Effective from 25 May 2018
JJFS are proud to have been entrusted with the financial wellbeing of our clients for over 40 years, providing a personal service now spanning four family generations. It should go without saying that we take confidentiality very seriously and will always protect and respect your privacy and the data we hold about you. This Privacy Notice explains how and what data we collect, how we use it, who we may need to share it with, and how long we keep it for.
How you are protected
We are only allowed to process data if we have a lawful basis for doing so. Our primary basis for processing your data is for the performance of the contract we have with you to provide financial planning services, including advising on and arranging investments and pensions. We will also process your data where we have a legitimate interest to do so, such as to enable us to meet our legal and regulatory responsibilities to you and the Financial Conduct Authority.
How we collect your data
We receive information about you when you complete a paper or electronic form, if you contact us by telephone or email and when you meet face to face with our Financial Planners.
We also receive information about you from other sources. For example, where we ask you to complete a risk tolerance profiling questionnaire provided by a third party who specialises in this field and we receive your information via that third party.
What data do we collect?
The personal data we collect from you includes your name; address, email address, phone numbers, date of birth, National Insurance number, passport number, copies of utility bills and your employment or business interests. We will also collect data about your income & expenditure, assets & liabilities, your attitude to risk, knowledge and experience of investing, current investments, the insurance policies you hold, your professional advisers, your will, and any power of attorney you have given or been given. We may also collect sensitive personal data about your state of health necessary to assist in the administration and performance of an insurance contract.
We may need to collect data about your close family members and dependants to provide our services. Where we do, you will be responsible for ensuring that you have the consent of the people concerned to share their information with us. If you ask us to provide a copy of our Privacy Notice to them, we will do so.
How we use your data
We use the information we hold in the following ways:
To comply with the Money Laundering Regulations.
To meet our contractual obligations to you under our Client Agreement and Service Agreement.
To comply with our regulatory duties to the Financial Conduct Authority.
To inform you of any arrangements we make with other financial services firms that we think could be beneficial for you to know about.
To assist us and you in resolving any dissatisfaction about our service at any time in the future.
Who we might share your data with
We will never share your data with a third party for marketing purposes.
To comply with the Money Laundering Regulations, we may share your data with a third party to verify your identity and perform other anti-money laundering checks.
To meet our contractual obligations to you under our Client Agreement and Service Agreement, and to enhance the effectiveness of our services to you, we may share your data with other third parties that we engage with for accountancy, compliance, legal, trust, will and probate specialist support. We will also share your data with financial product providers such as investment managers and platform providers, insurers and the third-party service providers that provide us with analytical tools to support our financial planning service and access the investment, platform and insurance market to arrange financial products for you.
We only share your data with a third party for processing if we have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with your or our written instructions.
How long we keep your data
We will retain your personal data while it is necessary for us to meet our contractual obligations to you under our Client Agreement and Service Agreement. We will take all reasonable steps to keep your data up to date throughout our relationship.
To comply with our regulatory duties to the Financial Conduct Authority, we must retain your data for specified minimum periods:
For investments: Five years
For pension transfer and opt-outs: Indefinitely
For insurance business: Three years
These are minimum periods during which we have a regulatory obligation to retain our records and, therefore, your data.
We reserve the right to retain your data for longer where we believe it is in our legitimate interest to do so.
You have the right to ask us to delete your personal data. We will comply with this request unless doing so limits our legal and regulatory obligations or affects our legitimate interests.
Accessing the data we hold
You have the right to request a copy of the data that we hold on you. We will provide you with a copy of the data we hold if you write to us or email us with your request.
We have an obligation to ensure that the data we hold is accurate and up to date. Please ask us to correct or remove any data that you think is incorrect.
If you have any questions relating to our data protection, please contact our Data Protection Officer:
Data Protection Officer John Joseph Financial Services Limited
If you are ever unhappy about the way we have processed your personal data, you have a right to complain to the Information Commissioner’s Office. Their address is:
0303 123 1113