We are committed to protecting and respecting your privacy and this policy (together with our Client Agreement Appendix: Protecting your personal information) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This policy sets out our practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection legislation, Christchurch Investment Management Ltd of 2 White Lion Court, Cornhill, London EC3V 3NP is the data controller.
This privacy notice explains how we use any personal information we collect about you.
Our privacy promise
- To keep your data safe and private
- Not to sell your data
- To give you ways to manage and review your marketing choices at any time
What information do we collect about you?
We collect information about you when you engage us for financial advice, mortgage advice and/or investment management services. 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.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
Information abour connected individuals
We may need to gether personal information about your close family members and dependants or people you have commercial links to, for example other directors or officers of your company, in order to provide our services 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?
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. Failure to provide this information may prevent or delay us fulfilling these obligations or performing services.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we collect your personal information?
We will collect personal information about you from a number of sources including:
- Information you give directly to us during meetings or discussions with you in person, over the phone and written communications you send us (letter or email).
- Information from or through other organisations that you authorise to release information to us (e.g. other financial services companies, solicitors, accountants).
- Information available on public registries (e.g. Companies House, Charities Commission etc.).
- Information given to us in the delivery of our services (e.g. application forms).
You are not required to give us this information, but in some cases if you fail to provide the requested personal data we shall be unable to provide the service you request.
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.
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 other companies.
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. Methods used to enhance the security of the data during transfer include password protection and/or encryption and/or a secure mail/document transfer portal.
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.
How long do we keep hold of your information?
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 data for specified minimum periods. These are generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-outs
- Three years for insurance business.
These are minimum peiods, during which we have a legal obligation to retain your records.
We also reserve the right to retain data where we believe it's in our legitimate interests to do so. In any case, we’ll not usually retain your personal data for longer than ten years after you cease to be a client.
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.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
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.
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.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
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
0303 123 1113 (local rate)
How to contact us
By telephone 020 7826 4350
Or write to us at: Christchurch Investment Management Limited, 2 White Lion Court, Cornhill, London EC3V 3NP.