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.
Tudor Franklin Ltd is committed to protecting and respecting your rights. This privacy notice explains how we collect, store and use personal information when our customers and website visitors purchase one of our products or otherwise provide us with personal information. Our privacy notice will provide you with details about:
• The types of personal information we collect from you;
• How we use it;
• The rights you have to control our use of it.
This notice applies regardless of how we collect your personal information.
2. Who are Tudor Franklin Ltd?
Firm name and any trading style: Tudor Franklin Ltd/Tudor Franklin Independent Financial Advice
Firms regulator: Financial Conduct Authority (FCA)
FCA registration number: 788066
Registered office details: 10 Bradgate Road, Anstey, Leicester, LE7 7AA
Registration details with the ICO: A8317456
Details of the Data Protection Officers: Mr Richard Meats & Mr Bharat Chudasama
3. Data Controller
For the purposes of Data Protection laws, Mr Richard Meats & Mr Bharat Chudasama are the Data Controllers of personal information covered by this notice.
You may contact Mr Richard Meats & Mr Bharat Chudasama about all issues related to this notice, your personal information and to exercise your rights under Data Protection laws.
Contact Details of the Controller and Data Protection Officer:
Data Controller & Data Protection Officers: Mr Richard Meats & Mr Bharat Chudasama
Address: 10 Bradgate Road, Anstey, Leicester, LE7 7AA
Telephone Number: 01163 193343
4. When do we collect personal information?
We collect and process personal information about you. The personal information you provide will assist us in offering you the best advice as required by the Financial Services and Markets Act 2000. The personal data you provide will be used and stored in accordance The General Data Protection Regulation.
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.
Personal information/data will be collected during the course of the fact find process and/or for illustrative purposes to provide a suitable recommendation. Personal information may also be taken and passed to approved third parties to help meet your identified objectives.
5. Where do we collect your information?
We will collect your information electronically and the information will be held on our records and shared on the Financial Advice Network’s central server.
This information may be collected either face to face in person, over the phone, via email or via our client portal.
5.1 Visiting and using our website
You can visit our website at www.tudorfranklin.co.uk
We have a ‘contact us’ section that is used to gather contact information only & this will be used as permission from yourself as consent for us to contact you.
Your browser settings will determine whether cookies can be stored by visiting the website.
5.2 Contacting us by telephone, by email or by post
You can contact us in the following ways:
Telephone: 01163 193343, 07873 248089 or 07976 700409.
Post: Tudor Franklin Ltd, 10 Bradgate Road, Anstey, Leicester, LE7 7AA
Your data can be collected in the following ways:
We collect personal information to enable us to provide financial services and advice, to maintain our own accounts and records and to support and manage our employees.
5.3 Third parties
Sometimes we may provide your data, by electronic or other means, to:
Other companies within the Financial Advice Network.
A third party to verify your identity, in line with money laundering or other requirements (this may involve carrying out checks with credit reference databases).
Third parties who perform tasks for us to help us service your plan (these third parties may be based in countries outside the European Economic Area (EEA)).
Third parties for referrals in specialised or areas that we do not deal with directly i.e. Will Writing, Conveyancing, Specialist mortgages, Estate Planning, Equity Release and Defined Benefit Pension transfers where applicable.
We may also be provided by your information from third parties looking to introduce business to us.
We may also share your data with other organisations, including the police, and check and/or file your data with fraud prevention agencies and databases to prevent and detect fraud. If we are given false or inaccurate information and we suspect fraud, we will record this. Your data may be made available to third parties where required by law, court order or regulation.
Financial Advice Network may also use your data for assessment and statistical analysis purposes.
6. Why do we collect this personal information?
We will collect your information to fairly process your information in order to help formulate recommendations based on your disclosed circumstances.
6.1 Staying in touch with you.
Tudor Franklin Ltd will continue to review your affairs by way of regular written or verbal contact and to keep you informed about products and deals which may be suitable for you.
If you send us emails, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send us an unsecured email, please keep the amount of confidential information you include to a minimum. If you no longer wish to be contacted in this manner then please ensure to provide us either written or electronic confirmation.
6.2 Process applications.
Applications can be processed in the following ways:
Manually on paper application forms.
Through provider platforms electronically.
6.3 Prevent and detect crime.
We have systems that protect us and our customers against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We may share your personal information from your account with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
Checking details on applications.
Checking details on claims.
Checking details of job applicants and employees.
7. Who do we share your personal information with?
Your information can be shared with the following:
Principal firm (Financial Advice Network).
Service providers and professional advisers.
Regulatory bodies and law enforcement agencies.
Other third parties where required or permitted by law.
8. Do you share personal information outside the UK?
On occasion third parties who perform tasks for us to help us service your plan (these third parties may be based in countries outside the European Economic Area (EEA)). Whilst countries outside the EEA may not have data protection laws equivalent to the UK’s, we will ensure that third parties agree to treat your data with the same level of protection as if we were dealing with it.
9. How long will you keep my personal information for?
We may hold your data indefinitely as per our retention policy. Please feel free to contact us should you require sight of this.
10. What are my rights with regards to my personal information?
You have the following rights:
Right of access.
The right of access, commonly referred to as subject access, gives individuals the right to obtain a copy of their personal data as well as other supplementary information. It helps individuals to understand how and why you are using their data, and check you are doing it lawfully.
Right of rectification.
You have the right to have inaccurate personal data rectified. An individual may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing. This may involve providing a supplementary statement to the incomplete data.
Right to erasure.
In certain circumstances, you have the right to have personal data erased. This is also known as the ‘right to be forgotten’. The right is not absolute and only applies in certain circumstances.
For example, you may exercise the right in the following circumstances:
Your Personal Data are 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 processing and there are no overriding legitimate grounds for the processing.
Your Personal Data has been unlawfully processed; or your Personal Data must be erased for compliance with a legal obligation.
Where we store Personal Data 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 Data for compliance with a legal obligation or in connection to legal proceedings.
Right to communication/to be informed
The right to be informed covers some of the key transparency requirements of the GDPR. It is about providing people with clear and concise information about what you do with their Personal Data.
Right to data portability
To further strengthen your control of your Personal Data, you have the right to receive and transfer the Personal Data that you provide to us in a structured, commonly used and machine readable format where we process your Personal Data 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 Data on your behalf to another controller of your choice (where it is feasible to do so)
Right to object to processing
In certain circumstances, you have a right to object to our processing of your Personal Data. 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 Data which override your interests, rights and freedoms or where the processing of the of your Personal Data is required for compliance with a legal obligation or in connection to legal proceedings.
Right to object to automated decision making including profiling
You have the 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.
11. Legal bases for processing personal information.
The legal bases for our processing of personal information are as follows:
The individual has given clear consent for you to process their personal data for a specific purpose.
The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation:
The processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests:
The processing is necessary to protect someone’s life.
(e) Public task:
The processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests:
The processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
12. Notification of a data breach.
If a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify you as soon as possible and later report the action we have taken 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:
• Phone us on: 01163 193343
• Email us at: firstname.lastname@example.org
• Write to us at: Tudor Franklin Ltd, 10 Bradgate Road, Anstey, Leicester, LE7 7AA
For further guidance please visit: www.ico.org.uk
Obtaining a copy of your information and making changes.
You can make changes to your information and marketing preferences held by Tudor Franklin Ltd at any time.
Under general Data Protection Regulation (GDPR) you have the right to access your personal data that we hold. This is known as a subject access request for which we would charge a “reasonable fee” for the administration costs involved.
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:
• Phone them on 0303 123 1113
• Use their live chat facility on their website www.ico.org.uk
• Write to them at: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF