Privacy & security

This Privacy Notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you. Please ensure that you read this notice and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

Who collects the information?

Pallant Independent Limited (‘Company’) is a ‘data controller’ and gathers and uses certain information about you. This information is also used by our group company Thesis Asset Management Limited (‘Thesis’), where you have appointed Thesis as your investment manager.

What information do we collect about you?

We collect your name, signature, residential address, telephone number (home, work and mobile), email address (home and work), date of birth, anticipated retirement age, National Insurance Number, marital status, whether you are a smoker, state of health, country of birth, country of residence and domicile, employment status, occupation, employer name, whether you have a power of attorney, the name of your financial dependents, relationship to you and their date of birth, when you expect them to become financially independent, how much it costs you to provide for them each year, details of your income and expenditure, assets and liabilities, deposits and investments, pension arrangements, protection arrangements details of your will and any gifts made, planned capital or income outgoings, your investment objective and priorities, whether you have strong moral views on where money should be invested and any specific financial planning requirements you have.

From 25 May 2018, information on your current or previous physical, mental or medical condition, health status, injury or disability information, medical diagnosis, medical procedures performed and treatment given, personal habits (for example, smoking or consumption of alcohol), prescription information, and medical history will only be collected if you have provided us with explicit consent to process it. We will need such sensitive personal data to be able to provide you with a suitability report when we make a personal recommendation on certain investments.

How do we collect the information about you?

We may collect this information from you when you complete our Personal Factfind, Pension Option Questionnaire, Risk Questionnaire available on our website and from our advisers, when you attend our marketing events, during meetings with you or when you email us. Website usage information is collected using cookies.

How will we use information about you?

We will typically collect and use this information for the following purposes:

  • To verify your identity
  • To onboard you as a client;
  • To provide our products and services to you;
  • To manage and administer our services;
  • To contact you in connection with any enquiries you make;
  • To assist us in identifying issues with our website and users’ experience of it and to monitor the way our website is used;

We will not share your information for marketing purposes with other organisations.

Why do we use information about you?

We collect and use your information for a variety of reasons. We need some information to enter into and perform our contact with you and provide you with the products or services you have requested.

We need to collect certain types of information for compliance with regulatory requirements. If this information is not provided we cannot agree to provide a product or service for you.

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are resolved.

How may we share the information?

We may also need to share some of the above categories of personal information with other parties, such as external contractors, for example for customer relationship management services, our professional advisers and with potential purchasers of some or all of our business or on a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal information with our regulator or as required to comply with the law. We may also share information about you with other members of our group of companies so we can provide the best service across our group.

Recipients with whom we share your personal data as a client and the purposes for such sharing include are set out in the list attached. This will be updated and available from our website at www.pallantindependent.com. A hard copy can be obtained from the Head of Compliance – please see “How to Contact Us” below for contact details.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Where is information processed?

Personal information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above. Information may be transferred internationally to countries outside the European Economic Area, including countries that do not have data protection laws equivalent to those in the UK, for the reasons described above. We will only transfer personal information to countries outside the European Economic Area where appropriate safeguards as set out in applicable data protection legislation are in place.

How long do we keep your information?

We will only keep your personal information for as long as it is reasonably necessary. In general, however:

  • We will retain personal data we collect for legal and regulatory obligations until six years after the termination of our agreement with you
  • We will retain personal data we require in relation to a legal claim or legal proceedings until the claim is either finally settled or finally determined by a court, meaning no right of appeal is given
  • We will retain personal data we collect pursuant to our legitimate business interests until our legitimate interests cease or your rights and freedoms override them
  • We will retain personal data collected for our records relating to suitability for a minimum of the following periods, provided you proceed with our recommendation:
    • if relating to a pension transfer or pension opt-out, indefinitely;
    • if relating to a life policy, personal pension scheme or stakeholder pension scheme, five years; and
    • in any other case, three years.

What rights do you have?

We have listed the rights you have over your information below. These rights are subject to restrictions in applicable data protection legislation and may only apply to certain types of information or processing. Please contact our Head of Compliance at compliance@thesisam.com if you would like to exercise or discuss any of these rights. You can also write to us at Pallant Independent Limited, Exchange Building, St John’s Street, Chichester, West Sussex, PO19 1UP. We may only charge a reasonable fee for responding to access requests if the request is manifestly unfounded or excessive, especially if it is repetitive, or the request is for further copies of the same information.

  • You can ask us to confirm if we are processing your information.
  • You can ask for access to your information.
  • You can ask us to correct your information if it’s wrong.
  • You have a right to be forgotten and you can ask that our systems stop using your information.
  • You can ask us to restrict how we use your information.
  • You can ask us to help you move your information to other companies.
  • You can ask us to stop using your personal information, but only in certain cases.
  • You can withdraw consent, where you have provided it, at any time.
  • We hope that our Head of Compliance can resolve any query or concern you raise about our use of your information. If not, you are entitled to contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

How do we keep your information secure?

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information 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.

What cookies are used on our website?

Web browser cookies are small text files placed on your computer to store information such as your IP address or other identifier, your browser type, and information about the content you view and interact with on our website. This information is used to remember your preferences and settings, remember information you may enter online, to keep you logged on to portals that we may offer, to generate statistics about how visitors use our website and to improve our website.  Cookies do not give us access to your computer or any information about you, other than the data you choose to share with us.

For more information on the cookies we use and why, please go to www.pallantindependent.com and refer to the Cookie Policy.

You can choose to accept or decline cookies via your browser settings. To find out how to manage and delete cookies, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Opting not to use cookies may prevent you from taking full advantage of the website.

What if you follow a link to other websites?

Our website may contain links to other websites which are outside our control and are not covered by this Privacy Notice. If you access other websites using the links provided on our website, you should read the privacy notices on those websites.

When was this Privacy Notice last updated?

We will keep this Privacy Notice under regular review. Any changes we make to our Privacy Notice will be posted on our website.  If you require a hard copy, please contact our Head of Compliance at Exchange Building, St John’s Street, Chichester, West Sussex PO19 1UP.  This Privacy Notice was last updated with effect from 25 May 2018.

Do you need extra help?

If you would like this notice in another format (including audio, large print and braille), please contact us.

How can you contact us?

If you have any questions about this policy please contact our Head of Compliance at compliance@thesisam.com or write to us at Pallant Independent Limited, Exchange Building, St John’s Street, Chichester, West Sussex, PO19 1UP.

 PALLANT INDEPENDENT LIMITED

 LIST OF PERSONAL DATA RECIPIENTS

These are the recipients to whom we may need to transfer your personal data, and the reasons we may need to provide it. This list is updated as necessary.

Identity of recipient Reason for potential supply
IRESS FS Limited Data feeds to Adviser Office, our previous client relationship management system software provider for the purposes of client administration
Discretionary investment managers, such as 7IM, Brooks Macdonald, Quilter Cheviot, Cornelian and Thesis Asset Management Limited Referring you to them as a client, receiving portfolio information from them and updating them on any changes to your financial circumstances
Intelliflo Limited Data feeds to the provider of our current client relationship management system, Intelligent Office, for the purposes of client administration, which makes us more efficient in providing our services to clients
Voyant UK Limited Provider of software tool for cash flow reports
Assureweb Provider of iPipeline portal, a secure electronic quotation and new business application, enabling us to obtain quotes and transact new business from all the major product providers
Financial Express Limited Provider of an online fund comparison tool, FE Analytics
Your lawyer, accountant or attorney appointed by you To forward information about your investments as requested by you or your attorney, as applicable
HMRC and other tax authorities Tax reporting
GB Group PLC

CallCredit

Regulatory Datacorp Limited

Anti-money laundering checks, global regulatory information database checks
Pension scheme administrators and trustees and investment bond providers and platforms, such as:

·        Abbey Life Assurance Company Limited

·        Adam & Company (business name of The Royal Bank of Scotland plc)

·        Aegon (brand name of Scottish Equitable plc, Aegon Investment Solutions Limited and Aegon Ireland plc)

·        AIG

·        AJ Bell

·        Aon Hewitt

·        Ascentric (trading name of Investment Funds Direct Limited)

·        AXA Group

·        Aviva (including previously Friends Life)

·        Barclays Group

·        BMO Global Asset Management (brand name for various BMO Financial Group entities)

·        BNY Mellon

·        BP Pensions Ltd

·        British Airways Pensions

·        Canada Life Group

·        Cazenove Capital Management (trading name of Schroder & Co. Limited)

·        Charles Stanley Group

·        Clerical Medical (trading name of Scottish Widows Limited)

·        Cofunds (part of the Aegon UK Group)

·        Columbia Threadneedle Investments (band name of the Threadneedle group of companies)

·        Curtis Banks Ltd

·        Downing LLP

·        Department for Work and Pensions

·        Equitable Life (trading name of the Equitable Life Assurance Society)

·        European Parliament Pension Scheme

·        F&C Group

·        Fidelity Group (including FIL Investment Services (UK) Limited and Financial Administration Services Limited)

·        Funds Network (the Fidelity platform)

·        Halifax Share Dealing Limited

·        Hargreaves Lansdown Group

·        HSBC Group

·        Interactive Investor Services Limited

·        Invesco Perpetual Group

·        Investec Wealth & Investment Limited

·        Irwin Mitchell LLP

·        James Hay Partnership

·        Janus Henderson Investors (trading name of Janus Capital International Limited, Henderson Global Investors Limited, Henderson Investment Funds Limited, AlphaGen Capital Limited and Henderson Private Equity Partners Limited)

·        JM Finn & Co. Ltd

·        JP Morgan Asset Management (UK) Limited

·        Jupiter Asset Management Limited

·        Just (trading name of Just Retirement Limited and Just Retirement Money Limited)

·        Key Partnerships (trading name of Key Retirement Solutions Limited)

·        Killick & Co LLP

·        Legal & General Group

·        Liberty Mutual Insurance Europe Limited

·        Liverpool Victoria Friendly Society Limited

·        M&G Investments (trading name for M&G Investment Management Limited)

·        NFU Mutual Group

·        NHS

·        NS&I

·        Octopus Investments Limited (including previously Octopus Asset Management Limited)

·        Old Mutual Wealth Group (including previously Skandia Life Assurance Company Limited)

·        Phoenix Life (including previously NPI and National Provident Life policyholders)

·        Prudential Group

·        Psigma Investment Management Limited

·        ReAssure Limited

·        Reliance Life Limited (including previously Reliance Mutual Insurance Society Limited)

·        The Royal Bank of Scotland Group

·        The Royal London Mutual Insurance Society Limited (trading as Royal London, including previously Scottish Provident Self Assurance and Scottish Provident Pegasus Whole of Life)

·        Sanlam Group

·        St James’ Place Group

·        Santander UK Group

·        Schroder Group

·        Scottish Widows Group

·        Standard Life (trading name of the Standard Life Aberdeen Group)

·        Stocktrade (trading name of Alliance Trust Savings Limited)

·        Suffolk Life Group

·        Sun Life Financial of Canada (trading name of Sun Life Assurance Company of Canada (U.K.) Limited)

·        Teachers’ Pensions

·        Unilever UK Pension Fund Trustees Limited

·        Unum Limited

·        Utmost Wealth Solutions (trading name of Utmost Group including previously AXA Life Europe)

·        Virgin Money Group

·        VitalityLife (trading name of Vitality Corporate Services Limited and Vitality Life Limited)

·        Vitol Pension Scheme

·        Wesleyan (trading name of the Wesleyan Group)

·        Yorkshire Building Society Group

·        Zurich Group

 

In relation to the administration of your self-invested personal pension, small self-administered pension scheme or investment bond, as applicable
Distribution Technology Limited Web-based financial planning tool to create a risk profile and risk report for you to enable us to better advise you
Mimecast Services Limited Cloud-based email management system provided by Mimecast Services Limited for email security, business continuity, mailbox management and document retention purposes
BT Telephonic communication recording
dotmailer Limited External email management company to help us manage and target our email contact more efficiently
GoDaddy Website hosting company, currently GoDaddy. The company has access to the personal data of people who submit their details on our website, for example to subscribe to news updates or register to attend events. This data sharing helps us to manage people’s preferences for how we contact them.
Straightedge Website design company, currently StraightEdge. This company has access to the personal data of people who submit their details on our website, for example to subscribe to news updates or register to attend events. This data sharing helps us to manage people’s preferences for how we contact them
The Financial Conduct Authority For responding to regulatory enquiries and reporting
The Financial Ombudsman Service For responding to client complaints

 

May 2018