privacy policy.

Our policy when it comes to your data.

As part of your relationship with us, we will ask you to provide us with lots of useful information about your circumstances to allow Gratitude Financial Planning to provide the best, most personal advice to you and your family.

This means as a client of Gratitude Financial Planning we will hold your ‘Personal Data’ - a responsibility we take very seriously. This document allows us to explain to you how we will use your Personal Data to deliver our great service as well as the rights you have in relation to your data.

What do we mean by ‘Personal Data’?

Your Personal Data means any information that describes or relates to your personal circumstances.

In the context of providing our advice and support regarding your money and financial plans your Personal Data may include:

Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
Bank details, tax information, pre-existing loans, pension, investment, and insurance information
Sources of income and expenditure, including employment or business information
Family circumstances, details of dependents and health

We will collect the vast majority of this information directly from you, either during our meetings or via documents and emails. We may also obtain necessary information from the public domain and perform electronic ID checks as required.

When we will use your Personal Data

Your Personal Data will be used for the following:

To provide you will personal advice and recommendations with regard to your money.
To arrange and manage your recommended or existing investments, pensions and insurance products on your behalf where possible.
In event that our relationship sadly ends, we have the right to use your personal data provided we have a legitimate business interest to do so, and your rights are not affected. (E.g. respond to your pension provider for you or contact you for feedback in order to improve our service).
To meet our contractual and legal obligations to the Financial Conduct Authority or compliance provider.

When we will process certain parts of Your Personal Data

When it comes to providing you with a financial plan or recommending the most suitable insurance or investments for you we may also ask for more ‘Sensitive’ or ‘Special Data’ in order to provide you will the best service.

This may include details such as your ethnic origin, health and medical history for you and your minor dependents. 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”).

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. Holding such information is important to ensure we provide the service and products you require.

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.

What happens to Your Personal Data when it is disclosed to us?

While handling Your Personal Data, we will:

Record and store Your Personal Data our computer systems and on rare occasions in paper files. 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 pension, investment and insurance providers as required in paper form or online via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application we make on your behalf.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to any recommendations or plans made, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

Recommended and existing Pension, Investment and Insurance providers.
Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs and allow us to provide the best service to you.

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress with any advice or recommendation and to provide you with our financial planning service.

Please be assured that this sharing of Your Personal Data does not entitle 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.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area or indeed outside of the UK.

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.

Likewise, we would expect you to also 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 form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data

You can:

request copies of Your Personal Data that is under our control
ask us to further explain how we use Your Personal Data
ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
ask us to send an electronic copy of Your Personal Data to another organisation should you wish
change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to make contact with Gratitude Financial Planning in relation to the use of your Personal Data

If you have any questions or comments about this document or wish to exercise any of the above rights, please contact Freddie Winter.

If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.