Introduction

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We need to collect and use some of your personal information so we can give you financial advice and manage the services you receive from us. We follow the UK GDPR and the Data (Consent and Use) Act 2025, which set out how we must protect your data and what your rights are.

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Why We Need Your Information

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We use your information so that we can:

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• Provide financial planning and advice tailored to your needs

• Meet rules set by the Financial Conduct Authority (FCA), including keeping proper records

• Respond to legal or regulatory requests, such as preventing fraud or financial crime

• Run our business properly, for example, checking your products remain suitable, meeting anti-money-laundering obligations, and dealing with complaints​

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Lawful Basis for Processing Personal Data

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Under UK GDPR, we must have a lawful basis for using your personal information. The purposes for which we use your information, and the lawful basis for each, are set out below:

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• Providing financial planning services and advice, including reviewing suitability and keeping your plan or portfolio up to date – Lawful basis: Contract

• Meeting FCA and other legal or regulatory requirements, including identity verification, anti-money laundering checks, audits and record keeping – Lawful basis: Legal Obligation

• Responding to lawful requests from regulators, courts or law enforcement, and helping prevent fraud and financial crime – Lawful basis: Legal Obligation and/or Legitimate Interests

• Running and managing our business, including quality assurance, complaint handling, record keeping and business continuity – Lawful basis: Legitimate Interests and/or Legal Obligation

• Sending marketing communications where you have agreed to receive them – Lawful basis: Consent​

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Where we rely on your consent, you may withdraw that consent at any time. This will not affect any processing carried out before consent was withdrawn, but it may limit the services we can provide where the information is required to deliver those services.

 

Your Data and Your Rights

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When we collect your information, we will always be able to tell you:

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• Who the data controller is (this may be us or a third-party provider)

• How to contact our Data Protection Officer

• Why we are using your information and the legal basis for doing so

• Who we may share your data with

• How long we will keep your data

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Under UK GDPR, you have the right to:

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• Access the personal information we hold about you

• Ask us to correct inaccurate personal information

• Ask us to delete your personal information in certain circumstances

• Ask us to restrict how we use your personal information in certain circumstances

• Object to how we use your personal information in certain circumstances, including direct marketing

• Withdraw consent at any time where we rely on consent

• Receive your information in a portable format where applicable

• Object to certain automated decisions, including profiling, and request information about how those decisions are made

• Claim compensation if you suffer harm because data protection law has been breached

 

We will normally respond to requests within one month. There will be no charge unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to respond.

 

Please note that some personal information is required for us to provide our services and meet legal and regulatory obligations. If you choose not to provide information that is required, we may be unable to act for you, progress your instructions, obtain products or quotations on your behalf, or continue providing certain services.

 

What Personal Data We Collect

 

We may collect and use the following categories of personal data:

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• Identity and contact information, including name, address, email address, telephone number and date of birth

• Financial and employment information, including income, expenditure, assets, liabilities and tax position

• Client profile information, including risk profile, capacity for loss and financial objectives

• Product and policy information, including pensions, investments, protection products and insurance arrangements

• Regulatory and due diligence information, including identity verification and anti-money laundering checks

• Records of meetings, correspondence, recommendations, suitability assessments and other advice documentation

 

How We Obtain Your Information

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We collect personal data directly from you through meetings, telephone calls, emails, application forms, questionnaires and online portals.

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We may also receive personal data from third parties where necessary to provide our services, including product providers, investment platforms, employers (where relevant), professional advisers, credit reference agencies, fraud prevention agencies and publicly available sources such as Companies House.

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Sensitive Information

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Sometimes we need to collect special category personal data. This may include information about your health, ethnic origin, or criminal convictions and offences where relevant to the services you have requested.

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In particular, where we provide advice on protection, annuity or similar products, we may need health information and information relating to criminal convictions or offences in order to obtain quotations or terms on your behalf.

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We will only process special category data where we have your explicit consent or where another lawful condition applies under data protection legislation, such as establishing, exercising or defending legal claims. We will always handle this information with additional safeguards and care.

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Sharing Your Information

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To provide our services and operate our business, we may share your information with trusted third parties including:

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• Compliance consultants and regulatory support providers

• IT, cyber security and cloud service providers

• AI and technology service providers

• Paraplanning and administrative support providers

• Auditors and professional advisers

• Product providers and investment platforms

• Other service providers supporting our regulated activities

 

Some organisations we share your information with may act as independent data controllers and will provide their own privacy information explaining how they use your personal data.

 

How Long We Keep Your Information

 

We regularly review the information we hold to ensure it remains accurate, relevant and necessary. During these reviews we may update inaccurate information, archive records that are no longer actively required, securely delete information that is no longer needed, and retain information where required by law, regulation or legitimate business purposes.

 

We keep information only for as long as we need to. This includes:

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• Agreements with you: 6 years after the agreement ends

• Investment records: while you are a client and at least 6 years afterwards

• FCA-required records: normally 6 years, but indefinitely for certain pension-related business

• HMRC-related data: 7 years or longer if they consider a period "open"

• Legal proceedings: 6 years after proceedings end

• In general, no personal data is kept for more than 50 years

 

Archiving Information

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Where information is no longer actively required but must still be retained for legal, regulatory or business reasons, it may be archived and processed only in limited circumstances. Both active and archived information are stored in accordance with appropriate organisational and security controls.

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AI Tools and Third-Party Processing

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We may use AI-enabled tools and third-party technology providers to support the delivery of our services and business operations.

 

Personal data processed through these systems may be stored and processed within the UK, the EEA, or other jurisdictions where our service providers operate. Where personal data is transferred outside the UK, we will ensure that appropriate safeguards are in place in accordance with applicable data protection legislation.

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You have the same rights in relation to personal data processed through AI systems as you do for any other personal data we hold.

 

Data Portability

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Where applicable, you may request a copy of the personal data you have provided to us in a structured, commonly used and machine-readable format. You may also request that we transfer that information directly to another data controller where technically feasible.

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We may retain copies of information where we are legally entitled or required to do so.

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Potential Business Transfers

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In the event that our business is involved in a merger, acquisition, sale of assets, restructuring or similar transaction, your personal data may form part of the transferred assets.

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Any such transfer will be carried out in accordance with applicable data protection legislation. The receiving organisation will continue to process your personal data in accordance with this Privacy Policy, or an updated privacy notice provided at the relevant time.

Where appropriate, we will notify you of any such transfer and any material changes to how your personal data will be processed.

 

Marketing

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We will only use your personal information for marketing purposes where you have given your consent. You may withdraw that consent at any time. Your marketing preferences do not affect how we use your personal information for the purposes of providing our services or meeting our legal and regulatory obligations.

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Your Contact Options

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Please contact the Data Protection Officer at our company address, or by telephone or email, if you wish to:

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• Access your data

• Correct or delete data

• Ask questions about how your data is used

 

You also have the right to complain in regard to any aspect of the processing of your data and any breach of the above rights to the relevant supervisory authority, who in the case of the UK is the Information Commissioner's Office, whom may be contacted at:

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• Online: www.ico.org.uk

• Phone: 0303 123 1113