1. What information do we record about you?
Before we give you financial planning advice, we need a full picture of your personal finances and your personal circumstances. We record this in a computer file for our future reference.
Even after you become a client, if we are to continue advising you on your finances in the future, we will need to update our records each time that we review your financial planning.
2. Why do we need this personal data?
So that the advice we give you is appropriate to your circumstances. For example:
- The advice that we may give to somebody with terminal cancer will probably differ from the advice that we may give to somebody without any health impairments.
- The advice to somebody running a profitable private business will probably differ from the advice to somebody who is retired and managing on a modest fixed income.
- The advice to a couple with a young family and a large residential mortgage will probably differ from the advice to a retired couple with no dependants and no debts.
Regulators take a dim view of inappropriate advice given without due diligence on our part
3. With whom might we share your personal data?
We respect client confidentiality.
- We will not sell client data to any outside agency.
- Nor will we join with any third party wanting to sell you their services.
Certain bodies can gain access to our client files on occasion:
- Our regulators, the Financial Conduct Authority.
- Such "compliance consultants" as we may appoint from time to time.
- Such "professional indemnity insurers" as we may appoint from time to time.
- The Financial Ombudsman Service.
- Such "computer software suppliers" as we may appoint from time to time.
Where access to our client files is granted to these bodies:
- They will be under the same obligations as us to ensure that your data is protected.
- And if they in turn are passing your data to anybody outside of the European Union, they must ensure that the data is as protected as it would be in the European Union.
Where we place business on behalf of clients with financial institutions:
- They may well contact you directly although we do try to avoid this as far as possible.
- Client data is only shared to the extent necessary to complete the business in question.
- And to verify clients' identity in order to satisfy "Money Laundering" regulations.
4. How long will we keep your personal data?
Usually for no more than six years after you cease to be a client. The six years’ delay is in case you – or your heirs – decide to raise a complaint about the advice that we have given to you in the past. Without our past records, how do we defend ourselves?
Our professional indemnity insurers are not happy about us destroying client files. And for certain classes of business, our regulators insist on indefinite retention.
That said, if you want us to delete your data earlier than would be our normal practice, we will try to oblige you, subject to any constraints placed on us by our insurers or our regulators.
5. Can you access the data that we hold about you?
You most certainly can - and you can ask us to correct or remove any incorrect information.
Please write or speak to our Managing Director, John Cope, in the first instance:
We have told you previously in section 3 of this document that we will not sell your data to any outside agency, nor will we join with any third party wanting to sell you their services.
We ourselves will not contact you for purely marketing purposes. However, if you register for our annual review service, you will authorise us to contact you each year in that context.
7. Internet web-site
We have an internet web-site at www.dcandp.co.uk
Most web-sites use “cookie technology” these days. Our web-site is no exception.
If “cookies” are new to you, they are explained on our web-site. You can also discover how to avoid them - although “cookies” of themselves cannot identify you personally.
8. What can you do if you are unhappy with how your personal data is being processed at David Cope & Partners Limited?
Please write or speak to our Managing Director, John Cope, in the first instance. Our contact details are as shown above in section 5.
If we cannot resolve matters to your satisfaction, you can contact the supervisory authority for data protection in the United Kingdom, the Information Commissioner:
- Postal address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
This document is reviewed regularly and updated at least once a year.