Suttons Independent Financial Advisers are committed to protecting your personal information.
Suttons Independent Financial Advisers (Authorised FCA reference: 455848) also operate a range of protection business via Sports Financial Services (Appointed Representative reference: 493197).
- Sports Financial Services
- BASI Financial Services
- Hazardous Pursuits
- Insurance Advice Service
- Scuba Financial Services
- Summit Financial Services
What information do we collect about you?
We collect information about you when you engage us for the provision of financial advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so.
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 carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
If you do not wish us to collect and use your personal information in this way, it may mean that we will be unable to provide you with our any of our services.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you.
We won’t share your information for marketing purposes with companies outside our company. In order 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 data we’ll 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’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
We employ a range of data security methods to ensure the security of your data, including:
- Controlled and managed privileged access to computer systems including individual password login
- Logging off computer terminals
- Regular updates to anti-virus and anti-malware software
- Regular software updating
- Regular data backup of files
- Restricted access to physical premises
- Restricted physical access to computers servers
- Secure disposal of sensitive paper-based information
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA). However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as the United States, New Zealand and India.
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long do we keep hold of your information?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain 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-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records. We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 10 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
The Suttons Independent Financial Advisers website, and those operating in the name of its Appointed Representative and Trading Styles, do not store or capture personal information about you when you visit them, they merely record traffic information. This means information about all of our visitors collectively, for example how many visits the website receives. In order to respect our visitors’ rights of privacy, this information is anonymous and no individual visitor can be identified from it. We will only collect personal information about you if you subscribe to Suttons ‘Wealth Updates’ facility or complete an enquiry its Appointed Representative and Trading Styles. In order for this to happen, you will need to fill out the on-line form or complete the registration details. The type of information being collected for this purpose will be apparent from the layout of the form, which also tells you how this information will be used.
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What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
How to contact us
Suttons Independent Financial Advisers / Sports Financial Services Limited
Or write to us at:
Harvey Sutton Suttons Independent Financial Advisers Limited / Sports Financial Services Trinity House 114 Northenden Road Sale Cheshire M33 3HD
June 2018 (Version 1.1)