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HFS Milbourne Financial Services Ltd – Privacy Notice 

Introduction

This Privacy Notice covers HFS Milbourne Financial Services Ltd and its joint venture companies, HFS feltons Financial Services Ltd, HFS Hamlyns Financial Services Ltd and HFS Goodwille Financial Services. In this notice, where ‘HFS Milbourne’ is stated, the relevant policy would also apply to the joint venture companies.

HFS Milbourne is committed to protecting your personal information and ensuring that it is used fairly and responsibly. This notice sets out what personal information HFS Milbourne will collect about you and how we will use this information.

We have appointed a dedicated ‘Data Protection Manager’, who are responsible for ensuring that we continue to apply the regulation and take care of data security within our business.

Information that we collect about you 

We will collect information about you to provide you with advice and our services. We collect information about you when you:

  • Attend meetings with your financial or mortgage consultants
  • Receive regular ongoing services
  • Communicate with your financial consultant and/or our support staff regarding products and services
  • Complete application details required for the contract, whether on the proposal form or on other associated administration forms
  • Complete an administration process, for example completing an amendment form to change personal or contractual details
  • For members of employee benefit schemes (for example group personal pension and/or group protection or insurance contracts) complete an application/administration process via your employer.

The type of information we collect about you will depend on the purpose for which it is collected and will typically include:

  • Your name and contact details
  • Details of your family and dependants
  • Information to verify your identity, for anti-money laundering purposes
  • Financial information regarding your current income and expenditure, employment information
  • Details of your wealth, i.e. assets and liabilities, investments and savings, tax status
  • Your investment objectives and attitude to risk

We will only collect personal information necessary and relevant to the contractual obligations with you.

Where we provide our services with regard to trusts, we collect personal information relating to settlor, trustees and beneficiaries. Where we provide our services to companies we may collect personal information for directors, shareholders and/or beneficial owners of the company.

The information that we gather may also include special categories of sensitive personal data, which for our purposes would include asking for information about your health, medical history and investment preferences. This information is necessary for example to apply for life assurance on your behalf and also as part of full financial planning exercises, to help us understand your individual circumstances and needs.

Why do we need to collect and use your personal data?  

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would also be unable to fulfil our legal and regulatory obligations. 

How we use your personal information

The personal information about you that we have collected will be used to:

  • Complete research and analysis, to find suitable products and recommendations
  • Write suitability reports for our advice to you
  • Prepare personalised illustrations for our recommendations
  • Carry out transactions that we have agreed, including the application phase
  • Provide other services to you, including an ongoing service agreement.
  • For employee benefit services, provide contractual information to your employer
  • Monitor and complete our financial accounting requirements
  • Meet our regulatory and legal obligations.

Information about connected individuals

As mentioned above, we may need to ask you questions which relate to personal information about your close family members and dependants in order to advise you appropriately and/or provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or ask you to pass the privacy information to them.

With whom might we share your information? 

We will share personal information with third parties, such as product and investment providers, mortgage lenders and other professional institutions which need to be involved for the performance of our contract with you. Some of these institutions may be located outside the EU.

In order to deliver our services to you effectively we may share your details with third parties such as accountancy or legal services. We may also need to engage professional compliance or audit services in order to adhere to regulatory or legal requirements in our industry.

Where third parties are involved in processing your data, we would have ensured that we understand the nature and purpose of the processing and that this is clear; that they are subject to a duty of confidence in processing your data; and that they will only act in accordance with our written instructions.

Data security

HFS Milbourne already has a robust Data Security policy in place which sets down strict rules across the company on how we handle client data and protect this. Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit.

Within the Data Security policy we have a procedure relating to password protection of our software and hardware, and also the documents that we electronically transfer (most commonly by email) to third party providers. We also have a comprehensive procedure for IT security, setting down robust means to ensure that any electronically stored information is kept secure. Our storage of data is retained within the EU.

The largest proportion of client our data is stored electronically, however where this is stored on paper, there are data security procedures in place to safeguard these documents equally.

The review of our Data Security policy is continuous so that we always strive to update our procedures and to work proactively to protect client data.

How long do we keep hold of your information?

During the course of our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship. We are subject to regulatory requirements to retain your data for specified minimum periods, depending on the type of contract and/or advice.

HFS Milbourne reserves the right to retain all data indefinitely which is longer that some of the minimum periods specified by regulatory requirements.  This is based on experience that enquiries from either clients or third party providers have required access to information from files going back a considerable number of years, or instances where we have required personal data for legal or regulatory purposes. This includes leavers of group personal pension schemes and other group employee benefit schemes.

Your rights

You have the right to:

  • Request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests.
  • Request a copy of the personal information that we have about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below.
  • Ask us to update or correct your personal information, subject to certain requirements, for example proof of ID to amend the spelling of your name.
  • Ask that we restrict the processing of your personal information where appropriate.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use. We have an obligation to ensure that your personal information is accurate and up to date.

Marketing

If you currently receive the HFS Milbourne Newsletter and other related communications as part of your service agreement with us, we will continue to send you these. The newsletter provides information about investments, pensions, estate planning and general financial & market updates. It contains articles with generic information, i.e. it does not include reference to personal information or circumstances.

We may email you about other products or services that we think may be of interest to you. We will never share your information for marketing purposes with companies outside our group.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please let us know via the contact details below.

Please note that this excludes the email correspondence that you have previously consented to, which we use for correspondence in order to service your contract, for example emailing you an application form or an illustration.

Our website

The HFS Milbourne website can be found on www.hfsmilbourne.co.uk

Our website contains links to other websites. This privacy policy only applies to our website so when you link to other websites you should read their own privacy policies.

We do not use cookies on our website, however when someone visits our website we use a third party service, Google Analytics, to collect standard internet log information and statistics. We do not retain any personal data from this process.

If you are unhappy with how your personal data is processed 

You also have a right to lodge a complaint with the supervisory authority for data protection.

In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 (local rate)

Changes to our privacy policy 

We keep our privacy policy under regular review and we will place any updates on this web

page (and/or) inform you of any changes when they occur. This privacy policy was last updated on 9 May 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or the information we hold about you:

The Data Protection Manager
HFS Milbourne Financial Services Ltd
Wonersh House
The Guildway
Old Portsmouth Road
Guildford
Surrey GU3 1LR
Tel: 01483 468888

info@hfsmilbourne.co.uk