Clarion Privacy Notice

The Clarion group of companies takes your privacy very seriously and is committed to protecting your personal information. Please read this Privacy Policy carefully, it will only take 10 minutes of your time.

The effective date of this privacy notice is 25th May 2018.

Who are ‘we’?

In this notice, “we”, “us” or “our”, means Clarion Wealth Planning Ltd and Clarion Investment Management Ltd, together ‘Clarion’.  This privacy notice applies to both aforementioned companies.

Clarion Wealth Planning Limited (company number 06372922) and Clarion Investment Management (company number 07899035) are companies established in England with its registered address at Overbank, 52 London Road, Alderley Edge, England, SK9 7DZ. Both companies act as data controllers and are registered with the ICO.

Clarion specialise in providing clients with unique, bespoke personalised plans to protect and promote long-term financial wellbeing. To provide our specialist advice it is important that we know you and fully understand your objectives.

This Privacy Notice sets out 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 in the event you have any concerns.

We are unable to provide you with our services without processing your personal data.

How to contact us

If you have any questions about our Privacy Notice or the information we collect and use about you, please contact:

FAO: Director of Operations
Clarion Wealth Planning
Overbank, 52 London Road
Alderley Edge
Cheshire
SK9 7DZ

Email address: datasecurity@clarionwealth.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

What is personal data and how do we collect it?

Personal data means any information about you that allows you to be directly, or indirectly identified. Direct identifiers include your name, email address, address or phone number. Indirect identifiers is information that when  combined with other information in our possession, or control, allows you to be identified.

Each time  you interact with us whether that be through face-to-face meetings, by phone, email, in writing, social media, or the use of our website  we will collect and process personal data about you.

We may also receive information about you from third parties such as business partners, credit or fraud checking agencies, as well as other third parties with whom we have had no prior contact.

Clients and Prospective Clients

If you are our client, or intend to become our client, we need to build up a detailed picture of your current personal and financial position, so we can deliver financial planning unique to your circumstances, values and aspirations..  Information that we collect from you and  hold may include:

  • Detailed information about who you are, e.g. your name, date of birth, contact details, national insurance number, place of work.
  • Information about children and other family members where it is relevant to your financial plan. In these cases, we will collect and use only the information needed to identify those near and dear to you. This notice will therefore apply to them and you should refer them to this notice.
  • Financial information including employment status, details of your income, expenditure, assets, bank accounts and other financial products.
  • Information about your interests and hobbies.
  • Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status.
  • Information relating to your morals, beliefs and values that influence or are an important factor to your unique financial plan.

In certain other circumstances, such as when you visit our offices, or use our website we may additionally collect:

  • Information that is automatically collected, e.g. via cookies when you visit our website.
  • Information if you visit our offices, e.g. visual images collected via closed circuit television (CCTV).

Professional Connections

We may hold information about you in your capacity as a business or professional contact which may include solicitors, bankers, auditors and insurers. The information we hold may include:

  • Information about who you are, e.g. your name, place of work and contact details.
  • Information about your interests and/or hobbies.
  • Information that is automatically collected, e.g. via cookies when you visit our website.
  • Information if you visit our offices, e.g. visual images collected via closed circuit television (CCTV).

Sensitive or Special Category Data

Sensitive or Special Category data refers to data that may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. It also captures information in relation to criminal convictions and offences.

We are required by our regulator, the Financial Conduct Authority (FCA), to collect and collate enough information about our clients to ensure that the advice we give is suitable.  This inevitably involves processing sensitive data without which we will be unable to fulfil our contract to you and also our obligation to our regulator.

However, we do try and ensure that we only collect sensitive data necessary and relevant to the areas that we are advising upon and it is proportionate to the advice given.

Why we need your personal data

As an active or prospective client, we have or hope to have a contractual relationship with you. To provide financial or wealth planning services tailored to you it will be necessary for us to collect and process detailed information.  As stated above, this may include where appropriate and necessary sensitive or ‘special category’ personal information.

We have set out below, in a table format, a description of  the ways we plan to use your personal data, and which of the lawful bases we rely on to do so.  We have also identified what our legitimate interests are, where appropriate.

Data Subject

Purpose / Processing Activity

Lawful Basis for processing

Client Processing personal & financial data in relation to providing financial planning services Performance of a contract or in order to take steps at your request prior to entering into a contract
Client Processing ‘sensitive’ personal information in relation to providing financial planning services Consent*
Client Sharing information with product providers and service providers where you have purchased their services and/or products Performance of a contract or in order to take steps at your request prior to entering into a contract.
Client Sharing data with third-party service providers, providing services to Clarion. Our legitimate interests; including everyday business activities and operations such as maintaining business records, invoicing, maintenance of our IT and other professional services.
Client Sending out marketing information such as newsletters and investment updates. Our legitimate interest; keeping you up to date on related products and services.

You can opt out of this at any time.

 

 

Client

 

 

Organising events tailored to your specific interests and/or hobbies. Our legitimate interest; to provide you with invitations and information on events and seminars.

You can opt out of this at any time.

Prospective Clients and

Professional Connections

Sending out marketing information such as newsletters and investment updates. Consent.

You can opt out at any time.

Prospective Clients andProfessional Connections Processing information about your personal interests and/or hobbies. Consent.

You can opt out at any time.

Clients,

Prospective Clients and

Professional Connections

Processing analytical information about your use of our website and online services such as your IP address, details of your browser and/or device, length of your visit to website and which pages you’ve visited. Clarion has a legitimate interest as this enables us to properly administer our website and our business.

It also helps us to grow the business and to aid our marketing strategy.

 

Client,

Prospective Clients and

Professional Connections

 

Processing data collected when visitors visit our offices, such as CCTV pictures. Our legitimate interest; to ensure the safety of colleagues and visitors whilst on our premises and to protect our physical assets.

*Because this is special category data, we may also retain special category data for the purpose of responding to, or supporting the enquiries made by the Financial Ombudsman Service about the services we provide, and we may additionally hold certain special category data where it is necessary for the establishment, exercise or defence of legal claims.

Marketing Communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (as outlined in the above table)

Under the ePrivacy Regulations we may lawfully send you marketing communication where (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and, in each case, you have not subsequently opted out of receiving marketing communications.

Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

You can ask to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at datasecurity@clarionwealth.co.uk

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided for other purposes necessary for the ongoing delivery of your services.

Who we share your personal data with

We may have to share your personal data with the parties set out below:

  • Other companies in our group who provide services to us,
  • Service providers who provide IT and system administration services.
  • Service providers who provide marketing or PR services to us.
  • Service providers who provide compliance and legal services to us.
  • Professional advisers including solicitors, bankers, auditors and insurers.
  • Government bodies that require us to report processing activities.
  • Fraud prevention agencies.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. In the majority of cases tthird parties will process your personal data for a specified purpose and in accordance with our instructions. On rare occasions however, and strictly in accordance with data protection law, your data may be transferred to third parties for their own purposes.

International Transfers

Where possible, we avoid transferring your data outside of the European Economic Area (EEA) as many countries outside of this area do not always offer the same levels of protection to your personal data.  UK data protection  law prohibits the transfer of personal data outside of the EEA unless the transfer meets certain criteria, and controls to protect your data are implemented.

If your data is transferred outside of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Data Security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to do so.

How long we hold your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

If you cease to be a client of Clarion, we will delete any data that we no longer require.  However, we will keep a record of any advice given to adhere to certain rules set by the Financial Conduct Authority (‘FCA’) and, in addition, where we have a legitimate interest or a lawful basis to do so.

In civil actions pursued through the courts, there is usually an overall “long-stop” requirement that the matter complained about should have happened within the last 15-years. This limitation does not apply to complaints to the Financial Ombudsman Service. There is no 15-year “long-stop” rule in the complaints-handling rules made under the Financial Services and Markets Act and the Consumer Credit Act.

This reflects the fact that financial products are “intangible” and can be of a very long-term nature. Problems – for example, with a whole-of-life policy – may only emerge or become apparent many years after the contract was taken out.

We will therefore continue to hold personal information for a period of two years after we become aware of your death.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your rights regarding your personal data

Under UK data protection law you have a number of rights in relation to your personal data, including; the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights above, please email us at datasecurity@clarionwealth.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee (or refuse to comply with your request) if your request is clearly unfounded, repetitive or excessive.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.We will respond to legitimate requests within one calendar month. Occasionally it may take us longer especially if your request is particularly complex. In this case, we will notify you.

Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

What are cookies?

A cookie is a small file that is saved on to your computer or other device when you visit our website so the website can remember who you are. Most major websites use cookies and they can help a website to arrange content to match your preferred interests more quickly.

We use cookies on our website to understand how the website is being used and to make improvements, we do not use cookies on our website to modify prices or services specific to you.

Two types of cookies are used by us on our site:

  • Session Cookies: which are temporary cookies that remain in the cookie file of your browser until you leave the site; and
  • Persistent cookies: which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

Session Cookies allow you to carry information across pages of our site and avoid having to re-enter information and to allow you to access stored information.

Persistent Cookies help us recognise you as a unique visitor and which will deploy each time you return to our website and to allow us to assess and understand our content, which pages are being visited and how long visitors spend on each page.  We specifically use Google Analytics for this. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Most web browsers allow some control of most cookies through the browser settings. The “Help” section in your browser should provide you with the necessary information to adjust your settings and control the creation and storage of cookies on your hard drive.

If you alter your browser settings to refuse our cookies you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

Our website may contain electronic images known as web beacons that allow us to count users who have visited those pages. Web beacons are not used to access your personally identifiable information on our site. They are a technique to compile aggregated statistics about our website’s usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view and a description of the page on which the web beacon resides.