Financial Advice Network Limited Privacy Notice

1) Welcome to our Privacy Notice

We recommend that you read through our Privacy Notice, because it’s really important that you understand how we use, process and store your personal information.

We respect your right to privacy and will only process personal information you provide to us in accordance with the EU General Data Protection Regulation (GDPR) which is the EU regulation surrounding data protection which became applicable in May 2016, the Privacy and Electronic Communications (EC Directive) Regulations 2003 which is to be replaced by the ePrivacy regulation which is expected to become applicable in May 2018, and other applicable privacy laws.

Financial Advice Network (‘we’, ‘us’) is committed to protecting and respecting your rights. This Privacy Notice (‘notice’) explains how we collect, store and use personal information provided to us by our Appointed Representatives (‘ARs’). Our Privacy Notice will provide you with details about:

  • The types of personal information we collect from you;
  • How we use it;
  • Who is Financial Advice Network?

2) Who is Financial Advice Network?

  • Financial Advice Network Ltd is a wholly owned subsidiary of The Shepherds Friendly Society Limited, which is an incorporated Friendly Society under the 1992 Friendly Societies Act No. 240F.
  • Financial Advice Network is a Registered Limited Company in England and Wales No. 5378813
  • We are regulated by the Financial Conduct Authority.
  • Our FS Registration number is 430769 and our registered office is at Haw Bank House, High Street, Cheadle, Cheshire, SK8 1AL.
  • We are registered as a data controller with the Information Commissioners Office (registration number Z9065581). Please note, as of 25 May 2018 registration requirements are due to cease. Being registered as a data controller means that we decide how and why personal information is processed.

3) Data controller

For the purposes of Data Protection laws, Financial Advice Network is the Data Controller of personal information covered by this Notice. You may contact us about all issues related to this Privacy Notice, your personal information and to exercise your rights under Data Protection laws.

Contact Details of the Controller:

Post: Financial Advice Network Ltd, Haw Bank House, High Street, Cheadle, Cheshire. SK8 1AL
Email: info@financialadvice-network.co.uk
Telephone: 0161 495 6446

4) When do we collect personal information?

We collect and process personal information about you, in order to fulfil our role as the principal firm for the Network and to provide Compliance services to our ARs

Any personal information you supply will be held securely, in accordance with data protection rules; this allows us to effectively manage your relationship with us. If you choose not to provide the information required you may not be able to be an AR of the Network.

5) Where do we collect your data?

5.1) Visiting and using our website:

To use our website, you do not have to provide us with personal information. Personal information is only collected should you complete the ‘Join Us’ submission form on the website. We also collect Internet Provider (IP) addresses and store them temporarily in order to monitor flow of traffic to our website.

5.2) Contacting us by telephone, by email or post:

If you contact us by telephone, email or post we may collect and retain your contact details and the contents of your communication in hard and/or electronic copy. We use details such as these to help us handle any queries you might have and for keeping records of communications. We would like to make you aware that calls to Financial Advice Network may be recorded for training or monitoring purposes.

5.3) Recruitment and joining the Network:

If you make enquiries about joining the Network, or decide to join the Network then we will collect information such as contact details, employment details, qualifications, bank account details and assets and liabilities.

5.4) Annual fit and proper assessments:

To meet regulatory requirements we have to collect information from all ARs on an annual basis, this includes financial information such as assets and liabilities.

For further information on when we collect personal information from you, please see section 4.

6) Why do we collect this personal information?

We obtain personal information about you and other personal details to help us carry out a variety of activities.
These include:

6.1) Recruitment and referencing:

When applying to join the Network we will collect details about you such as:

  • Your contact details such as your name, address, email and telephone number;
  • Your bank account details;
  • Your date of birth or age;
  • Your gender;
  • Your relationship status;
  • Your identification number, for example, your National Insurance(NI) number;
  • Your employment details and qualifications;
  • Your financial background including assets and liabilities
  • Any criminal convictions;

6.2) Management and supervision of ARs (including communicating with you):

Making sure we provide our ARs with excellent service and support is very important to us and to do this we try, where possible, to communicate information in the way you want to be contacted. Most of the time you will be contacted by phone or email, although you may receive updates by letter. You can opt-out or change your preferred method of communication at any time by simply contacting us - see section 3.

To manage and supervise ARs we will use some or all of the personal information you provided during the recruitment process.

7) Who do we share your personal information with?

We may need to share your Personal Information with external companies (third parties). We share your Personal Information with carefully selected third parties to help us provide essential services to you.
These third parties include:

Financial service providers:

  • Product providers;
  • Platforms;
  • Any other firm you wish to have an agency with.

Our service providers and professional advisers:

  • Back office system provider;
  • Auditor services;
  • Other third parties where required or permitted by law, or with your consent.

Crime detection, prevention and prosecution:

  • Credit reference or identity verification services;
  • Disclosure services.

Regulatory and governmental bodies:

  • The Financial Conduct Authority;
  • HMRC;
  • and law enforcement authorities.

We will never sell your personal information to third parties, or share it with anyone who is not listed above.

8) Do you share personal information outside of the UK?

We may transfer personal information that we collect from you to third party processors who are located in countries that are outside of the European Economic Area (EEA). Please be aware, countries which are outside the EEA may not offer the same level of data protection as the United Kingdom, although our collection, storage and use of your personal information will continue to be governed by this Privacy Notice.

Please see section 7 for further information on who we share your personal information with.

9) How long will you keep my personal information for?

We will hold your personal information for as long as you are an AR with the Network. Should you leave the Network we will keep your personal information for a further six years.

10) What are my rights with regards to my personal data?

10.1) Right of Access

You have the right to access and obtain a copy of the personal information that we hold about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.

10.2) Right to Rectification

You have the right to request that we correct any inaccuracies in the personal information stored about you.

10.3) Right to Erasure

In certain circumstances, you have the right to request that we erase your personal information.
For example, you may exercise this right in the following circumstances:

  • Your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed by us;
  • Where you withdraw consent and no other legal ground permits the processing;
  • Where you object to the processing and there are no overriding legitimate grounds for the processing;
  • Your personal information has been unlawfully processed; or
  • Your personal information must be erased for compliance with a legal obligation.

Where we store your personal information for statistical purposes, we may not be able to comply with such a request where it would likely impair such statistical purposes or where we require your personal information for compliance with a legal obligation or in connection with legal proceedings.

10.4) Right to Restriction

You have the right to restrict our processing of your personal information where any of the following circumstances apply:

  • Where you feel that the personal information which we hold about you is not accurate. This restriction will be in place for a period to enable us to verify the accuracy of your personal information;
  • Where the processing is unlawful and you do not want your personal information be erased and request the restriction of its use instead;
  • Where we no longer need to process your personal information (e.g. any of the purposes outlined above have been completed or expire), but we require it in connection with legal proceedings;
  • Where you have objected to our processing of your personal information pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms;
  • Where you exercise your right to restrict our processing of your personal information, we will only continue to process it with your consent or in connection with legal proceedings or for the protection of the rights of other people or for reasons of important public interest.

10.5) Right to Communication

If you ask us to correct, erase or restrict the processing of your personal information, and we have shared your data with a third party, we will notify those third parties of your request.

If a breach or loss of your data occurs, you will be notified immediately by us.

10.6) Right to Data Portability

To further strengthen your control over your personal information, you have a right to receive and transfer the personal information that you provide to us in a structured, commonly used and machine readable format where we process your personal information on the legal bases of: a) your consent; or b) where it is necessary to perform our contract with you and such processing is carried out by automated means. Where you make such a request, we will directly transfer your personal information on your behalf to another controller of your choice (where it is feasible for us to do so).

10.7) Right to Object to Processing

In certain circumstances, you have a right to object to our processing of your personal information where we process it on the legal bases of: a) our legitimate business interest (e.g. the statistical purposes outlined above), including profiling based on our legitimate business interests; or b) your consent to marketing. We may not be able to comply with such a request where we can demonstrate that there are compelling legitimate grounds for us to process your personal information which overrides your interests, rights and freedoms or where the processing of your personal information is required for compliance with a legal obligation or in connection with legal proceedings.

10.8) Right to Object to Automated Decision-Making, including Profiling

You have a right not to be subjected to decisions based solely on automated decision-making, including profiling, which produce legal effects concerning you or similarly significantly affects you.

We may not be able to comply with such a request where we rely on the legal bases of:

  1. your explicit consent; or
  2. where it is necessary to enter and perform our contract with you

You will, however, be entitled to have a person from the Network review the decision so that you can query it and set out your point of view and circumstances to us.

11) Legal bases for processing of personal data

The legal bases for our processing of personal information are as follows:

  • The processing is necessary to comply with a legal or regulatory obligation, for example anti-money laundering legislation, the requirements of the Financial Conduct Authority, or those of HMRC;
  • Other processing of personal information with your consent;
  • For the performance of your contract with us and the provision of our services to you.

We will only process special categories of personal information (e.g. any criminal convictions) with your explicit consent.

We will only collect the personal information we need so that we can provide you with the service you expect from us. If you choose not to provide us with any of the data we have requested, this may result in us being unable to offer you the service you request.

12) Notification of a data breach

If a security breach causes an unauthorised intrusion into our system that materially affects you, we will notify you as soon as possible and later report the action we took in response to any breach.

13) Contacting us

If you have any questions about how we collect, store and use personal information; would like to make a complaint regarding privacy; or if you have any other privacy related questions, please contact us by using any of the following means:

Telephone: 0161 495 6446
Email: info@financialadvice-network.co.uk
Post: Financial Advice Network Ltd, Haw Bank House, High Street, Cheadle, Cheshire. SK8 1AL

If you have already contacted us but are still not satisfied, you have the right to refer your complaint to the Information Commissioners Office. They can be contacted by using any of the following means:

Telephone: 0303 123 1113
Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF
Live chat: Available by visiting their website www.ico.org.uk

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