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Privacy Notice (private clients)

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

Eastwood Financial Services Ltd collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation (applicable data privacy and protection laws) and we are responsible as a data controller of that personal data for the purposes of those laws. 

Data controller means a natural or legal person (such as a company) which determines the means and purposes of processing personal data.  We are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected and the purposes for which it will be used in the course of us providing you with our services.

When we mention "EFS", "we", "us" or "our" we are referring to Eastwood Financial Services Ltd.

We area company registered in England and Wales (company number 3649630) whose registered office is at Northumberland House, Northumberland Street, Huddersfield, HD1 1DT.

Eastwood Financial Services Ltd is authorised and regulated by the Financial Conduct Authority. Our Financial Services Register number is 188860.

We provide independent financial advice to clients on an initial, ongoing and transactional basis.  The way in which we work with you is detailed and confirmed within our ‘Information about our Services & Costs’ document and our ‘Services & Payment Agreement’. 

The personal data we collect and use

In the course of providing our services to you we may collect the following personal data when you provide it to us: 

  • Your contact details (personal and at work, where necessary)
  • Your date of birth, National Insurance Number, nationality, place of birth, country of residence and country of domicile
  • Details of your spouse, children, dependants and/or beneficiaries under a policy (please see the additional notes on the next page) **
  • Details of your employment status (current/historical) and income
  • Your income and expenditure together with details on income tax and other taxation matters
  • Details of your assets and liabilities
  • Details of any financial products, policies or planning that you may already have in place
  • Details of mortgages and other lending/debts
  • Health & medical information
  • Lifestyle information
  • Details of any wills, powers of attorney or any other relevant legal arrangements you have made
  • Details of any other professional advisers that you may have
  • Your bank account details
  • Identity information i.e. passport, driving licence, utility bills
  • Copy birth, marriage and death certificates
  • Details of any vulnerability

Should you require further information or clarification on any of the above, please contact us.  Our contact details are provided later in this notice.

**  Please Note:  if you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please ask them to contact us in one of the ways described later in this privacy notice.

Information collected from other sources

We may also obtain personal data from other sources in the course of providing our services to you. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.

The personal data we obtain from other sources may include details from product providers on policies/products that you already hold with them or from identification and verification checking agencies i.e. Her Majesty’s Treasury financial sanctions list.  We may also request information from any other professional advisers that you may have, i.e. your solicitor or accountant.

How we use your personal data

We will only use your personal data when the law allows us to.  Most commonly, we will only use your personal data in the following circumstances:

 Where we need to perform the contract we have entered into with you;

  1. Where we need to comply with a legal obligation;
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

 We may also use your personal data in the following situations, which are likely to be rare:

  1. Where we need to protect your interests (or someone else’s interests):
  2. Where it is needed in the public interest (or for official purposes)

Special category data 

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Although we would not typically hold data relating to criminal convictions or offences, this is also subject to additional levels of protection.

We may process health information and lifestyle information when providing our services in relation to a protection insurance product, a private medical insurance policy and/or any other products or areas of advice to which this information may be relevant i.e. annuities.

We will process this information either (i) for the purpose of advising on, arranging or administering a contract or (ii) for the establishment, exercise or defence of legal claims.

In the course of our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information (outlined earlier), we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.

Marketing

We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.

In addition, where you have provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.

You can opt out of receiving marketing communications at any time. If you wish to amend your marketing preferences please contact us:

By phone:        01422 377737

By email:        office@eastwoodfinancial.co.uk

By post:           Pennine House, Lowfields Close, Lowfields Business Park, Elland, HX5 9DA

Whether information has to be provided by you, and if so why

We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with our services.

How long your personal data will be kept

We will hold your personal data for differing periods of time depending upon the reason we have for processing it but will only retain this for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements. 

In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such further information without further notice to you.

Transfer of your information out of the European Economic Area (EEA)

We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your rights

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

  • To access personal data
  • To correct / erase personal data
  • To restrict how we use personal data
  • To object to how we use personal data
  • To ask us to transfer personal data to another organisation
  • To object to automated decisions
  • To find out more about how we use personal data

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive.  Where a fee is necessary, we will inform you before proceeding with your request. 

We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests.  We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about. 

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data

You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims. 

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances, for example

  • where you think the information is inaccurate and we need to verify it;
  • where our use of your personal data is not lawful but you do not want us to erase it;
  • where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
  • where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

To object to use of personal data

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).

You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means. 

To contest decisions based on automatic decision making  

If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.

You can contact us for more information

If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.

If you would like to exercise any of the above rights, please:

  • email or write to Karen Wynard, our Managing Director at karen@eastwoodfinancial.co.ukor Eastwood Financial Services Ltd, Pennine House, Lowfields Close, Lowfields Business Park, Elland, HX5 9DA;
  • let us have enough information to identify you, e.g. name, address, date of birth;
  • let us have proof of your identity and address (your driving licence or passport and a recent utility or credit card bill); and
  • let us know the information to which your request relates

Keeping your personal data secure

We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).

We ask that you please attempt to resolve any issues with us before the ICO.

How to contact us

Please contact Karen Wynard, our Managing Director if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact Karen Wynard, please get in touch using the contact details provided earlier in this notice.