We are committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use and disclosure of Personal Information. Our privacy policy is based upon the values set by our regulator, the Financial Conduct Authority, the Data Protection Act 2018 and General Data Protection Regulation (GDPR).

This privacy policy explains how we use any Personal Information that we collect about you during your interactions with us.

Introduction

We are responsible for maintaining and protecting the Personal Information under our control. We have designated individuals who are responsible for compliance with our privacy policy.

Identifying Purposes

We collect, use and disclose Personal Information to provide you with the products or services you have requested and to offer you additional products and services we believe you might be interested in. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address and bank account details are provided as part of the servicing process.

Consent

Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit or prevent our ability to provide you with our products or services.

Limiting Collection

The Personal Information collected will be limited to those details necessary for the purposes identified by us. We may collect Personal Information from you in person, over the telephone or by corresponding with you via post, email or over the internet.

How will we use the data about you?

We collect and use data about you to contact you by telephone, email or by post.

We collect and use data about you to provide you with the services for which you engage us. Your Personal Information will be held in our secure database and will be shared with providers and other professional services needed to carry out relevant and necessary work.

Why do we need to collect and use your Personal Information  ?

We need to collect, store and use your Personal Information so that we can contact you in response to an enquiry or submission of a contact form.

Where you engage our services, the primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to effectively carry out the services we have agreed. We would be unable to fulfil our legal and regulatory obligations without collecting your personal data. Therefore, we will not ask for your explicit consent to collect and process this information.

Where special category data (sensitive personal information) is needed, we will obtain your explicit consent to collect and process this information.

Limiting Use, Disclosure and Retention

Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by law. Personal Information will only be retained for the period of time required to fulfil the purpose for which we collected it, is deemed necessary for legitimate reasons, or as may be required by law.

How long do we keep your information for?

Contact form submission and Enquiries

We will keep the Personal Information that you submit, or has been collected, for a period of 12 months unless you go on to engage our services, whereby timescales shown apply.

Engaging our services

During our relationship with you, we will keep Personal Information which is necessary to provide our services to you. All reasonable steps will be taken to keep your Personal Information up to date throughout our relationship.

Where you have engaged our services, we are subject to regulatory requirements to keep 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-outs
• Three years for insurance business

These are minimum periods, during which we have a legal obligation to keep your records.

We reserve the right to keep data for longer where we believe it is in our legitimate interests to do so. For example, to defend ourselves in the event of a complaint.

You have the right to request deletion of your Personal Information. We will follow this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

What information do we collect about you?

We collect Personal Information relevant to your engagement of us for financial planning/financial advice/mortgage advice/investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of Personal Information (Sensitive Personal Information) such as data about your health if this is necessary for the provision of our services.

We will also collect Personal Information when you voluntarily complete client surveys or forms, submit a contact on our website, or provide feedback to us.

Information about connected individuals

We may need to gather personal information about your close family members and dependants to effectively provide our services. In such cases, it will be your responsibility to ensure that you have their consent to pass their information on to us. A copy of this Privacy Notice will be provided for their information.

Who might we share your information with?

We will not share your information for marketing purposes with any other companies.

To deliver our services to you effectively, we may send your details to third parties such as those that we engage for professional compliance, accountancy, or legal services, as well as product and platform providers that we use to arrange financial products for you.

Where third parties are involved in processing your Personal Information, we will 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 will only act in line with our written instructions.

Where it is necessary for us to share your personal data with a third party, we will use robust security measures to protect your personal data in-transit. This may include the use of password-protected or encrypted documents, or the use of an industry-standard, secure document delivery service such as DocuSign.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we will send your details to third-party agencies for identity verification purposes.

Accuracy

Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfil the purposes for which it is to be used.

We have an obligation to ensure that your Personal Information is correct and up to date and request that you ask us to correct or remove any information that you think is incorrect.

Safeguarding Customer Information

Personal Information will be protected by security safeguards that are appropriate to the sensitivity level of the information. We take all reasonable precautions to protect your Personal Information from any loss or unauthorised use, access or disclosure.

Openness

We will make information available to you about our policies and practices with respect to the management of your Personal Information.

How can I access the information you hold about me?

You have the right to request a copy of the data we hold about you. If you would like a copy of some or all of your Personal Information, please email or write to us using the contact details noted below.

Upon request, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information, and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.

What can you do if you are unhappy with how your Personal Information is processed?

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 our business address.

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

Additional Information

Cookies

A cookie is a small computer file or piece of information that may be stored in your computer’s hard drive when you visit our website. We may use cookies to improve our website’s functionality and in some cases, to provide visitors with a customised online experience.

Cookies are widely used and most web browsers are configured initially to accept cookies automatically. You may change your Internet browser settings to prevent your computer from accepting cookies or to notify you when you receive a cookie so that you may decline its acceptance. Please note, however, if you disable cookies, you may not experience optimal performance of our website. You can also choose to reject the installation of these cookies when you visit our website.

Other Websites

Our website may contain links to other third party sites that are not governed by this privacy policy. Although we endeavour to only link to sites with high privacy standards, our privacy policy will no longer apply once you leave our website. Additionally, we are not responsible for the privacy practices employed by third party websites. Therefore, we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

Marketing

We may send you information about our products and services which could be of interest to you. If you have agreed to receive marketing information, you have a right to stop us from contacting you for marketing purposes at any time. If you wish to opt out of these communications, please tell us in writing by email at enquiries@brightonwilliams.com or by post.

Changes to our privacy policy

We keep our Privacy Policy under regular review, and we will place the updated policy on our website, which can be accessed using the ‘Privacy Policy’ links. This Privacy Policy was last updated on 01/03/2024.