Privacy Policy
This is an important document and should be read carefully. Financial Management Services is the trading name of FMS Sevenoaks LLP. FMS Sevenoaks LLP is registered with the Information Commissioner’s Office (ICO) under registration reference Z9799171.
How we use your information
This privacy notice tells you what to expect when FMS Sevenoaks LLP collects personal information. It applies to information we collect about you. To enable us to provide the services we have agreed and for other related purposes – including updating and enhancing customer records, analysis for management purposes and statutory returns, crime prevention and legal & regulatory compliance – we may obtain, use, process and disclose personal data about you.
We may collect and process the following data about you:
- Information that you provide by filling in forms on our website www.fms-sevenoaks.co.uk
- Information that you provide to us by telephone, e-mail or face to face
- If you contact us, we may keep a copy of that correspondence
Visitors to our website
If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it. We do not use cookies (small text files that are placed on your computer by websites that you visit).
Security and performance
FMS Sevenoaks LLP uses a third-party service to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to the website.
People who email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who use our services
FMS Sevenoaks LLP provides a range of Financial Services to our clients (data subjects). We process data provided by the data subjects and other sources in order to deliver the appropriate products and services to data subjects.
We have to hold the details of the people who have requested the service in order to provide it. The lawful basis for holding your data will be under the consent of the data subject and under the performance of, or entry into, a contract in providing the service. However, we only use these details to provide the service the person has requested and for other closely related purposes. For example, we might use information about people who have requested a financial review to carry out a survey to find out if they are happy with the level of service they received. When people do subscribe to our services they can cancel their subscription at any time and are given an easy way of doing this.
Connected persons
FMS Sevenoaks LLP will process data provided by you in relation to connected persons such as family members or your beneficiaries under a will, trust or pension arrangement. It is your responsibility to obtain express consent from connected persons for you to provide personal information to us to carry out our duties as your financial adviser.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. We usually have to disclose details of the complaint to our Professional Indemnity Insurance Broker and Insurer. We may be required to provide a copy of our file to the Financial Ombudsman Service should an adjudicator be required to consider the complaint case. We are required to disclose to the Financial Conduct Authority (FCA) high level analytics concerning the number and nature of complaints received. This data does not include names or details that identify the specific data subject.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for six years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Use of data processors
Data processors are third parties who provide elements of our service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. Our Data processors / Third parties that we use include:
- Banking arrangements: Barclays Bank Plc and Bank of Scotland Plc
- Regulatory and Compliance opinion where required: Millen Compliance Ltd
- Sanctions and PEPs checking (Anti Money laundering): Callcredit Ltd
- Accountancy and Audit requirements: Wells Associates LLP
- Back Office Systems and Research Software Tools: Synaptic Software Ltd
- Cloud Computing and Data Storage & Back-Ups: Brookland Computer Services Ltd
- Scanning and Document Image Handling: Reckon Software Ltd
- Administration and Client Support Services: FMS South Park Ltd
Your rights
Under the Data Protection Act 1998, you have rights as an individual which you can exercise in relation to the information we hold about you. From 25 May 2018 the General Data Protection Regulations (GDPR) come into force. If you are unhappy with the data processing or data policy of FMS Sevenoaks LLP you have the right to complain to the Information Commissioner’s Office (ICO). Their website address is www.ico.org.uk and their helpline number is 0303 1231113.
Access to personal information (Portability)
Data subjects may submit a Subject Access Request – in order to obtain a copy of the personal data that we hold about them in a structured and portable manner. All SAR requests should be sent to: Simon Billing, FMS Sevenoaks LLP, Second Floor, 87-93 High Street, Sevenoaks, Kent, TN13 1LE.
Confirmation of whether, and where, the controller is processing their personal data
FMS Sevenoaks LLP is the Data Controller and a Processor. FMS Sevenoaks LLP undertakes data processing within the EEA.
Use of data outside the EU
Product Providers and Investment Management companies may administer policies and plans you have with them and provide other services from locations in countries outside Europe that do not always have the same standard of Data Protection as the UK. However, they are required to put controls in place to ensure that your information is adequately protected and they undertake to be bound by the obligations under the Data Protection Act even when your personal information is processed outside Europe.
Right of Data subjects to erasure (Right to be forgotten)
Data subjects may notify FMS Sevenoaks LLP if they wish to exercise their right to erasure. Such a withdrawal of Consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data subjects that exercise this right will be removed from any marketing or future contact. FMS Sevenoaks LLP may retain a copy of any personal data and be retained by the Controller if the processing is necessary for the establishment, exercise or defence of legal claims.
Right of rectification
FMS Sevenoaks LLP will seek to ensure that inaccurate or incomplete data will be rectified. Data subjects have the right of rectification.
Right to object to processing for the purposes of Direct Marketing
Data subjects may notify FMS Sevenoaks LLP if they wish to exercise their right to be removed from any Direct Marketing activities. FMS Sevenoaks LLP may still contact the data subject in order to fulfil any contractual obligations concerning the policies and services provided.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
Sharing Information with Third Parties
We may share your information with third party service providers such as product and insurance providers, investment managers, compliance, and other agents relevant to the business activity.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated in May 2018.
How to contact us
If you want to request information about our Privacy Policy, you can email us or write to:
FMS Sevenoaks LLP, Second Floor, 87-93 High Street, Sevenoaks, Kent. TN13 1LE
WITHDRAWAL OF CONSENT
If at any time you wish us – or any company associated with us – to cease obtaining, using, processing and disclosing personal data about you (including contacting you for marketing purposes), please contact us to withdraw your consent in writing to Mr Simon Billing, Data Protection Officer, FMS Sevenoaks LLP, Second Floor, 87-93 High Street, Sevenoaks, Kent. TN13 1LE or by phone on 01732 227700.
Subject to certain exceptions, you are entitled to have access to your personal data held by us.
