Carpenter Box Financial Advisers takes the protection of your privacy very seriously. We will only use your personal information to deliver the services you have requested from us, and to meet our legal responsibilities.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
How do we collect information from you?
We may collect our personal information from a variety of sources, including:
- Information that we collect from you directly when you contact one of our local offices;
- Information that you provide by filling in the on-line enquiry form on our site www.carpenterboxfa.com (our site);
- Information that we collect about you from other commercially available sources (such as credit reference agencies);
What type of information do we collect from you?
The personal information we collect from you will vary depending on which services you engage us to deliver. The personal information we collect might include your name, address, telephone number, email address, your Unique Tax Reference (UTR) number, your National Insurance number, bank account details, your IP address, which pages you may have visited on our website and when you accessed them.
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. Upon request, we’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
How is your information used?
In general terms, and depending on which services you engage us to deliver, as part of providing our agreed services we may use your information to:
- contact you by post, email or telephone
- verify your identity where this is required
- understand your needs and how they may be met
- maintain our records in accordance with applicable legal and regulatory obligations
- process financial transactions to you or your employees, if you use our payroll service
- prevent and detect crime, fraud or corruption
We are required by legislation, other regulatory requirements and our insurers to retain your data where we have ceased to act for you. The period of retention required varies with the applicable legislation but is typically six years.
To ensure compliance with all such requirements it is the policy of the firm to retain all data for a period of seven years from the end of the period concerned.
In some cases, data will be retained for significantly longer periods for instance, where there is an ongoing trust or there has been a financial transaction such as an investment or disposal that may later need to be referred back to.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 7 years after our relationship with you has ended.
Who has access to your information?
- We will not sell or rent your information to third parties.
- We will not ordinarily share your information with third parties for marketing purposes or where we do so, which will be limited to events held jointly with trusted third parties, we will make it clear before sign-up where there is such an intention.
- With respect to sector specific events where networking is a key component, you will be given the choice as to whether your name and contact data is shared with the other attendees. You may choose not to share your contact data on sign up; this will not preclude you from attending.
- Any staff with access to your information have a duty of confidentiality under the ethical standards that this firm is required to follow.
Third Party Service Providers working on our behalf
We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf, for example to process payroll or basic bookkeeping.
However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes. Third parties may be in the EU or elsewhere in the world but in each case, the duty of confidentiality incumbent upon them will be the same.
Please be assured that we will not release your information to third parties unless you have requested that we do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention and detection of crime, fraud or corruption.
Personal Finance Portal (PFP) – online banking
|Categories of personal data||All personal data processed through the PFP, as well as information collected from payment service providers.|
|Purposes of processing||For the provision of the PFP open banking service, which is an account information service. An account information service is an online service which provides consolidated information on payment accounts held by a client with payment service providers (such as banks).|
|Recipients of personal data||Intelliflo Limited and its service providers.|
|Transfers of personal data outside of the EU||None|
|Automated decision making||The PFP open banking service does not utilise personal data to make automated decisions.|
How you can access and update your information
Keeping your information up to date and accurate is important to us. We commit to regularly review and correct where necessary, the information that we hold about you. If any of your information changes, please email or write to us, or call us using the ‘Contact information’ noted below.
You have the right to ask for a copy of the information which Carpenter Box Financial Advisers holds about you.
Our site contains links to third party websites and social media (such as LinkedIn and Twitter). If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Communicating service related information: We may occasionally contact you by post, email or telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please let us know by contacting us as indicated under ‘Contact information’ below.
General and sector specific newsletters: We offer a monthly e-newsletter and other sector and service specific newsletters. At the outset we will seek your permission to subscribe you this service. You can subsequently unsubscribe at any time from within such newsletters or emailing firstname.lastname@example.org.
Access to your information: You have the right to request a copy of the personal information about you that we hold.
Correcting your information: We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information: You have the right to ask us to delete personal information about you where:
- you consider that we no longer require the information for the purposes for which it was obtained;
- you have validly objected to our use of your personal information (see ‘Objecting to how we may use your information’ below);
- our use of your personal information is contrary to law or our other legal obligations;
- we are using your information with your consent and you have withdrawn your consent (see ‘Withdrawing consent to use your information’ below).
Restricting how we may use your information: In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information.
The right might also apply where there is no longer a basis for using your personal information but you do not want us to delete the data. Where this right is validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Objecting to how we may use your information: Where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Withdrawing consent to use your information: Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in ‘Contact information’ below if you wish to exercise any of these rights.
For more information on GDPR and your rights please see:
Changes to our privacy notice
We keep this privacy notice under regular review and will place any updates on our website. Paper copies of the privacy notice may also be obtained from The Compliance Manager, Carpenter Box Financial Advisers, Amelia House, Crescent Road, Worthing BN11 1RL.
The Compliance Manager, Carpenter Box Financial Advisers, Amelia House, Crescent Road, Worthing BN11 1RL.
We seek to resolve directly all complaints about how we handle your personal information, but you also have the right to lodge a complaint with the Information Commissioner’s Office.
Information Commissioner’s Office
Telephone: 0303 123 1113 (local rate) or 01625 545 745
Please note that you may withdraw this consent at any time by notifying us at our main business address.
We may also engage the services of third party providers of professional services in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of their contract with us. If you wish to know the names of these third parties please contact us for further information.
Appendix 1 – Protecting your personal information
- To provide our services properly we will need to collect information about your personal and financial circumstances. We take your privacy seriously and will only use your personal information to deliver our services.
- Processing of your personal data is necessary for the performance of our contract for services with you and in meeting our obligations to prevent money laundering or terrorist financing. Generally this is the lawful basis on which we intend to rely for the processing of your data. (Please see the reference to special categories of data below). Our policy is to gather and process only that personal data which is necessary for us to conduct our services appropriately with you and to prevent money laundering or terrorist financing.
- We adopt a transparent approach to the processing of your personal data. Sometimes, we may need to pass your personal information to other organisations. If you apply to take out a financial product or service we will need to pass certain personal details to the product or service provider.
- We may engage the services of third party providers of professional services such as an introduction to a mortgage broker in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of their contract with us. Your personal information may be transferred electronically (e.g. by email or over the internet) and we, or any relevant third party, such as Carpenter Box Accountants may contact you in future by what we believe to be the most appropriate means of communication at the time (e.g. telephone/email /letter etc.).
- The organisations to whom we may pass your details also have their own obligations to deal with your personal information appropriately. Sometimes a product or service may be administered from a country outside Europe. If this is the case, the firm must put a contract in place to ensure that your information is adequately protected.
- Our privacy notice can be found here and explains how we process personal data in respect of the various services that we provide. A copy will be provided to you with our Terms of Business.
- As part of this agreement we will ask you to consent to the transfer of personal information in accordance with the protections outlined above.
Special categories of personal data:
- There are certain categories of personal data that are sensitive by nature. The categories include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health. Depending on the nature of the products and services that you engage us for we may need to obtain some sensitive personal data, particularly in relation to health. Our policy is that, should we require any special category of personal data, we will only gather this with your explicit consent.
- If you are concerned about any aspect of our privacy arrangements please speak to us.