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Privacy and Cookie Policy

Website privacy policy

This privacy policy sets out how Finance Alliance, which is a trading style of Select Financial Planning Ltd and is registered in England No. 12416033, uses and protects any information that you give.

Select Financial Planning Ltd is committed to protecting the privacy of all individuals it interacts with and we therefore ask that you please read this fair processing notice carefully. This fair processing notice explains how various Select Financial Planning Ltd collects, processes and uses your personal information.

Our wealth management services are provided through personal, face to face advisors, delivered by our Select Financial Planning Ltd. Select Financial Planning Ltd acts as principal in its relationship with the Select Financial Planning Ltd, which means that we provide the products, services and regulatory and compliance framework in which our Partners operate.

Where you have a Select Financial Planning Ltd, your Partner will provide your services and will process your personal information in accordance with its own Privacy Policy which is available on their Website

Select Financial Planning Ltd Partnership

Select Financial Planning Ltd will collect personal information about you as part of its role as principal, in order to ensure that the Select Financial Planning Ltd are compliant with applicable financial regulations. We do this by providing shared services product and servicing activity, conducting audits and dealing with any complaints that you may have. As principal, Select Financial Planning Ltd also has access to all personal information that Select Financial Planning Ltd collect and use; this means that Select Financial Planning Ltd is the joint controller of your personal information along with your Partner.

For the purposes of this section and section 2, “we” and “our” shall refer to Select Financial Planning Ltd and “Partner” shall refer to your Select Financial Planning Ltd.

Processing of your personal information

We will collect and use different personal information about you for different reasons, depending on our relationship with you.

Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership) in order to provide comprehensive advice and deliver health related products to you.

In our role as principal and on behalf of Partners, we may also use details of any unspent criminal convictions for fraud prevention purposes to help Partners during the process of investing money.

Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and we are responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.

How we collect Your Personal Data

If you are a prospective or existing client enquiring about or receiving wealth management services through our Partners the following will apply:

What personal information may we collect?

  • Information collected from any communications with you; and
  • Information obtained through audits or processed in the process of ensuring our Partners comply with their regulatory obligations.
  • Information stored on our client relationship management systems which Partners have access to and store information onto.
  • Information collected when dealing with any complaints you may have;

This will include the following personal information:

  • General information such as your name, address, phone numbers and email addresses, date of birth and gender.
  • Identification information including passport, driving licence, national identity card (for non-UK nationals), government issued ID verification and address verification documents such as council tax letters, bank statements and evidence of benefit entitlement.
  • Employment information such as job title, employment history and professional accreditations.

Financial information:

  • Bank details
  • Financial reviews (fact finds)
  • Information relating to your personal finances such as your financial liabilities and assets, income and outgoings
  • Information obtained from carrying out identification checks and checking sanction lists and politically exposed persons (PEP) screening, including bankruptcy orders.

Information relevant to the services that your Partner provides to you, including:

  • previous and current investments
  • information about your lifestyle
  • attitude to investment risk
  • existing plan details
  • objectives
  • copies of your will
  • information about any trusts you have.
  • Information about your family including information about your dependants.
  • Information obtained during telephone recordings.
  • Information which we have gathered from publically available sources such as the electoral roll, internet search engines and social media sites where you have been flagged as a PEP and our Partners are required to carry out enhanced due diligence.

What special categories of personal information will we collect?

  • Details about any criminal convictions and any related information which have been obtained from our Partners’ sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
  • Details about your health which are relevant to the service you are receiving, for example where you have disclosed such information to our Partners or to us because it explains your risk appetite for investments.
  • In limited circumstances and where relevant to the advice being provided by our Partner, we may also collect information which relates to your trade union membership, ethnicity or political opinions where you have disclosed it to our Partner.

How will we collect your personal information?

We will collect information directly from you when:

  • you contact us by email, telephone and through other written and verbal communications.

We will also collect your personal information from:

  • Your Partner directly;
  • The Select Financial Planning Ltd client relationship management system and hosted platforms;
  • Publicly available sources such as the electoral roll, court judgments, insolvency registers, internet search engines and social media sites.
  • Other Select Financial Planning Ltd group companies where appropriate, including independent financial advisers (IFAs) (where you were previously a client) that have been acquired by the Select Financial Planning Ltd.

What will we use your personal information for?

There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.

We will rely on the following “lawful basis” when we process your “personal information”:

  • We have a legal or regulatory obligation to use such personal information. For example, our regulators require us to hold certain records of our dealings with you.
  • We have a valid business reason to use your personal information and which is necessary for our everyday business operations and activities, for example to respond to any queries relating to our Partner services that we receive.
  • In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.

When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basis in these circumstances:

  • It is in the substantial public interest to comply with regulatory requirements relating to unlawful acts and dishonesty – such as carrying out fraud, credit and anti-money laundering checks.
  • You have given your explicit consent to our use of your special categories of personal information. In some cases we are not able to review a complaint in respect of the Partner service you have received unless we have all the information we need, which could include your health information for example.
  • We need to use such special categories of personal information to establish, exercise or defend legal rights, such as when we are facing legal proceedings or want to bring legal proceedings ourselves.
  • There is a substantial public interest in the prevention and detection of unlawful acts such as where we suspect fraud.

What special categories of personal information will we collect?

  • Details about any criminal convictions and any related information which have been obtained from our Partners’ sanctions checks and PEP screening. This will include information relating to any offences or alleged offences you have committed or any court sentences which you are subject to.
  • Details about your health which are relevant to the service you are receiving, for example where you have disclosed such information to our Partners or to us because it explains your risk appetite for investments.
  • In limited circumstances and where relevant to the advice being provided by our Partner, we may also collect information which relates to your trade union membership, ethnicity or political opinions where you have disclosed it to our Partner.

Who will we share your personal information with?

We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:

  • Your Partner
  • Other Partners within the Select Financial Planning Ltd where necessary to support other wealth management services or advice ( e.g. your Partner leaves the Select Financial Planning Ltd, another Partner provides other/additional services)
  • Other Select Financial Planning Ltd group companies, including any independent financial advisers (IFAs) (where you were previously a client) that have been acquired by the Select Financial Planning Ltd;
  • Our regulators including the Financial Conduct Authority and the Financial Ombudsman Service.
  • Selected third parties in connection with any sale, transfer or disposal of our business.
  • Our insurers.
  • Data protection authorities.
  • Financial crime and fraud detection agencies.
  • The police, HMRC and other crime prevention and detection agencies.
  • Third parties who have entered into contractual arrangements with us to provide services we need to carry out our everyday business activities such as partner support specialists, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.

How long do we keep your personal information for?

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out,  to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which we must adhere to.

Your rights

You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time if you wish to exercise these rights; we will not usually charge you.

We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:

  • in doing so we could not comply with our own legal or regulatory requirements for example we are under obligations to hold records of our dealings with you for certain periods of time; or
  • in doing so we could not provide services to you and would have to cancel your client agreement, for example we could not enter into investments on your behalf if we had deleted your personal information.

We will of course inform you if any of the above situations arise and if we are unable to comply with your request.

Cookies

This Select Financial Planning Ltd website uses cookies – small text files that are stored on your computer or in your browser – to help us to monitor how visitors use our site and allow us to maintain the optimum experience for website users. The website does not store or capture personal information about you when you visit it, it merely records traffic information. This means information about all of our visitors collectively, for example the number of 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.

You can disable and delete cookies by changing the appropriate setting within your browser’s ‘Help’, ‘Tools’ or ‘Settings’ menu. Please note that by disabling cookies you may not benefit from some of the features of our site. You can find out more about deleting or controlling cookies by visiting aboutcookies.org.

Updates to this notice

From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, other developments or new products and services being offered.

We will provide you with the most up-to-date notice and you can check our website periodically to view it or you can request a copy from your Select Financial Planning Ltd.

This notice was last updated on 21/10/2020.