PRIVACY STATEMENT

Your information will be held by Chamberlain De Broe.

This Privacy Statement explains why we collect personal data, what data we store and how we use it.

You entrust Chamberlain De Broe with important information about you and your family. We take our responsibilities seriously. We are committed to protecting and respecting your personal data.

This privacy notice is to let you know how we will look after your personal information. Personal information includes what you tell us about yourself, for instance, by filling forms or applications; what we learn by having you as a customer, i.e. through your interactions with us by post, email, phone or in person and from the way you use financial products. We may also receive information about you from third parties who provide services to you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.


WE PROMISE:

> To keep your data safe and private.
> Not to sell your data.
> Not to use your data in automated decision making or profiling.

Data Protection law will change on 25 May 2018

This Notice sets out most of your right under the new laws.

As well as our Privacy Promise, you are also protected by law. Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so.

The law says we must have one or more of these reasons:
To fulfil a contract we have with you, or
When it is our legal duty, or
When it is in our legitimate interest, or
When you consent to it.

We will only use your data when the law allows us to. Most commonly, we use your personal data to offer you financial advice and to comply with our legal obligations as financial advisers.

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so.

  • To fulfil the contract we have entered into, for example:
    – Provide financial advice
    – Provide an investment proposal
    – Arrange investments and transactions
    – Confirm your identity
    – Provide regular reviews of your financial situation
  • To comply with our legal obligations, for example:
    Where we are required to use your personal data and maintain records of our dealings with you by our regulators and other authorities.
    – To resolve disputes.
    – To respond to data subject requests.
    – To prevent, detect or investigate crime.
    – To carry out identity and anti-money laundering checks.
  • Where it is necessary for our legitimate interests, for example:
    – To establish, exercise or defend our legal rights, where we are faced with any legal claims or where we want to pursue legal claims.
    – To prevent, detect or investigate fraud
    – To respond to enquiries and resolve disputes.
    – To monitor advice given.
    – To provide management information to enable us to monitor our performance and understand our business.
    – For accounting, auditing and corporate governance purposes.
    – To manage risk for us and our customers.
    – For training purposes.
  • Where we have obtained your explicit consent to do so, for example:
    – To process sensitive personal data (see below)

What kind of personal data may we hold about you

We may use different kinds of personal information.
Contact: your address, email address and how to contact you
Financial: your financial position, status and history.
Contractual: details of products and services we advise you upon
Transactional: details about payments to you or from you
Technical: details of the devices and technology you use
Socio-demographic: details about your profession and your work, your income and expenditure, nationality and education.
Communications: what we learn about you from letters, emails and conversations.
Social and family: your family, friends and other relationships.
Open data and public records: information about you that is available on the internet and public records.
Documentary data: details about you stored in documents or copy documents, like passports, birth certificates, driving licences etc.
National Identifiers: number or codes given to you by a government to identify, like National Insurance or Unique Tax Reference numbers.
Consents: Any permissions, consents or preferences that you give us. This includes method of contact, whether you receive paper statements or prefer large print format.
Special types of data: the law treats some types of sensitive personal information as special. We will only collect and use this type of data when the law allows us and we have your permission to do so. Special data includes racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetic and biometric data, physical or mental health information and records of criminal convictions.

How will we use the information we hold about you

We will use the information we collect about you in a number of ways:

  • To offer you financial advice appropriate to your circumstances
  • To research the market on your behalf
  • To provide you with products and services
  • To offer or inform you about new investments
  • For security and identity verification
  • To communicate with you
  • To comply with the law and regulations

We will also use your information to monitor the quality of our advice, for training and quality purposes, to help us investigate any disputes that may arise in the future.

How long will we store your information

We will hold your personal information for as long as we require it to provide you with the services you asked for; or as long as we are legally obliged to do so; or if it is in our legitimate interest. After you stop being a client we will still keep your data to respond to any questions, to resolve potential disputes and to maintain records in accordance with the rules that apply to us.


Who may we share your data with

We may share your personal information with third parties and organisations such as:

  • HM Revenue & Customs
  • Financial Conduct Authority and other regulators
  • UK Financial Services Compensation Scheme
  • Organisations that introduce us to you
  • Companies we introduce to you
  • Companies you ask us to share your data with


How do we ensure security of your data

We have appropriate security measures in place to prevent your personal data being accidentally lost or accessed in an unauthorised way, altered or disclosed. We limit access to your data to those employees, agents, contractors and other third parties who have a business need for it. They will only process your data on our instruction and are subject to a duty of confidentiality.
We have procedures to deal with any suspected data security breach and will notify you (and any relevant regulator) of a suspected breach when we are legally required to do so.

Your rights in connection with personal data

You can access your personal data by asking us to provide you with a copy of it.

You have the right to object to our use of your personal information, or to ask us to correct it, delete, or stop using your data if there is no need for us to keep it. This is known as the ‘right to object’ or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

If you wish to exercise any of your rights or you have any questions about this Privacy Statement, how we handle your data, please write to us or email enquiries@cdebroe.com or call on 020 7240 7640.

Our Data Protection Officer is Mr James Higgins.

You also have the right to make a complaint at any time about our use of your data to Information Commissioner’s Office (ICO), the supervisory authority for data protection issues.

The ICO’s contact details are: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Telephone number 0303 123 1113 or at https://ico.org.uk/

 

Version II (May 2018)