Privacy Policy

What is “Personal Data”?

Personal Data means any information that describes or relates to your personal circumstances. It may identify you either directly or indirectly.

In the context of acting as your personal financial planning advisers, your Personal Data may include:

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses, national insurance number and documents that are necessary to verify your identity

• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history

• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants

• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)

• Any pre-existing investment, pension, mortgage / finance or insurance products and the terms and conditions relating to these

• Any other information that could be associated with your cultural or social identity.

 

What We Do with Your Personal Data?

As Part of Our Contracted Service to You

Whilst you choose to pay for our services, we have the right to use your Personal Data for the purposes of:

• Completing a Comprehensive Financial Review (financial planning assessment)

• Contacting you between pre-agreed review meetings to aid progress of agreed actions and to seek updates on your position

• Contacting you as and when appropriate in order to provide personal guidance or recommendations in response to changes in external conditions such as tax rules or relevant legislation

• Recommending and setting up specific investment, pension or insurance products on your behalf

• Providing ongoing product related administration services and acting as your agent

• Contacting you occasionally via email newsletter with generic information or guidance which is relevant to our ability to provide you with the best possible financial planning services and where one to one contact is not practical. For example:

  • Investment comment

  • Changes to One Life Wealth Planning investment models

  • Tax year end action reminders

  • Details of changes to tax rules or legislation such as those announced in the annual budget, news relating to

  • Staff or other general service changes which affect how we look after our clients

• Submit your Personal Data to Product Providers, both in paper form and on-line 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 and to deal with any additional questions or administrative issues that providers may raise.

• Use your Personal Data for the purposes of responding to any queries you may have in relation to any investment/finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware

Outside of Any Contracted Service

Either in the course of initial discussions with you (prior to you becoming a client) or when the contract between us has come to an end for whatever reason, we have the right to use your Personal Data provided 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 product providers or our compliance service provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.

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

 

Processing “Special Data”

Where you ask us to assist you with, for example your insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (your Special Data). We will record and use your Special Data in order to make enquiries of insurance providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

 We will use Special Data in the same way as your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

 

How Do We Collect Your Personal Data?

We will collect and record your Personal Data directly from you. You will usually provide information during our meetings or conversations with you to establish your circumstances and needs and preferences in relation to investments, pensions, insurances and general financial planning arrangements. You will provide information to us verbally and in writing, including email.

 

How Do We Store and Access Your Personal Data?

We record and store your Personal Data in our paper files, on 3rd party financial planning software tools and on our computer systems. These include email servers, hard drives and cloud-based data storage facilities such as Dropbox or Microsoft OneDrive. With the exception of paper files, all data can be accessed via web-based applications. We also have limited access to this data via mobile devices (notably emails and SMS messages).

This information can only be accessed by employees within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.

Please note that One Life Wealth Planning Ltd does employ the services of 3rd party IT support companies from time to time. It is necessary to grant them access to our systems only to the extent necessary to update and maintain them when such support is required.

 

Sharing Your Personal Data

From time to time we must share your Personal Data with (for example):

• Investment 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 will include but may not be limited to, our compliance advisers, product specialists, providers of legal services such as estate planners, (in each case where we believe this to be required due to your particular circumstances).

• Third parties who act on our behalf as business consultants or may be considered as potential purchasers or business partners of the company

 In each case, we will only share information which is regarded as necessary for the requirements of the third party and steps are taken to ensure your data cannot be used for any other purpose.

 

Security and Retention of Your Personal Data

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 it being accessed unlawfully or maliciously 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 in instances whereby we have legal right to such information (for example, in relation to any regulated recommendations made), we will retain records indefinitely.

 

Your Rights in Relation to Your Personal Data

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)

 

Marketing

One Life Wealth Planning does not use any of your information for marketing purposes. Nor do we make it available to anyone else for this purpose.

Our only contact with you will be as part of our contractual service commitments, or where it is necessary as part of our regulatory or legal accountabilities.

 

Further Contact & Complaints

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact Nick Evans. One Life Wealth Planning Ltd. 01707 262541. nick@onelifewealth.co.uk.

If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their 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.

Last updated August 2023