PRIVACY NOTICE
DATA PROTECTION STATEMENT
We at Big Planning take your privacy very seriously and ask that you read this notice carefully as it contains important information about who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities if you have a complaint.
Big Planning Limited collects uses and is responsible for personal data about you. We are required to comply with data protection regulation and we are responsible as the data controller of that personal data for the purposes of the law.
We provide financial planning, financial advice and intermediary product arrangement services to individuals and businesses.
PERSONAL DATA WE COLLECT FROM YOU
While providing our service to you we may collect the following personal data when you provide it to us:
Contact information – This includes any information that can be used to contact a person such as title, forename, surname, personal telephone number, fax, email address, home address. This may also include work contact information such as work telephone number, fax, work email and work address.
Identity information – This includes any information that can be used to distinguish a person or verify their identity such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, driving licence and national insurance number.
| Financial information | This includes any information relating to a person’s financial circumstances such as income and expenditure, tax status, assets and liabilities, plans and policies, banking, mortgage and credit card details. |
| Employment status | This includes any information about a person’s work status, whether employed, self-employed, unemployed, retired or a student. |
| Lifestyle information | This includes both work and leisure behaviour patterns such as a person’s smoker status, alcohol consumption, general health, sex life and sexual orientation, retirement age and exercise habits. |
| Health information | This includes any information relating to a person’s current and previous physical or mental health and medical history, such as symptoms, diagnoses, procedures, outcomes and genetic data, as well as information about height and weight. |
| Criminal convictions and offences | This includes any criminal convictions, other offences and any outstanding charges or investigations. |
| Racial or ethnic origin | This includes any information about a person’s racial or ethnic background. |
| Dependents and other family members | This includes any personal information such as name, address, telephone number, email address, date of birth and their relationship. Please make sure the person has given their permission to share their data. |
| Other beneficiaries under a policy or service | This includes any personal information such as name, address, telephone number, email address, date of birth and their association.Please make sure the person has given their permission to share their data. |
SPECIAL CATEGORY DATA
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
PERSONAL DATA WE COLLECT FROM OTHER SOURCES
We may obtain personal data from other sources while providing our services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us. The personal data we obtain from other sources may include the following:
| Investments, pension plans or insurance policies | Information may be provided to us directly from investment managers and from other product and insurance providers. |
| Mortgages and other debts | Information may be provided to us directly from mortgage lenders and other credit providers. |
| Identity and other anti- financial crime information | Information may be provided to us by identification and other verification checking agencies. |
HOW WE USE YOUR PERSONAL DATA
The below table sets out how we use your personal data, the lawful bases upon which we collect and use your personal data who we routinely share your personal data with:
Reason for Data Processing |
Lawful Basis for Data Processing |
|---|---|
| To provide you with financial planning | Legitimate interests |
| To apply to providers for information from investment, pension, protection and mortgage providers on your behalf | Legitimate interests |
| To refer you to third parties to provide you with advice or services. | Consent |
| To retain records of any financial planning, or other services provided to you by us to defend potential complaints or legal claims. | Legitimate interests |
| To provide you with details of products and services from ourselves and third parties that may be of interest to you in accordance with your preferences. | Consent |
During our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information set out in the above table, we will be processing it for compliance with regulatory requirements relating to unlawful acts and dishonesty.
WHEN INFORMATION MUST BE PROVIDED BY YOU
We will tell you if providing some personal data is optional and ask for your consent to process it. In all other cases you must provide your personal data for us to provide you with our services.
HOW LONG YOUR DATA WILL BE KEPT
We will retain personal information we collect when we have an ongoing legitimate need to do so.
When we no longer have a legitimate need to retain personal information, we will either delete it or anonymise it, or, if this is not possible then we will securely store it and isolate it from any further processing until deletion becomes possible.
INTERNATIONAL DATA TRANSFERS
We may transfer personal data to the following countries which are located outside the European Economic Area as follows:
- United States of America, as the secure servers that our data storage provider use are located there.
Some countries do not have the same data protection laws as the United Kingdom and European Economic Area. Whilst the European Commission has not given a formal decision that countries must provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to an EU-US and Swiss-US ‘Privacy Shield Framework’, as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union, the EEA, and Switzerland to the United States. This is designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data. Further details regarding Privacy Shield Frameworks can be accessed at www.privacyshield.gov
YOUR RIGHTS
You have legal rights under data protection regulation in relation to your personal data as follows:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
- In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your consent, please see the “Your consent to us processing your special category personal data” heading below.
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
KEEPING YOUR DATA SECURE
We have appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
OUR SUPERVISORY AUTHORITY
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before the ICO.
HOW TO CONTACT US
If you are not satisfied with the level of information provided, or you would like to exercise any of the above rights or make a complaint, please email: johnp@bigplanning.co.uk 65, Viceroy Close Birmingham B5 7UT, with enough information to identify you, e.g. name, address, date of birth.
Please also provide proof of your identity and address and explain the information to which your request relates.