Your privacy is extremely important to us. We are committed to respecting and protecting your personal information and will try to ensure that your details are accurate and kept up to date.
1. About FPP
Financial Planning Partners Ltd (FPP) is an Independent Financial Adviser (IFA). Providing regulated financial advice to high standards requires an in-depth understanding of our clients, so it is essential that we collect and manage your data appropriately. This means that we are described as a ‘Data Controller’ and we are responsible for complying with Data Protection laws.
2. Our processing of your Personal Information
What personal information will we collect?
To provide our Financial Advice services, we collect a wide range of information on your personal and financial circumstances. This includes your:
• Goals, objectives and anticipated events
• Contact details and National Insurance Number
• Health/smoker status
• Employment/Income details
• Expenditure details
• Assets – Savings, Investments, Pensions, Property etc.
• Liabilities – Mortgages, Personal Loans, Credit Cards etc.
• Contingency plans – e.g. Life Assurance, Critical Illness, Income Protection, Private Medical Insurance, Wills and Lasting Powers of Attorney details
• Solicitor/Accountant contact details
What information do we collect on our Website?
When you visit our Website (including the mobile-optimised version of the website accessible from your device), you may provide us with personal information such as your name, postcode, email address, landline phone number, mobile phone number, and information about your requirements and the services you might be interested in (“Information”).
We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration purposes. We may also report aggregate information to our advertisers. This is statistical data about browsing actions and patterns and does not identify you as an individual.
Similar to other commercial websites, our Website uses a technology called “Cookies” and web server logs to collect information about how our Website is used. A Cookie is a very small text document, which often includes an anonymous unique identifier.
When you visit a website, that site's computer asks your computer for permission to store this file in a part of your hard drive specifically designated for Cookies. Information gathered through Cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Website, and the websites visited just before and just after our Website.
Cookies, in conjunction with our web server's log files, allow us to calculate the aggregate number of people visiting our Website and which parts of the website are most popular. This helps us gather feedback so that we can improve our Website and better serve our clients. Cookies do not allow us to gather any personal Information about you, and we do not generally store any personal Information that you provided to us in your Cookies.
We use ‘Session’ Cookies which enable you to carry information across pages of the Website and avoid having to re-enter information. Session Cookies enable us to compile statistics that help us to understand how the Website is being used and to improve its structure.
We also use ‘Persistent’ Cookies which remain in the Cookies file of your browser for longer and help us to recognise you as a unique visitor to the Website, tailoring the content of certain areas of the Website to offer you content that match your preferred interests.
What information do we collect on our App?
When using our App, you may provide us with the following Information:
a) Your name and contact details (email address and mobile telephone number);
b) If you use the App to register as a registered user or subscribe to receive updates or offers from us. To become a registered user, you must provide us with your name, postcode, email address, landline phone number and mobile phone number, but you may also provide us with additional information if you choose to do so;
c) Your physical location, where you have agreed to it being used on the App or where you allow the App to access your location settings; and
d) Other Information that may be provided by you when adding content to our App, or to our social network pages.
How and when will we collect your personal information?
We typically collect information directly from you when we first meet with you and at Annual Planning Meetings to obtain your up to date information. From time to time, we may also collect information via our Website or App, or by telephone, post or e-mail. We may also ask for signed Letters of Authority to contact your investment, pension and insurance providers on your behalf, so that we can request more-detailed information on your financial plans in a timely manner. You can provide us with information in a number of ways:
a) By supplying us with the information as listed above, on an individual basis by registering as a registered user, subscribing to receive updates or information from us or completing our online contact form. To become a registered user, you must provide us with your name, postcode, email address, landline phone number and mobile phone number, but you may also provide us with additional information if you choose to do so;
b) By corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
c) By downloading our digital content or applying for a job with us;
d) Through any preferences and areas of interest as advised by you on subscribing to our online services;
e) By Information provided when you use our App; and
f) By Information provided when you use our mobile-optimised website from your portable hand-held device including details of your physical location, where you have agreed to it being used.
What will we use your personal information for?
Fundamentally, we use your personal data to get to know you, to model your financial future as accurately as we can and provide you with Independent Financial Advice on an ongoing basis, if required.
Under the UK GDPR, the main grounds that we rely upon in order to process your Information are the following:
Who may we share your personal information with?
In certain circumstances, we may share some of your Information with third-parties. Details of those parties are set out below along with the reasons for sharing it:
a) Other parties within our group of companies.
b) Trusted third-parties in order to provide certain services. We will share your information with third-party service providers such as printing and courier companies and technology providers.
c) Regulatory and law enforcement agencies. As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under the UK GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
d) New business owners if we or our business merges with or is acquired by another business or company. We will share your personal information with the new owners of the business or company and their Advisers. If this happens, you will be sent notice of such event.
Below are some examples of third-parties that we may share some information with in order to provide our services:
• Microsoft Exchange – This allows us to send and receive e-mails and book meetings.
• Intelligent Office (iO) – We use this cloud-based system as a Business Management system, which allows us to manage your data responsibly and provide our services to you.
• Prestwood Truth – We may use this software to map out your financial future with a Lifetime Cashflow and explore various what-if scenarios with you.
• DocuSign – We may use this to generate contracts and allow electronic signing of said contracts.
• Voyant – We may use this software to map out your financial future with a Lifetime Cashflow and explore various what-if scenarios with you.
• Albion Strategic – We may use this Investment Consultancy to help us stress-test our in-house investment research and analysis to help ensure that we are continually providing our clients with the highest quality of ongoing investment advice.
• Prudential – We may use Prudential and/or other financial providers, platforms or fund managers to help us invest and manage your money strategically.
• Financial Express (FE) Analytics – We may use Financial Express (FE) and/or other research and analysis tools to compare portfolio asset allocation and investment strategies for you.
• Skype – We may use Skype and/or other Video Conferencing and/or Screen Sharing software to carry out remote meetings with clients.
• Go To Meeting – We may use Go to Meeting or other Video Conferencing and/or Screen Sharing software to carry out remote meetings with clients.
• Olympus Dictation – We may record meetings using Olympus Dictation and/or other hardware and software.
• Samsung Xchange – We may record telephone calls using Samsung Xchange and/or other hardware and software.
• Boolean Consulting – We may use Boolean Consulting and/or other providers for IT and Network expertise.
• Dimensional – We may use Dimensional and/or other financial providers, platforms or fund managers, to help us invest and manage your money strategically.
• Parmenion - We may use Parmenion and/or other financial providers, platforms or fund managers, to help us invest and manage your money strategically.
• Old Mutual Wealth – We may use Old Mutual Wealth and/or other financial providers, platforms or fund managers to help us invest and manage your money strategically.
• Standard Life - We may use Standard Life and/or other financial providers, platforms or fund managers, to help us invest and manage your money strategically.
• Transact - We may use Transact and/or other financial providers, platforms or fund managers, to help us invest and manage your money strategically.
• 7IM - We may use 7IM and/or other financial providers, platforms or fund managers, to help us invest and manage your money strategically.
• Vanguard - We may use Vanguard and/or other financial providers, platforms or fund managers, to help us invest and manage your money strategically.
• Morningstar – We may use Morningstar and/or other research and analysis tools to compare portfolio asset allocation and investment strategies for you.
• SelectaPension – We may use SelectaPension and/or other research and analysis tools to compare pension strategies for you.
• O&M – We may use O&M and/or other research and analysis tools to compare pension strategies for you.
3. What marketing activities do we carry out?
We may carry out Direct Marketing activities such as:
• Social Media
We would need your consent for these Direct Marketing activities and you can withdraw consent at any time. Simply let us know – contact details at the end of this document.
4. How long do we keep personal information for?
We will only retain your information for as long as is necessary for the purposes for which we have collected it and in accordance with our regulatory and legal requirements.
5. Your rights
You have certain rights in relation to personal information that we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
a) Right to Access - You have the right at any time to ask us for a copy of the Information that we hold about you and to confirm the nature of the Information and how it is used. Where we have good reason, and if the UK GDPR permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
b) Right to Correction or Completion - If Information we hold about you is not accurate or is out of date or incomplete and requires amendment or correction, you have a right to have the data rectified, updated or completed. You can let us know by contacting us.
c) Right to Erasure - In certain circumstances, you have the right to request that Information we hold about you is erased. For example, if the Information is no longer necessary for the purposes for which it was collected or processed, or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
d) Right to Object to or Restrict Processing - In certain circumstances, you have the right to object to our processing of your Information by contacting us at the address or email address set out at the end of this document. For example, if we are processing your Information on the basis of our Legitimate Interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your Information for Direct Marketing purposes. You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.
e) Right to Data Portability - In certain instances, you have a right to receive any Information that we hold about you. You can ask us to transmit that Information to you or directly to a third-party organisation.
6. How do we protect your information?
All your personal Information shall be held and used in accordance with the UK General Data Protection Regulation (the UK GDPR) and national laws implementing the UK GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data.
8. Contact us
If you would like to contact us or are unhappy about our use of your personal information, please get in touch:
Telephone 01344 778990
Financial Planning Partners Ltd
19 Wellington Business Park
You are also entitled to lodge a complaint with the UK Information Commissioner's Office (ICO):
Telephone 0303 123 11113
Information Commissioner's Office