Data Protection and Privacy Notice
Clear Financial Advice privacy notice explains how they use any personal information that is collected about its clients.
What information do Clear collect about clients?
Clear will abide by the GDPR. Clear 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 the individual voluntarily complete client surveys or provide feedback.
Information relating to usage of Clear’s website is collected using cookies. These are text files placed on the computer to collect standard internet log information and visitor behaviour information. Clear will use the information collected from the website to personalise repeat visits to the site
EU GDPR Notice
The EU General Data Protection Regulation (GDPR) is a first step toward giving EU citizens and residents more control over how data is used by organisations. Companies handling personal information of people in the EU, must comply with the GDPR, no matter where your business is in the world. Clear will abide by the GDPR. At the end of the transitionary period EU GDPR was converted to UK GDPR, for clients based in the EU, Clear will continue to abide with EU GDPR.
Information about connected individuals
Clear may need to gather personal information about the client’s close family members and dependants in order to provide the service to the customer most effectively. In such cases it will be the clients 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 the client 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 Clear to provide the most effective services. Without collecting your personal data Clear are also to be unable to fulfil their 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 Clear use the information about its clients?
Clear will collect information in order to provide the client with the services for which they have engaged the business to provide.
Who might Clear share your information with?
If you agree, Clear may email individuals 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 Clear 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.
Individuals 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 Clear 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.
Automated decision making and profiling
If you use Clear’s service with your personal information it could be gathered through the information that you input onto the system. Your data is collected in order for Clear to carry out the service for which they have been engaged for. If you’re unsure about the outcome of the automated process you can contact Clear to discuss or to challenge the outcome.
Clear take measures to ensure the security of your data (limited access and only on two terminals). Clear don’t use any special category data (such as data about your health) in the automated process unless it’s strictly necessary to deliver the service and have obtained your explicit consent to do so.
Clear regularly check the systems for accuracy and bias and feed any changes back into the design process.
Clear like to send you information about the products and services and those of other companies in the relevant groups 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.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of the website features may not function as a result.
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
0303 123 1113 (local rate)
How to contact Clear Financial Advice
Or write to us at ……Suite J, First Floor, Castle House, Park Road, Banstead, Surrey, SM7 3BT