This privacy notice explains how Blue Sky Financial Planning Ltd use any personal information we collect about you whether or not you are a client.
We understand how important personal data is. That is why we keep your data protected and want to be really clear about how and why we are using the information we hold. We also want you to know that you have the right to change how we use your data at any time, and this document will tell you how to do that.
What information do we collect about you if you are a client?
We collect information about you when you engage us for financial planning, financial advice or investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to effectively carry out the services that you require from us. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Who might we share your information with?
We will not share your information for marketing purposes with any other company.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll 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 will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party (as described above) we will use appropriate security measures to protect your personal data in transit such as password protection or encryption as necessary.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
Your personal data will not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us.
You have the right to request deletion of your personal data by writing to us at our office address. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above, within 30 days.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please write to us at our office address.
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.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Automated decision making and profiling
If you use our regulated Automated Advice Service, your personal information will only be gathered through the information that you input onto the system. Your data is collected in order for us to carry out the service for which you engage us.
Marketing Information (applicable to clients and non-clients)
We require your permission to send you ‘Marketing Information’. If you agree to receive such communications, you may update your preferences or stop us contacting you at any time in the future. To do this please follow the link at the bottom of any of our email communications or write to us at our office address.
What can you do if you are unhappy with how your personal data is processed?
You have the 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 us
By email: firstname.lastname@example.org
By writing to us: 7 Vista Place, Coy Pond Business Park, Ingworth Road, Poole, Dorset, BH12 1JY