Privacy Policy

During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (“Your Personal Data”). This document explains what we need to do with Your Personal Data, and the various rights you have in relation to it.

Your Personal Data means any information that describes or relates to your personal circumstances. It may identify you directly, for example your name, address, date of birth or national insurance number. It may also identify you indirectly, for example your employment situation, physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing you with assistance with your personal advice requirements, Your Personal Data may include:

• Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.
• Employment and remuneration information, including salary, bonus schemes, overtime, sick pay, other benefits and employment history.
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents.
• Special Category Data, for example health status and history, details of treatment and prognosis and medical reports.
• Details of any pre-existing investment, protection or mortgage products and the terms and conditions relating to these.

When we speak with you about your requirements, we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract, arrange the products you require and provide fully personalised advice tailored to your circumstances, we have the right to use Your Personal Data.

Alternatively, either during initial discussions or when the contract between us has ended, we may use Your Personal Data where it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, regulators, insurance providers and our compliance service provider relating to advice we have given, or contact you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for responsibilities we owe our regulator, the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we may be subject.

When discussing your financial plans we may need to ask you about your ethnic origin, health and medical history (“Your Special Category Data”). We will record and use this information to ensure we recommend and use products that meet your needs fully. For example, health information can affect underwriting for life cover and life expectancy considerations for investments and pensions.

If you have parental responsibility for children under the age of 13, we may need to record information that relates to those children and potentially their Special Category Data, for example where a child has a long-term health problem or disability.

The arrangement of certain types of insurance may involve disclosure of information relating to historic or current criminal convictions or offences (“Criminal Disclosures”). This can be relevant to underwriting, claims and fraud management.

We will use Special Category Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice. This information must be capable of being exchanged between insurance intermediaries and insurance providers to enable customers to secure the important insurance protection their needs require.

We collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during our initial meetings or conversations to establish your circumstances, needs and preferences. You may provide information verbally and in writing, including by email.

We may also obtain information from third parties, for example credit checks, information from your employer and searches of information in the public domain such as the voters roll. We may use technology solutions to verify your credit status and conduct electronic identity checks to comply with anti-money-laundering rules, including Politically Exposed Persons (PEP) and sanctions checks. On some occasions we may ask you to supply a passport or driving licence number to complete an electronic identity check.

In the course of handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems. This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administrative tasks associated with or incidental to that service.
• Submit Your Personal Data to product providers and mortgage lenders, both on paper and online via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf. This will also enable us to verify your identification with the provider, should any queries need to be resolved.
• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any product or policy you may take out, or to inform you of any developments in relation to those products or policies of which we might become aware.

From time to time Your Personal Data will be shared with:

• Investment providers, mortgage lenders and insurance providers.
• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties may include our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers, where required due to your particular circumstances.

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice: to help us meet your financial requirements and provide our professional services.

This sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages. It is shared so we can adequately fulfil our responsibilities to you and as otherwise set out in this Privacy Notice.

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against unlawful or malicious access by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or where we have a legal right or regulatory requirement to hold records indefinitely for complaint handling purposes.

You can:

• Request copies of Your Personal Data that is under our control.
• Ask us to further explain how we use Your Personal Data.
• Ask us to correct, delete or require us to restrict or stop using Your Personal Data. Details as to the extent to which we can do this will be provided at the time of any such request.
• Ask us to send an electronic copy of Your Personal Data to another organisation should you wish.
• Change the basis of any consent you may have provided to enable us to market to you in the future, including withdrawing any consent in its entirety.

Some data is provided jointly, for example on a joint mortgage. If we are later asked by just one person to provide a copy of the data held, we will also need consent from the other person because joint personal information provided for advice and applications cannot later be separated out.

If you have any questions or comments about this document, or wish to exercise any of your rights set out within it, please contact our principal firm:

The Data Protection Officer, Rosemount Financial Solutions (IFA) Ltd, Rosemount House, 2-4 Chequers Road, Basingstoke, Hampshire, RG21 7PU. Tel: 01256 405460.

If we feel we have a legal right not to deal with your request, or to action it differently from how you have requested, we will inform you at the time. You should also contact us as soon as possible if you become aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our regulatory obligations.

If you have any concerns or complaints about how we have handled Your Personal Data, you may lodge a complaint with the UK’s data protection regulator, the ICO, through its website at https://ico.org.uk/global/contact-us/, or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

As part of ensuring that our advice to you remains suitable over the longer term, we may need to contact you in future. For example, we may need to do this if we have recommended a fixed-term mortgage deal where the term is shortly coming to an end.