DATA PRIVACY NOTICE
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.
Who we are
Financial Protection Limited collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “FPL”, “we”, “us” or “our” we are referring to Financial Protection Limited.
We are a company registered in England and Wales (company number 08638135) Financial Protection Limited whose registered office is at Forshaws Accountants Limited, Railex Business Centre, Crossens Way, Southport, Merseyside, PR9 9LY. [Financial Protection Limited.] We provide you with financial advice on a range of products from life insurance, critical illness insurance, income protection, health insurance, and wills.
The personal data we collect and useIn the course of providing our service to you we may collect the following personal data when you provide it to us:
- contact information
- identity information
- financial information
- employment status
- lifestyle information
- health information
- data about criminal convictions or offences
- details of any vulnerability
- details of your dependents and/or beneficiaries under a policy (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.)
- product details
- From product providers:
- product details
- From identification and verification checking agencies:
- identity information
- sanction check information
How we use your personal dataThe below table sets out:
- how we use your personal data
- the lawful bases upon which we collect and use your personal data
- who we routinely share your personal data with
|Rationale/Reason for Processing||Lawful Basis for Processing||Third party recipients linked to that activity|
|· We process your personal data so that we can fulfil our contractual obligations and deliver the service that you request from us. Such processing takes place in our secure systems with limited personnel access and the systems of our processing partners.||Performance of a contract||Our Principal, Dragon Brokers Limited and the Dragon network of insurers, including One Family, Royal London, Liverpool Victoria, Vitality and Legal & General|
|· For auditing and reporting purposes||Compliance with a legal obligation||Financial Conduct Authority, HMRC, Our FCA Principal|
|· We use your personal information in the administration of your account and where appropriate, to advise you similar financial products and services that may be of interest to you. You can opt out of this at any time.||Legitimate Interest||We will always let you know if there are any third parties that could offer similar and relevant products.|
Special category dataCertain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection. We may process:
- health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
- criminal conviction or offence information when providing intermediary services in relation to a general insurance product
MarketingWe may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent or where there are legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us. In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you. You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please contact us: By phone: 0800 103 2613 By email: [email protected] By Post: Financial Protection Ltd, St George’s House, Peter Street Manchester M2 3NQ In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every email.
Whether information has to be provided by you, and if so whyWe will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.
How long your personal data will be keptWe will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.
|Type of Record||Retention Period|
|Personal data for successful cases.||We keep records of cases that have been successful for 7 years.|
|Personal data for cases that we’re not successful or we couldn’t assist with.||We keep records of unsuccessful cases for 4 years.|
Transfer of your information out of the EEAWe will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
Your rightsYou have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:
- To access personal data
- To correct / erase personal data
- To restrict how we use personal data
- To object to how we use personal data
- To ask us to transfer personal data to another organisation
- To object to automated decisions
- To find out more about how we use personal data
- where you think the information is inaccurate and we need to verify it;
- where our use of your personal data is not lawful but you do not want us to erase it;
- where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
- where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.
- email or write to Data Protection at [email protected] or Financial Protection Limited, St George’s House, Peter Street Manchester M2 3NQ
- let us have enough information to identify you, e.g. name, address, date of birth;
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information to which your request relates.
Keeping your personal data secureWe have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our supervisory authorityIf you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk). We ask that you please attempt to resolve any issues with us before the ICO.
How to contact usPlease contact our Data Protection Office if you have any questions about this privacy notice or the information we hold about you. If you wish to contact The Data Protection Office, please send an email to [email protected] or write to Financial Protection Ltd, St George’s House, Peter Street Manchester M2 3NQ
Glossary of Terms
|we, us or our||Financial Protection Ltd (FPL) a company registered in (England and Wales) (Scotland) (company number 08638135) and having its registered office at Forshaws Accountants Limited, Railex Business Centre, Crossens Way, Southport, Merseyside|
|contact information||these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address|
|data controller||means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services|
|data protection regulation||applicable data privacy and protection laws|
|employment status||this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance|
|FCA||the Financial Conduct Authority, being the independent watchdog that regulates financial services|
|financial information||this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60|
|health information||this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history|
|identity information||this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number|
|intermediary services||these are the services we provide to you in relation to the products|
|lifestyle information||this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits|
|product||this is an investment, pension, mortgage, protection and/or general insurance product in respect of which we may provide intermediary services to you|
|product provider||a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above)|
|sanction check information||this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering|
|vulnerability||a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence)|