This website is owned and operated by Trusted Planning Ltd, registered in England under the number 7146761. Trusted Planning previously traded under the Limited Liability Partnership, Trusted Planning LLP before incorporating into a limited company in 2016. Our registered office address is Stamford House, Northenden Road, Sale M33 2DH.
Trusted Planning Ltd is an Independent Financial Advice company (directly) authorised and regulated by the Financial Conduct Authority. The FCA reference number is 726208. The FCA does not regulates the sale of investment products. It does not regulate lifestyle planning, generic financial planning or tax planning.
Why should you read this policy?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your personal circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance with your financial, investment, tax and estate planning requirements Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.
- Personal circumstances including family, details of dependents.
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically about the processing we may undertake in relation to this type of information).
- Details of assets and liabilities including property, bank and building society accounts, National Savings, stocks and shares, loans and credit commitments, personal credit history, vehicle registration numbers.
- Any pre-existing investment, pension, insurance, mortgage or other financial products or holdings and their terms and conditions.
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history and details of other sources of income.
- Expenditure details.
- Tax information relating to you and any companies, trusts or other related parties.
- Details of wills, trusts, powers of attorney and expressions of wishes of yours or in respect of which you are a trustee, beneficiary or settlor.
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your financial, investment, tax and estate planning requirements we do so on the basis that both parties are entering a contract for the supply of services.
To perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either during initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from insurance, investment or other product providers and our compliance service provider relating to the advice we have given to you, or to contact you to seek feedback on the service you received.
On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data to meet a legal, compliance or other regulatory obligations to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with, for example, your insurance, and in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you for information about your health and medical history (Your Special Data). We will record and use Your Special Data to make enquiries of insurance, investment or other providers in relation to insurance, investment or other products that may meet your needs and to provide you with advice or guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use Your Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during our initial meetings, correspondence or conversations with you to establish your circumstances and needs and preferences in relation to financial, investment, tax and estate planning. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, providers of products you hold, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that can verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems and third-party remote software systems including websites, remote software services, email services, hard drives, and cloud facilities. Other than on rare occasions when Trusted Planning Ltd may grant access to a third-party software or service provider that requires access to view Your Personal Data to fix a defect, this information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to pension and life assurance providers and/or administrators, investment and platform providers, estate or tax planning product providers and/or insurance product providers, both in paper form and on-line via secure portals and by encrypted email or encrypted attachments to email. The provision of this information to third parties is essential in allowing us to progress any enquiry or application made on your behalf, to deal with any additional questions or administrative issues that they might raise and to provide ongoing administrative and review services.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment, pension, life assurance, insurance, estate or tax planning or products you already hold or you may take out, or to inform you of any developments in relation to those areas of our service and/or products and/or polices of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment, pension, life assurance, insurance, estate or tax planning or other product providers.
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers, product specialists, mortgage providers or brokers, providers of legal services such as solicitors or estate planners, accountants (in each case where we believe this to be required due to your circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your financial, investment, estate and/or tax planning related enquiries including product related enquiries and to provide you with our professional services.
This sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
The performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area, for example the cloud services we use may have servers based outside the EEA. Trusted Planning Ltd shall not transfer Personal Data outside the EEA to a sub-processor where such transfer is not subject to: (a) an adequacy decision (in accordance with Article 45 of the GDPR); or (b) appropriate safeguards (in accordance with Article 46 of the GDPR); or (c) binding corporate rules (in accordance with Article 47 of the GDPR), without your prior written consent.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
- Request copies of Your Personal Data that is under our control.
- Ask us to further explain how we use Your Personal Data.
- Ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request).
- Ask us to send an electronic copy of Your Personal Data to another organisation should you wish.
- Change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety).
How to contact our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact to exercise any of your rights set out within it please contact:
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who may be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.