Brighton Williams & Partners is committed to safeguarding the privacy of our service users and website visitors.

Our Privacy Notice contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

This Privacy Notice applies where we are acting as a data controller with respect to the personal data of our service users and website visitors; in other words, where we determine the purposes and means of the processing of that personal data.

We may need to make changes to our Privacy Notice; so please check our website for updates from time to time.

This version of our Privacy Notice Version 2.0 updated June 2018.

Who we are

We are Brighton Williams & Partners, a firm of financial advisers. Our principal place of business is at:

Brighton Williams & Partners
8 High Street
Winterbourne
Bristol
BS36 1JN

You can contact us:

• by post, to the postal address given above;
• using our website contact form;
• by telephone, on 01454 773690; or
• by email, using the email address enquiries@brightonwilliams.com

If you have any questions about our Privacy Notice or the information we collect or use about you, please contact our Data Protection Officer.

Information we collect and use

Information about you that we collect and use includes:

• Information about who you are e.g. your name, date of birth and contact details
• Information connected to your use of our services e.g. your employment details, your bank account details, your personal and financial circumstances
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information that is automatically collected e.g. via cookies when you visit our website
• Information you submit via our website contact form e.g. your name, email and telephone number
• Information if you visit our offices e.g. your name and car registration
• Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
• Information you may provide to us about other people e.g. joint applicants or beneficiaries for products you have with us
• Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
• We may need to gather personal information about your close family members and dependants so that we can provide our service to you effectively. In these cases, it will be your responsibility to ensure that you have consent from the people concerned to pass their information on to us. We’ll provide a copy of this Privacy Notice for them.

Where we collect your information

We may collect your personal information directly from you and from a variety of sources, including:

• At meetings with one of our employees, such as your financial adviser
• During phone conversations with us
• From emails or letters you send to us
• From an application form for a product or service
• Through our online services such as our website, website contact form, social media or client portal
• If you are a member of your employer’s pension scheme, the information we collect and use will most likely have been provided by them on your behalf
• We may also collect personal information on you from publicly available sources e.g. to check or improve the information we hold (like your address)
• Where you are introduced to us, with your consent, by a third party

Use of cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to our website. It is recommended that you leave on all cookies if you are not sure whether you need them or not, in case they are used to provide a service that you use.

What are cookies?

A cookie is a small file – it’s saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example – they will remember you’ve visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don’t have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and improve our website and services.

• Persistent cookies – these stay valid, and will work until their expiry date (unless you delete them before they expire)
• Session cookies – these expire when you close your web browser

Managing cookies

Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. Information on how to do this will be available to you on the website of the browser in question.

You should note that blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.

The cookies we set

We use cookies for the following purposes:

1. personalisation – we use cookies to store information about your preferences and to personalise the website for you;
2. security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
3. analysis – we use Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content; and
4. cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, the social media sites (including Facebook, Linkedin etc.) will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over the destination website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting other websites, and you should be aware that other websites are not governed by this Privacy Notice. You should exercise caution and look at the privacy statement applicable to the website in question.

What we use your information for

We take your privacy seriously and we will only ever collect and use and retain information that is personal to you where it is necessary, fair and lawful to do so in the following circumstances:

• You have given your consent for us to contact you and correspond with you e.g. if you have completed and submitted our website contact form for the purposes of an enquiry
• It’s necessary to provide the product or service you have requested e.g. if you wish to invest in a pension or savings product, we will require personal and financial information including your name, address, date of birth, bank account details
• It’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Review information and Statements, to tell you about any changes to Terms and Conditions or for the detection and prevention of fraud
• It’s in the legitimate interests of Brighton Williams & Partners e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from our service; where we need to process your information to better understand you and your needs so we can make suitable recommendations
• It’s in the legitimate interests of a third party e.g. sharing information with your employer’s adviser for the governance of a pension scheme of which you are a member

If you do not wish us to collect, use or retain your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

Who we may share your information with

We may share your information with third parties for the reasons outlined in ‘What we use your information for’.

These third parties include:

• Trusted companies that we have chosen to support us in the delivery of the products and services we offer to you e.g. financial product providers, accountants, solicitors, estate agents. 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
• Our regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• Law enforcement, credit and identity check agencies for the prevention and detection of crime
• HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Where your information is processed

Your information is processed in the UK and European Economic Area (EEA).

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls and processes designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and undertake training on this.

Our security controls are aligned to industry standards and good practice; providing a controlled environment that effectively manages risks to the confidentiality, integrity and availability of your information.

How long we keep your information for

Enquiries

When you consent to us using the personal data that you submit while making an enquiry, we’ll retain that data so that we can get in touch. During the enquiry process it may be necessary for you to consent to us collecting other personal data, such as your personal and financial circumstances or ‘sensitive’ personal information (e.g. relating to your health, marital or civil partnership status) so that we can progress your enquiry.

Data collected during an enquiry process will be retained by us for 12 months and will then be securely removed from our system unless you go on to use our contracted services. You have the right to withdraw consent for us to use this data by contacting us at the details above.

Our clients

During the course of our relationship with you, we’ll retain personal data which is necessary to provide our services to you. We’ll take all reasonable steps to keep your personal data up-to-date throughout our relationship.

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 we are required to do so to comply with the law.

Where you have given us your consent to collect sensitive personal data, you do have the right to withdraw that consent in the future. If we feel we have an ongoing lawful basis for keeping some or all of that data we will discuss this with you.

Your individual rights

You have several rights in relation to how Brighton Williams & Partners uses your information. They are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why we have it and who we share it with – we do this in our Privacy Notice and privacy notices.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

Under normal circumstances you have the right to request erasure of your personal data that we hold. However, in order for us to fulfil our legal and regulatory obligations regarding your right to make a complaint, your personal data must be retained.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

Right to data portability

You have the right to request a copy of the information that we hold about you. When your personal data is processed by automated means you have the right to ask to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct any information that you think is incorrect.

Marketing

We may send you information about our products and services which may be of interest to you. If you have agreed to receive marketing information you can opt out at a later date.

You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes please contact us by email, telephone, post or by submitting our digital contact form.

How to make a complaint

You have the right to lodge a complaint if you are unhappy with how your personal data is processed. You can contact the Brighton Williams & Partners Data Protection Officer at the address given above.

If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are:

Information Commissioner’s Office (ICO)
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel. 0303 123 1113 (local rate)
www.ico.org.uk