, Contact Details, Date of Birth, Nationality, Marital Status, Employment Details, Salary, Financial Holdings
Medical Details (where required for providing a relevant service)
4. How Data Is Collected
We collect personal information about you through direct interactions where you provide us with information at our request. This may be through ad-hoc communications or via a data collection form such as a Financial Questionnaire. We may obtain some information about you via your existing investment providers (having obtained permission from you) and certain information such as your previous addresses from identity checking services.
5. How Data Is Used
We will process your data only in accordance with specific permissions. Most commonly these are:
i. You have given us consent to the processing of your personal data for specific purposes. For example by you consenting to this document and providing contact details to us.
ii. Where it is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract. For example to prepare an investment recommendation in accordance with the terms of service you have agreed with us.
iii. Where it is necessary for compliance with a legal obligation to which we are subject. For example we are required by law to carry out anti money laundering checks for new clients and we are required by law to retain records of our advice services for a minimum term.
iv. Where it is necessary for our legitimate interests or those of a third party, and where your interests and fundamental rights do not override those interests. For example we need to record your contact details in case we need to contact you, and we may need to pass on your details to our professional insurance provider, any company we engage with to carry out an audit of our accounts and processes, and any third party to whom we may sell, transfer or merge parts or all of our services.
Most of the data we process is within the remits of permissions ii, iii and iv. Contact us if you wish to obtain full details of the basis for which we process each type of personal data.
As examples of how we might share your information with relevant third parties, we may need to pass on your details to product providers, banks, insurers, fund managers, platform providers, product research and quotation services and financial modelling providers.
6. How Data Is Processed
We process data on secure physical devices. We also retain third-party storage of our data for the purposes of data resilience. We share some data with third-parties in the process of providing our services. All data is processed and transferred under conditions which we deem to provide adequate protection under data protection legislation for both privacy and security.
We are based in the United Kingdom. We may store or transfer data to other locations such as within the European Union or USA where we deem the data protection in place is adequate. Where we use third parties to process your data, they may also transfer your data to other countries in line with their own privacy notice.
8. How Long Data Is Processed For
We process data only for as long as required to deliver our services to you, for legal requirements and so long as we have a legitimate interest. Some data will be recorded for as long as reasonably expected to be required for the interests of both parties in the case of a complaint.
We take reasonable steps to ensure the security of your data but this can not be fully guaranteed by anyone. Do not provide data to us if you do not accept this risk.
10. Requesting Data or Deletion
You may contact us at any time to request a copy of, or to request the deletion of, your data.
11. Changes to the Privacy Notice
We reserve the right to change this Privacy Notice from time to time to better reflect the current circumstances. Any changes will be made visible by revising the date on this document. We encourage you to review the Privacy Notice whenever you use our services in order to understand how your information may be collected, used or shared. The latest version can be found at any time on our website (www.qsfinancial.co.uk) or can be sent to you on request. If you use our services we must assume that, having agreed to these terms in the first instance, your use of our services comes after having consented to the most up to date Privacy Notice.
You have the right to complain at any time and we ask that you contact us in the first instance. If you are not happy with our response, you may contact the Information Commissioner’s Office (www.ico.org.uk).
13. How to Contact Us
If you have any queries relating to this document or about your data, please contact any member of staff or by using the contact details on our website (www.qsfinancial.co.uk).