FPC takes your privacy very seriously and is committed to protecting your personal information. This Privacy Policy Statement sets out how we use and look after the personal information we collect from you.
We are the data controller, responsible for the processing of any personal data you give to us. We take reasonable care to keep your information secure and to prevent any unauthorised access to or use of it. By providing us with your data, you warrant to us that you are over 13 years of age.
Who are ‘we’?
In this notice, whenever you see the words “we”, “us” or “our”, we mean the Financial Planning Corporation LLP
This privacy notice was updated on 23rd July 2021.
Introduction
- By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
- By completing our newsletter sign-up form, you are agreeing to receive email-marketing communications.
- By using our client portal and agreeing to this policy, you consent to the storage and processing of any personal data provided.
What personal data do we hold on you?
Personal data means any information about an individual, from which that individual can be identified. We collect, use, store and transfer personal data whenever you interact with us whether that be through face-to-face meetings, by phone, email, in writing, social media, the use of our website, video conferencing or other methods.
When permitted, or authorised by law, we may also receive information about you from third parties such as business partners, credit or fraud checking agencies, as well as other third parties with whom we have had no prior contact.
Clients and Prospective Clients
If you are our client, or intend to become our client, we need to build up a detailed picture of your current personal and financial position, so we can deliver financial planning services in fulfilment of our contract with you. The information we hold may include:
- Detailed information about who you are, e.g. your name, date of birth, contact details, national insurance number, place of work, previous addresses.
- Information about children and other family members where it is relevant to your financial plan. In these cases, we will assume that you have their consent.
- Financial information including employment status, details of your income, expenditure, assets, bank accounts and other financial products.
- Information about your interests and/or hobbies.
- Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status.
- Information that is automatically collected, e.g. via cookies when you visit our website.
- Details of all written, email and telephone and video conferencing communication.
Professional Connections
In certain situations, we also hold less detailed personal information about other professionals who we work with. The information we hold may include:
- Information about who you are, e.g. your name, place of work and contact details.
- Information about your interests and/or hobbies.
- Information that is automatically collected, e.g. via cookies when you visit our website.
- Details of all written, email and telephone and video conferencing communication.
Sensitive Data
Sensitive data refers to data that may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences and only collect information about the above if it is needed for us to provide our services.
You are not obliged to share sensitive personal data (or any personal data) and must give us explicit consent to process this type of data. However, without your consent, it is unlikely that we will be able to fulfil our contract to you and would most likely have to terminate any agreement we have in place with you to provide financial planning services. If we are unable to provide these services, we will notify you at the time.
Why we need your personal data
As a prospective or active client, we have an obligation to you to provide financial planning and investment services for which we need to collect detailed information about you. As stated above, this may include ‘sensitive’ personal information for which you must also give your explicit consent if you want us to process this data.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
| Data Subject | Purpose/Processing Activity | Lawful Basis for Processing |
| Client and Prospective Client | Processing personal & financial data in relation to providing financial planning services | Performance or preparation of a contract for financial planning and investment services |
| Client and Prospective Client | Processing ‘sensitive’ personal information in relation to providing financial planning services | Consent |
| Client | Sharing information with product providers and service providers where you have purchased their services and/or products | Performance of Contract |
| Client | Sharing data with third-party service providers, providing services to FPC | FPC has a legitimate interest to run the company efficiently and as it sees fit. Provision of some third party services are for the benefit of the company and its clients. |
| Client | Sending out marketing information such as newsletters and investment updates | FPC has a legitimate interest in keeping clients up to date in relation to products or services that they have purchased, and many clients would expect us to do so. You can opt out of this at any time. |
| Client | Organising events tailored to your specific interests | FPC has a legitimate interest in providing what we feel are added value events. We use this information to tailor events to the interests of our clients, prospects and professional connections. You can opt out of this at any time. |
| Prospects &
Professional Connections |
Sending out marketing information such as newsletters and investment updates. | Consent. You can opt out at any time. |
| Prospects &
Professional Connections |
Processing information about your personal interests and/or hobbies. | Consent.
You can opt out at any time. |
| Client Prospects & Professional Connections |
Processing analytical information about your use of our website and online services such as your IP address, details of your browser and/or device, length of your visit to website and which pages you have visited. | FPC has a legitimate interest as this enables us to properly administer our website and our business. It also helps us to grow the business and to aid our marketing strategy. You will need to turn off analytical cookies to opt out of this. |
Marketing Communications
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (as outlined in the above table)
Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and, in each case, you have not opted out of receiving such communications since.
Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
You can ask to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@fpc.co.uk
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided for other purposes such as the ongoing delivery of financial planning and investment services.
How we use CCTV
Before installing the CCTV we carried out a privacy impact assessment to ensure we were balancing our need for CCTV with the impact on your privacy.
We have installed CCTV to:
- Ensure the security of our property and that of our clients and staff
- Prevent and detect crimes
- Identify, apprehend and prosecute offenders;
All of the above are also legitimate reasons for us to use and store this data.
We do not use CCTV to view or record client meetings or staff areas.
Any information captured by CCTV will be viewed in a restricted area and only by the Data Manager and any authorised people. Images will not be shared with anyone, unless we need to engage with the Police with regard to any crime or suspicious activity.
All CCTV is maintained and overseen by our Data Manager who is responsible for carrying out compliance audits and reviewing the need for CCTV.
Who we share your personal data with
We may have to share your personal data with the parties set out below:
- Service providers who provide IT and system administration services.
- Service providers who provide marketing or PR services to us.
- Service providers who provide compliance and legal services to us.
- Professional advisers including solicitors, bankers, auditors and insurers and those who you authorise to act on your behalf.
- Government bodies that require us to report processing activities.
- Fraud prevention agencies.
- Third party providers from whom we purchase products and services on your behalf.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
- If you hold an account with moneycorp, our FX and International Payments partner, we may share and receive information about your trading activity in order to maintain client records, verify and allocate commissions and pay rebates.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
International Transfers
Where possible, we avoid transferring your data outside of the European Economic Area (EEA) as many countries outside of this area do not always offer the same levels of protection to your personal data. Indeed, European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
If your data is transferred outside of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
How long we hold your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the legal requirements, processing purposes, and, if these can be achieved by other means.
If you cease to be a client of FPC, we will ‘deactivate’ and archive your data, which means that we will no longer process it. However, we will keep a record of any advice given as we have to adhere to certain rules set by the Financial Conduct Authority and, in addition, we believe we have a legitimate interest in holding a record of the personal information to protect ourselves against future complaints.
In civil actions in the courts, there is usually an overall “long-stop” requirement that the matter complained about should have happened within the last 15-years. This limitation does not apply to complaints to the Financial Ombudsman Service. There is no 15-year “long-stop” rule in the complaints-handling rules made under the Financial Services and Markets Act and the Consumer Credit Act.
For marketing purposes, where we have obtained consent, we will contact you and ask you to refresh this consent on a regular basis. If you withdraw your consent, we will cease processing the information immediately.
In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your rights regarding your personal data
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights above, please email us at info@fpc.co.uk
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee (or refuse to comply with your request) if your request is clearly unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Cookies
This site uses cookies for a variety of reasons, please see this page on the cookies we use, how we use them, and how you can disable them if needed: About cookies
Links to other websites
Both our website and client portal may contain links to other websites. However once you have used these links to leave our site you should note that we do not have any control over that website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Our details
This website is owned and operated by the Financial Planning Corporation LLP
We are registered in England and Wales under registration number OC337787 and our registered office is at 124 Station Road, Ainsdale, Southport, PR8 3HL.
Our principal place of business is at 124 Station Road, Ainsdale, Southport, PR8 3HL.
You can contact us:
- by post, using the postal address given above
- using our website contact form
- by telephone, on 01704 571777
- by email, using info@fpc.co.uk.
Data Manager: John Phelan, Head of Operations
