GL Integrity Financial Planning understands its obligations about your fundamental right to a private life and has implemented systems and controls to ensure your rights and freedoms are protected.
GL Integrity Financial Planning undertakes to meet its obligations under the Data Protection Act 1998/2018, the Privacy and Electronic Communications Regulations 2003 and the EU General Data Protection Regulation (GDPR).
WHO WILL PROCESS YOUR PERSONAL INFORMATION?
Your personal information will be initially processed by GL Integrity Financial Planning. Your personal data will be further processed by On-Line Partnership Group Limited on behalf of its subsidiary company The On-Line Partnership Limited who acts as our Principal for regulatory purposes. All parties will process your personal data in accordance with this privacy notice.
WHY IS YOUR PERSONAL INFORMATION REQUIRED?
Your personal information is required to enable us to take necessary steps at your request prior to entering into a contract and to perform such a contract. This may include reviewing assets and liabilities, bank account validation, identity and age verification checks, credit checks, preventing and detecting fraud, money laundering or other crimes and any other requirements in accordance with rules set by the Financial Conduct Authority (FCA) or other applicable legislation.
WHAT HAPPENS IF WE WANT TO PROCESS YOUR INFORMATION FOR OTHER REASONS?
Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about we will notify you.
WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION?
Your personal data is essential to enable us to take steps at your request prior to entering into a contract or to perform a contract to which you are a party. Without this information we will not be able to proceed to provide any financial service.
WHAT MAKES THE PROCESSING LAWFUL?
Because the processing is necessary:
- For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
- For compliance with a legal obligation to which we are subject;
- For the performance of a task carried out in the public interest;
- For the purpose of the legititmate interests pursued by us.
KEEPING YOUR INFORMATION UP TO DATE
We will record your information exactly as you provide it. You may ask us to update it at any time and we will action your request promptly and where possible notify relevant third parties of any changes.
WHAT ABOUT SENSITIVE PERSONAL DATA?
Unless we are processing because it is necessary for reasons of substantial public interest, we will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific processing activities. In such cases you will be asked to sign a separate consent form to evidence this and that you understand the purpose(s) of the processing of such data. Your consent may be withdrawn at any time.
HOW WILL WE FURTHER USE YOUR PERSONAL INFORMATION (OUR LEGITIMATE INTERESTS)?
- To contact you to ensure that our records of your personal information are correct;
- To respond to questions or complaints you have about our services;
- To update you with changes in our terms;
- For statistical or research analysis relating to the performance of our business or that of our principal and understanding the changing needs of our clients;
- To review, improve and develop services we offer or handle complaints;
- To pursue debts or unpaid fees;
- To evidence company practices;
- To evidence the standards and processes carried out to conform to the company’s ethical standards and expectations;
- For direct marketing activities;
- To protect the business from risks which might be introduced by an individual
You have the right to object to processing for these purposes and we shall cease unless we can show we have competing legitimate grounds to continue.
PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST
We will use the information provided to protect members of the public against dishonesty, money laundering or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group Plc or Creditsafe Business Solutions Ltd.
WHAT INFORMATION IS REQUIRED
We only collect information that is necessary to carry out the purposes listed above. This included information you supply and data we receive from reference agencies. Where practical and lawful we will inform you about any personal data we receive about you from third parties of which you may be unaware.
HOW SECURE WILL YOUR DATA BE?
We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security measures will be in place to prevent unauthorised access, alteration, disclosure, loss, damage or destruction of your information. If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding appropriate security measures in place and only process your information in the way we’ve authorised them to. These organisations won’t be entitled to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we’ve set.
WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?
We may share your information with:
- Appropriate staff such as those who carry out financial or compliance functions including third party Paraplanning Support, Parasols Ltd.
- Organisations that need your information because we are required to provide it by law (e.g. The FCA, ombudsman services, HMRC etc).
- Organisations that carry out credit references or identity checks such as GB Group Plc or CreditSafe Business Solutions Ltd. These organisations may keep a record of the information and may disclose the fact that a search of its records was made to its other customers for the purpose of assessing the risk of giving credit, to prevent fraud and to trace debtors. may
- Law enforcement agencies, courts or other public authorities if we have to, or are authorised to by law.
- Our accountants and auditors.
- Product providers we use to provide financial services or for direct marketing (see below).
- Where we or our Principal go through a business transaction, such as a merger, being acquired by another company or selling a portion of its assets, your information will, in most instances, be part of the assets transferred. Cl
TRANSFERRING DATA OUTSIDE THE EUROPEAN UNION
We do not usually transfer any of your personal data outside of the EU except when we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies, like Creditsafe Business Solutions Ltd, may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases Creditsafe encrypts any data it sends to other agencies and only transfers information necessary to carry out checks.
(A list of countries used to perform checks include Germany, Netherland, Belgium, France, Sweden, Norway, Finland, Luxembourg, Switzerland, Liechtenstein, Spain, USA, Estonia, Latvia, Lithuania, Poland, Slovakia, Czech Republic, Hungary, Slovenia, Bosnia, Serbia, Montenegro, Croatia, Macedonia, Kosovo, Albania, Bulgaria, Romania, Ukraine, Austria, Denmark, Moldova, Portugal, Italy, Canada, Brazil, Greenland, China, India, Australia, Russia, South Korea, Taiwan, Mexico, South Africa, New Zealand, Hong Kong, UK.)
WHAT ABOUT DIRECT MARKETING?
We will use the information provided now and, in the future, to carry out direct marketing activities as these are legitimate interests pursued by us. Sometimes this includes, with your consent, sharing data with product providers for their marketing activities. You can choose which method you’d prefer us to use to contact you (by email, telephone, SMS or post) and you have the right to object at any time to the use of your personal data for this purpose and we will cease marketing activity. Just let us know my email or call about your preferences or unsubscribe from Updates.
AUTOMATED DECISION-MAKING PROCESS
We sometimes use automated processes when making decisions, but you will not be subject to a decision based solely on automated processing, including profiling.
TELEPHONE CALL RECORDING
In line with The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 we may record incoming or outgoing telephone conversations for the following purposes:
- Establishing facts and evidence for business transactions;
- Ensuring compliance with regulatory or self-regulatory practices;
- Ascertaining and demonstrating that standards are being met;
- Preventing or detecting crime;
- Investigating or detecting the unauthorised use of that or any other telecommunication system;
Safeguarding the effective operation of the telecommunications system.
HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
The Financial Conduct Authority lays down rules relating to how long information should be held for and we will keep your information to meet these requirements. We will not keep your information for longer than is necessary.
REQUESTING A COPY OF THE INFORMATION WE HOLD
You may at any time ask for a copy of the information we hold about you – it is your legal right. We will provide you with a copy of any non-exempt personal information within one month unless we ask you for an extension of time. To protect personal data, we will ask you to verify your identity before we release any information. We may refuse your request if we are unable to confirm your identity.
IMPORTANT RIGHTS
You have the right on grounds relating to your situation, at any time to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. We will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defence of legal claims.
You have the right to object at any time to processing your personal data for marketing activities. In such a case we must stop processing for this purpose.
WHAT ARE YOUR OTHER LEGAL RIGHTS?
In addition to the rights above the additional following rights;
- Where you have given consent, you have the right to withdraw previous consent to processing your personal data at any time;
- You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning your data;
- You have the right to receive data you have provided to us in a structured, commonly used and machine-readable format;
- You have the right to lodge a complain with the regulator (see below).
To exercise any of these rights please contact us (details below)
HOW TO CONTACT OUR DATA PRIVACY OFFICER
You can contact our data protection officer about any data protection or marketing issues by;
- Writing to:
The Data Privacy Officer
GL Integrity Financial Planning Ltd
6 Queen Square, Bristol, BS1 4JE
- Telephone: 0117 457 1660
- Email: andrew.stinchcomb@glfinancial.co.uk
OUR PRINCIPAL AND THE GROUP’S CONTACT DETAILS
You can contact our Principal, The On-Line Partnership Limited or the group company, On-Line Partnership Group Limited by;
- Writing to;
The On-Line Partnership Limited
On-Line House
50-56 North Street
Horsham
West Sussex
RH12 1RRD
- Telephoning: 01403 214200
- Emailing: dpo@inpartnership.net
HOW DO YOU MAKE A COMPLAINT TO THE REGULATOR?
- Writing to;
Information Commissioner’s Office
Wycliffe House
Walter Lane
Wilmslow
Cheshire
SK9 5AF
- Telephoning: 0303 123 1133
- By emailing: casework@ico.org.uk
- By using their website:
https://ico.org.uk/for-organisations/report-a-breach/
COOKIES POLICY
We use a system of classifying the different types of cookies which we use on the Website, or which may be used by third parties through our websites. The classification was developed by the International Chamber of Commerce UK and explains more about which cookies we use, why we use them, and the functionality you will lose if you decide you don’t want to have them on your device.
WHAT IS A COOKIE
Cookies are text files containing small amounts of information which are downloaded to your personal computer, mobile or other device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device.
HOW LONG ARE COOKIES STORED FOR?
Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookies – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience.
You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.
COOKIES USED ON THE WEBSITE
A list of all the cookies used on the Website by category is set out below.
STRICTLY NECESSARY COOKIES
These cookies enable services you have specifically asked for. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website.
PERFORMANCE COOKIES
These cookies collect anonymous information on the pages visited. By using the Website, you agree that we can place these types of cookies on your device.
These cookies collect information about how visitors use the Website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the Website works.
FUNCTIONALITY COOKIES
These cookies remember choices you make to improve your experience. By using the Website, you agree that we can place these types of cookies on your device.
These cookies allow the Website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
THIRD PARTY COOKIES
These cookies allow third parties to track the success of their application or customise the application for you. Because of how cookies work we cannot access these cookies, nor can the third parties access the data in cookies used on our site.
For example, if you choose to ‘share’ content through Twitter or other social networks you might be sent cookies from these websites. We don’t control the setting of these cookies, so please check those websites for more information about their cookies and how to manage them.
