Privacy Notice for Campbell Munro Ltd
Data Protection regulations are important to ensure that personal information is kept securely and used only for the correct purposes. Campbell Munro Ltd has been complying with the current laws since they were first introduced in 1998. From 25th May 2018, the law will be changing to further tighten the protection of personal data. This does not just apply to Financial Services firms; every company and organization in Europe has access to personal data will need to comply with the law.
Your personal information and what we do with it
In order to provide the most comprehensive financial planning service to clients, Campbell Munro Ltd is required to collect and process personal information of individuals. This is done for a number of reasons including applying for investment policies, monitoring your financial position, verifying your identity to prevent fraud and fulfilling legal and regulatory obligations. In future we may also send you marketing information subject to your consent.
Whilst much of the data we collate is supplied by clients themselves, we also hold and process data supplied by other organisations such as previous investment providers, the HMRC, the DWP and various regulatory bodies. We also receive information regarding the beneficiaries of clients under the assumption that clients have the consent of those individuals to provide us with that information. This privacy notice should be shared with any proposed beneficiary that you, as a client, may provide information on.
Campbell Munro will only hold the data that is required in order to process your investment and planning advice and this includes but is not limited to your name, address, date of birth, contact details, NINO, extended family details, ISA and pension contribution details, salary, cash position and employment details. Subject to consent being provided we also hold ‘sensitive’ data such as information on your health.
Campbell Munro will hold client data for as long as such data is required in line with the regulatory requirements for providing financial and investment advice. This will involve keeping your information for a reasonable period of time after your relationship with us has ended. In the absence of specific legal, regulatory or contractual requirements, personal information will be kept for a baseline retention period of 5 years, except in the case of Defined Benefit Pension Transfer information which we are required by the Financial Conduct Authority to hold indefinitely.
Our legal grounds for using your data
In order so that we are able to hold and process your data, there must be a lawful basis for doing so. We will only use your personal data when at least one of the following has been satisfied:
Consent – You have provided clear consent for us to process personal information for a specific purpose. Please note, under GDPR your consent can be withdrawn by you at any time.
Contract – The processing of your personal information is necessary for the contract we have with you, or because you have asked us to take steps prior to entering into a contract. Your personal data will be required to establish products we recommend as part of our financial planning and advice.
Legal Obligation – The processing of your personal information is necessary for us to comply with the law. This will include obtaining information required to verify your identity and prevent fraud.
Your Vital Interests – This will only apply in cases where we are required to process data to protect someone’s life, for example, if we have concerns surrounding your wellbeing.
Legitimate Interests – In the event that we decide to issue marketing to clients or conduct independent customer research, we may use your data for a legitimate interest purpose. The purpose of such processing will be to ensure we can continue to improve our service to you and other clients. We will never use your data in this manner without first receiving your consent to do so and you always hold the right to object to the use of such data. We will always consider your interests, rights and freedoms when processing such data and keep considerations for your privacy at the forefront of any data processing.
Special Category Data – In order so that we can provide you with the most comprehensive financial planning, we may need to obtain sensitive, special category data such as information on your health.
Who else processes your data?
We share your personal data with certain third parties involved in the servicing and investment of your monies. For example, Ascentric, A J Bell Investcentre and Transact Platform Services amongst others. These companies all have Data Protection Officers tasked with ensuring compliance with data protection legislation. We also may share your information with public bodies such as HMRC and the FCA where this is required under our business arrangement with you as well as any companies you ask us to share your information with. Under Data Protection Regulations you have the right to ask what information is being held by Campbell Munro Ltd.
We will in some instances share your data with third parties located in other countries outside of the European Economic Area (EEA). This will occur when recommending offshore investment policies and products with such services being carried out by experienced and reputable organisations which comply with European data protection requirements and safeguard your information. We will always ensure that transfers of personal information outside of the EEA are done lawfully.
All of our data held on electronic systems is backed up daily and protected by suitable firewalls and encryption methods. All data held physically is stored appropriately and securely.
Under GDPR Clients have the rights to the following:
Accessing personal information - You have the right to find out what personal information we hold on you.
Correcting or adding to personal information – You can ask us to amend any incorrect information.
Rights to Erasure – You can ask us to delete your personal information which we will fulfill in certain circumstances. We may not be able to carry out this request if this information is required to maintain our level of service to you in our terms of business, or if the information is required to be held for legal/regulatory reasons.
Restricting of processing – If you believe the information we hold is incorrect or feel your information has been unlawfully processed you can request that we do not process your data any further. In the event of such a request we are still permitted to store your data and will provide a response to your request before further process.
Data Portability – In certain instances you can ask us to provide you, or provide another organization with, an electronic copy of the personal information we hold on you.
To object – You have the right to object to the issue of any direct marketing and the use of personal information under legitimate interests.
If you wish to exercise any of your rights, please contact us and we will provide a response to the request within 30 days. There’s normally no charge for exercising any of the aforementioned rights.
If you’re unhappy with how we’re using your information, you have the right to complain to the Information Commissioner’s Office. We’d encourage you to contact us first, so we can deal with your concerns. The Information Commissioner’s Office can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
General Data Protection Regulations (GDPR)
Under the new regulations as from 25th May 2018, one of the things Campbell Munro Ltd will do is incorporate the required changes to our Client Agreement. We will advise clients of the changes to our Privacy Notice which have been made to comply with our obligations under GDPR on our website. This privacy notice will be updated as required.
Your point of contact within Campbell Munro Ltd is Luke Fizia.