Please refer to our website footer for details of our firm and how to contact us.
Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information describing or relating to your circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your financial affairs, Your Personal Data may include:
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your financial affairs, we do so because both parties are entering a contract for the supply of services.
To perform that contract and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, in the course of initial discussions with you or when the contract between us has ended for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given you or to contact you to seek feedback on the service you received.
Occasionally, we will use Your Personal data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data to make enquiries of providers in relation to insurance products that may meet your needs and to
provide you with advice/guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to your financial affairs. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
Record and store Your Personal Data in our paper files, mobile devices and on our computer systems for example websites, email, hard drives, and cloud facilities. This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
Submit Your Personal Data to Product Providers and lenders in paper form and on-line via a secure portal. Providing this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to your financial affairs, or to inform you of any developments in relation to those products and/or policies of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
Product Providers / Lenders
Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your enquiry and to provide you with our professional services.
Please note that sharing Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you and as otherwise set out in this Customer Privacy Notice.
Security and Retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password-protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your Rights in Relation to Your Personal Data
If we feel we have a legal right not to deal with your request or to act it differently than you requested, we will inform you of this then.
You should also contact us as soon as possible upon becoming aware of any unauthorised disclosure of Your Personal Data so that we may investigate and fulfil our regulatory obligations.
If you your rights set out within it please contact our firm via the contact details within this website and ask for the person responsible for data protection.sioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Jenny Lomas Financial Advice registered office, 1 Barford Woods, Barford Road, Warwick, CV34 6SZ.
Authorised and regulated by the Financial Conduct Authority. Jenny Lomas Financial Advice is entered on the Financial Services Register https://register.fca.org.uk/ under reference 842769
If you wish to register a complaint, please write to firstname.lastname@example.org or telephone 01926 401189
A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request. If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service at www.financial-ombudsman.org.uk or by contacting them at 0800 0234 567.