This policy applies to information about living identifiable individuals only.
Information gathered from our website
You may choose to provide personal information to us when you register on our website to ask us to contact you. You may be asked to provide information about yourself including (but not necessarily limited to) your name, title, postal address, telephone number and/or email address.
Information gathered to offer financial services
If you contact us and request information or become a client of MFP, we will need to obtain basic information to confirm your preferred means of communication, including your name, title and postal address, together with normal contact details for you and any other parties that will be included in any products or services we provide. The information that we need will be explained to you by your financial adviser and/or set out in our client engagement information, depending on the nature of your enquiry or requirements.
Information gathered automatically
We may also collect information automatically about your access and usage of our website using cookies and other analytical technology. Full details of our data collection methods are included in the ‘Cookie’ section below. We will use your IP address, which is a numeric code that identifies a computer on the internet, to collect internet traffic data and information on your browser type and computer. If you do not wish to receive cookies, you may reject them by amending your browser settings, unless they are required for the delivery of our website or services to visitors.
Information gathered from third parties
Additionally, we may obtain information about you from legitimate third parties, including suppliers, partners or other specialist advisers that are relevant to your enquiry or financial service request.
How does MFP use your information?
We will use your information for the specific purpose(s) for which it has been provided or collected by us, including:
to provide information that you may request regarding the services we offer, including whether we can assist with related financial advice
to contact you to introduce our products and services
to provide our clients with associated products and services including referrals to other financial specialists both in the UK and overseas, where appropriate
to comply with our statutory and regulatory obligations
to verify your identity for financial compliance purposes
to deal with any feedback, queries or complaints that you may have
We may also use the information that we collect about you for marketing and business development purposes, including:
to provide information about MFP and the financial services we provide, which may be of interest to you, by sending you newsletters or business updates
to provide you with updates on relevant areas of our financial services
to contact you about other activities and events that we may undertake
Information gathered by cookies and similar analytical technologies are used to measure and analyse information on visits to our website, to update the website to improve the visitor experience and to improve technical performance. We will not use the data to identify you personally or to make any decisions about you.
Furthermore, we may use your information to administer, support and improve our business generally and to enforce our legal rights.
Legitimate grounds for processing your information
We must have a lawful basis for processing your information. This will vary depending on the circumstances for obtaining your information, but will typically include:
the activities within our legitimate interests as a financial services company seeking to engage with and provide services to prospective and current clients
you have given consent for us to process your information in relation to our marketing activities
we are completing necessary steps in relation to a contract to which you are a party or prior to you entering into a contract with MFP, because you wish to instruct us to carry out financial services activities for you
the processing is necessary for compliance with legal obligations that we are subject to, including confirming your identity under our financial compliance requirements which may require the completion of electronic ID checks
If we legitimately process any special categories of information, which may reveal racial or ethnic origin; political opinions; religious or philosophical beliefs or trade union membership; processing of genetic or biometric data for the purpose of uniquely identifying individuals; health data or data concerning your sex life or sexual orientation, we must have a further lawful basis for the completion of the processing activities, which may include:
where you have given us your explicit consent to do so
where the processing is necessary to protect your vital interests or someone else's vital interests
where you have made the information public
where the processing is necessary for the establishment, exercise or defence of legal claims
where the processing is necessary for reasons of substantial public interest
If you become a client of MFP, we may use your personal information to send you information that we think may be of interest to you. This falls within our legitimate interests as a financial services company to use your information for marketing purposes.
You will be given the opportunity to confirm whether or not you wish to receive direct marketing materials and communications from us, either at the time you provide your details and/or within the marketing communication itself.
At any point, if you change your mind about being contacted by us, or any of your personal details change, or you believe that any information we hold about you is either inaccurate or out-of-date, please contact us by emailing email@example.com or writing to us at Meridian Financial Planning Ltd, 2 White Cliffs Business Centre, Honeywood Road, Whitfield, Dover, Kent, CT16 3EH. Alternatively, you can call us on 01304 820220.
Disclosure of your information
The information you provide to MFP will usually be held on our computers in the UK and accessed by staff working in the UK. Information you provide to us may be transferred to, stored or processed by third party organisations which process data on our behalf. These third parties may store or process your information in the UK or elsewhere, including outside the EEA. These third parties may include suppliers of products and services, administrative and support services, suppliers of other specialist products or outsourced IT applications and systems, including cloud-based platforms.
We may also transfer your information to other organisations or professional advisers with whom we are working on financial services matters or to whom we are referring you for additional or separate financial advice.
Additionally, we may be obliged to disclose information under certain laws, by order of court or other competent regulatory body or may be permitted to disclose it under applicable data protection laws.
Finally, if MFP merges with another business entity, divests part of its business or carries out internal corporate restructuring, your information may be disclosed to MFP’s new business partners or owners or the new corporate entities.
Protection of your information
We have implemented relevant administrative, technical and physical controls for our website, which are designed to mitigate the risk of loss, misuse, unauthorised processing or disclosure of the personal information that we hold. Where we transfer information to third parties to enable them to process it on our behalf, we ensure that these third parties can meet or exceed relevant legal or regulatory requirements for transferring and securing information under their control.
We will also ensure that where information is transferred to a country or international organisation outside of the UK / EEA, we will comply with the relevant legal rules governing such transfers.
We will retain your personal information for no longer than necessary for the purposes that it was collected. Details of our information retention policy is available upon request. Our terms of business include details of how we keep clients’ personal information secure.
You have certain rights in relation to your personal information. However, these rights do not apply in all cases or to all information that we hold about you. In certain circumstances, we may need to continue to hold and process information to establish, exercise or defend our legal rights. Additionally, your rights may not be enforceable until the EU General Data Protection Regulation 2016 (GDPR) comes into force on 25 May 2018.
You have the right to request that we:
Provide you with a copy of the personal information that we hold
Update your personal information where it is incorrect or out-of-date
Delete personal information that we hold
Restrict the way in which we process your information
Consider any valid objections to our processing of your personal information
Provide information you have given to us to a third-party provider of services, where our lawful basis for processing is consent and where processing is automated
We will respond to your request, including providing information on whether the rights apply in the particular circumstances, within the statutory time period. If we are unable to confirm your identity, we may require you to provide further information in order for us complete verification of your identity.
Changes to this policy
We may make changes to this policy from time to time as our business, internal practices or applicable laws change. We will not make any use of your personal information that is inconsistent with the original purposes for which it was obtained or otherwise than is permitted by applicable law. If we intend to use your information for any other purposes, we will notify you in advance, wherever possible.
How to contact us
If you would like to contact us to discuss this policy or how we use your personal information, to exercise your rights, to provide feedback or make a complaint about use of your information, please contact us as follows:
Russell Skues – Director and Data Protection Manager
firstname.lastname@example.org or 01304 820220
Meridian Financial Planning Ltd, 2 White Cliffs Business Centre, Honeywood Road, Whitfield, Dover, Kent, CT16 3EH.
You can also contact the Information Commissioner's Office for information, advice or to make a complaint. The ICO can be contacted online at https://ico.org.uk
Cookies, including browsers or tracking cookies, are small text files that are added to your computer when you visit a website. They help websites to perform certain functions, including knowing who you are if you log into a restricted part of a website and for tracking purposes.
At MFP we use the following cookies:
Google Analytics - We use Google analytics cookies on the website for tracking purposes. The cookies allow us to understand general traffic to our website, including the number of visitors and length of time on the website. This process collects anonymous data to help us develop the website, make improvements and enhance the user experience.
Privacy Preferences - We use a tracking cookie, which is added to your computer to remember your cookie preferences, including whether you have allowed or disallowed them.
Client Services - For areas of our website that are password protected, an essential cookie is added to your computer, which is then automatically deleted after your session has ended.
Shortly after arriving at our website, we will add an 'opt-in' tracking cookie to your computer unless you specify otherwise. If you would like to opt-in or opt-out of using cookies, you can amend this by altering your browser settings. You can review your cookie settings at any time.
If you do opt-out then an opt-out preference cookie will be added to your computer, however if you delete all your cookies or use a different device then you will need to set your cookie preference again. If this is your first visit and you navigate away from this page without specifying your cookies preference then an 'opt-in' tracking cookie with be added to your computer.
Please note that you cannot opt-out of the deployment of cookies that are necessary for delivery of our website or services to visitors.
v1.0 – 16th May 2018