Data Protection

Privacy Notice

Clear Financial Advice (Clear) privacy notice explains how we use any personal information that is collected about its clients.

What information do Clear collect about you?

We collect information about you when you engage with the business for financial planning/ financial advice/mortgage advice/investment management services.  This information will relate to the individuals personal and financial circumstances.  It may also include special categories of personal data such as data about the health, if this is necessary for the provision of the services.

Clear may also collect information when you voluntarily complete client surveys or provide feedback.

Information about connected individuals

Clear may need to gather personal information about your close family members and dependants in order to provide the service to you most effectively.  In such cases it will be the responsibility to ensure that they have the consent of the people concerned to pass their information on.  Clear will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

Why do Clear need to collect and use your personal data?

The primary legal basis that Clear intend to use for the processing of personal data is for the performance of the contract with you.  The information that is collected about you is essential for to be able to carry out the services that is required more effectively. Without collecting your personal data Clear are also to be unable to fulfil the legal and regulatory obligations.

Where special category data is required Clear will obtain your explicit consent in order to collect and process this information.

How will we use the information about you?

Clear will collect information in order to provide you with the services for which you have engaged the business to provide.

Who might we share your information with?

If you agree, Clear may email you about other products or services that we think may be of interest to you.

If you agree, Clear will pass on your personal information to a recognised group of companies so that they may offer you their products and services relevant to your requirements.

Clear won’t share the collected information for marketing purposes with companies outside the relevant group of companies/other companies.

In order to deliver the services to you effectively Clear may send your details to third parties such as those that are engaged for professional compliance, accountancy or legal services as well as product and platform providers that are used to arrange financial products for you.

Where third parties are involved in processing your data Clear will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with written instructions.

Where it’s necessary for your personal data to be forwarded to a third-party Clear will use appropriate security measures to protect your personal data in transit.   To enhance the security of the data during transfer, Clear will provide extra security, such as password protection and/or encryption of data etc.

To fulfil the obligations in respect of prevention of money-laundering and other financial crime Clear may send your details to third party agencies for identity verification purposes.

How long do we keep hold of your information?

During the course of the relationship with you Clear will retain personal data which is necessary to provide services to you. Clear will take all reasonable steps to keep your personal data up to date throughout the relationship.

Clear are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

  • Five years for investment business
  • Three years for mortgage business
  • Indefinitely for pension transfers and opt-out business
  • Three years for insurance business

These are minimum periods, during which Clear have a legal obligation to retain your records.

Clear reserve the right to retain data for longer where there is a belief it’s in their legitimate interests to do so.  In any case, Clear will not keep your personal data for longer than the specific years indicated after the relationship with you has ended.

You have the right to request deletion of the personal data.  Clear will comply with this request, subject to the restrictions of regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that Clear hold about you. If you’d like a copy of some or all of your personal information please email or write to Clear using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

Clear have an obligation to ensure that your personal information is accurate and up to date.  Please ask Clear to correct or remove any information that you think is incorrect.

Marketing  

Clear may like to send you information about the products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop Clear from contacting you for marketing purposes or giving your information to other members of the group.  If you no longer wish to be contacted for marketing purposes, please contact Clear by email or post.

Other websites

Clear’s website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

Individuals also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 (local rate)

Changes to our privacy policy

Clear keep the privacy policy under regular review and inform you of any changes when they occur.  This privacy policy was last updated on 2nd April 2018

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you: by email at info@clearfinancialadvice.co.uk