Our Privacy Information explains how we use any personal information that we collect about you.
Who we are and how we can be contacted:
We are Tallow Financial Planning Limited, and our address is as follows:
South Church Enterprise Park
Telephone: 01388 450666
We are registered with the Information Commissioner and our registration number is ZA768423. For the purpose of the General Data Protection Regulations (GDPR) and the Data Protection Bill, we are a data controller.
If you would like to contact us regarding our Privacy Information then please contact our manager responsible for our information technology.
Information we collect and use
We collect information about you when you contact us to talk to us about our services and also when you engage us for financial planning that is necessary for the provision of our services. This information will relate to your personal and financial circumstances and may include:
- Your name and address, date of birth and contact details.
- Your bank account details.
- Details of your savings, pensions and/or other assets.
- Details of any debts and/or other liabilities.
- Details of any protection arrangements that you have; for example life insurance and employer’s death in service cover.
- Information about any contact with you e.g. emails, letters, telephone calls and meetings.
- Information that is classed as sensitive personal information including information regarding your race, ethnic origin, political views, trade union membership, health, sex life or sexual orientation. This type of information will only be collected and used when it’s necessary to help you arrange products or services that you require or to comply with our legal obligations.
- Information that you provide about other people for example, family members, parents, relatives and joint applicants, beneficiaries, potential beneficiaries or trustees.
- Information on children when you want us to help you with full family financial planning or when you want to make financial provision for a child who is not your own for example a grandchild. In these cases we will only collect information to identify the identity of the child such as name, age, address and gender unless a third party such as an investment product provider requires additional information.
- We may require and collect additional information about you so we can provide you with suitable advice but only when it is necessary to do so.
- Information when you voluntarily complete client surveys or provide feedback to us.
- Information that is automatically collected e.g. via cookies when you visit our website.
- Visual images of you when you visit our offices as we have security cameras.
- Information that you provide for any presentations or training that we provide.
- Identity evidence and Financial Sanctions records.
Please note that we may require and collect additional information about you if it is required to help us provide you with our services.
Information that we collect from you when you use our website
When you visit our website, we will place a cookie on your computer. A cookie is a small data file that will store a small piece of information and will for example, remember that you have visited our website or performed a certain action. They are designed to help us improve your experience when you visit our website. Our cookies help us track our visitor behaviour anonymously which means that we do not know who has visited our site and therefore we will not have information regarding any individual’s personal details.
You may be able to delete, restrict or block cookies from your information technology device by adjusting your browser settings. Alternatively, you can visit www.aboutcookies.org.uk which contains information about cookies, including how to delete them. If you are using our website, then by continuing to use the site you consent to the setting of the cookie.
How we collect your information
We may collect information in the following ways:
- In meetings with you.
- During telephone conversations with you.
- By email, letter or from our forms that you have completed.
- If you provide authority to another firm or organisation to let them provide information to us.
- If an attorney, guardian or other individual provides information on your behalf.
- If you ask us to contact a professional body such as your solicitor or accountant.
- If you ask us to contact your employer regarding your pension arrangement, death in service or other benefit that they may have available.
- From application forms that you complete to apply for products or services.
- If we hold events and you complete an application form or complete a feedback questionnaire.
- If you participate in surveys.
- If you visit our website – see section above entitled ’Information that we collect from you when you use our website’.
- By copying any documents that you provide to us.
- From carrying out checks to verify your identity and for Financial Sanctions checks which we are legally required to do.
- From our security cameras.
Why we need to collect and use your personal data
We will only collect information that is lawful, fair and necessary. We will collect and use your information only where:
- We have informed you that we have a Privacy Information document and you have had the opportunity to read through this. If you do not become one of our clients we will hold your information on file for up to 14 months.
- The legal basis for collecting and processing your information is contract. If you become one of our clients you will sign a Client Agreement with us and therefore we have a contract with you for providing the services detailed in the Client Agreement. Some of the data that we collect requires your explicit permission in particular, in relation to any health information.
- It is necessary to provide the services that you require from us and to help you find the most suitable product or service for you and also to apply for a third party products or services. An example is a pension plan where we agree to partially complete the application for you.
- It is necessary to meet our legal or regulatory obligations for example when dealing with certain pension transactions.
- If it is in your interest that we contact third parties to be able to provide a suitable advice for you. An example would be contacting your accountant regarding your tax affairs.
If you do not want us to collect and use your personal information this way then it is unlikely that we can provide our services to you.
Who we may share your information with
In order to deliver our service to you, we may share information with third parties as we have outlined above under the section entitled ‘Why we need to collect and use your personal data’ and the third parties will include:
- Professional advisers such as accountants and solicitors.
- Organisations that provide products and services but only when we are carrying out research on your behalf or when assisting you to arrange products or services.
- 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 identification verification purposes.
- Your employer.
- Our regulatory and supervisory authorities for example the Financial Conduct Authority.
- Law enforcement agencies for the prevention of crime.
- HM Revenue & Customs for taxation information and for the prevention of tax avoidance.
- Software and systems providers.
- Where you explicitly ask us to.
Where third parties are involved in processing your data we will 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 will only act in accordance with our written instructions.
We will not share your information with other companies, individuals or partnerships for marketing purposes.
Where your information is processed
The majority of your information is processed in the UK. As we are using cloud computing services, your data may be held outside of the UK in the European Economic Area (EEA) but also in other countries.
Any of your personal data that is transferred outside the EEA will only be transferred to a country with an adequate ruling or where appropriate safeguards (such as the relevant company being signed up to privacy shield, or having appropriate contracts dealing with this) are in place.
Security of your data
We are committed to protecting the confidentiality and security of the information that you have provided to us or any information that other individuals, partnership or companies have provided about you. We have in place appropriate technical, physical and organisational security measures to protect against any unauthorised access or damage to or loss of your information.
Please note that emails are only secure when they have been encrypted.
How long we keep hold of your information
We will keep your information for no longer than necessary. We are however subject to regulatory requirements to retain data for specific 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.
What individual rights you have
You have the following rights:
- Right to be informed.You have the right to be told in a clear and concise way about what personal data we hold and what we do with it. We provide this information by providing this Privacy Information to you.
- Right of access.You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please write to or email us using the contact details shown above. We will provide this to you within one month of receipt of your request unless your request is complex or we have numerous requests to deal with in which case we will provide this to you within three months.
- Right to request that your personal information be rectified.If you are aware that any data that we hold for you is inaccurate or incomplete, you have the right to have this rectified. If this is the case, please let us know and we will investigate and correct our records.
- Right to request erasure/right to be forgotten.You have the right to ask for your information to be deleted or removed if we do not have a compelling reason for holding the data. Please be aware that we are subject to regulatory requirements to retain data for specific 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.
- Right to restrict processing.You have the right to block or suppress processing of your personal data for certain reasons. In this case we will have to retain this data to ensure that we do not use it in future for the reasons that you have restricted.
- Right to data portability.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 on our customer database to another IT environment in a safe and secure way.
- Right to object.You can object to us processing your personal information based on our legitimate interests (including profiling which means any form of automated processing of personal data to evaluate certain personal aspects relating to a person, in particular data to evaluate or to analyse or predict aspects concerning that person) or for the performance of a task in the public interest or exercise of official authority, direct marketing and processing for scientific or historical research and statistics. We will comply with your request unless we have compelling legal grounds for the processing, which overrides your interests, rights and freedoms or if the processing is for the establishment, exercise or defence of legal claims.
- Rights related to automated decision making including profiling.You have the right to ask us to give you information about our processing of your personal information, request human intervention or challenge a decision where processing is done solely by automated processes and also to ask us to carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
How to complain about your data and your privacy
We will only collect data that is lawful, fair and necessary and will collect use and safeguard your personal data in line with data protection laws. If you believe that we have not handled your data in line with this Privacy Information then please contact us using the contact details shown above and we will thoroughly investigate your complaint and do what we can to get things right.
If you are still unhappy when you receive our response, you can complain to our data security supervisory authority who is the Information Commissioner. Their contact details at the time of preparing this information are:
Information Governance Department
Information Commissioner’s Office
Telephone: 0303 123 1113