2022-03-22 GDD

Your personal data and privacy
New laws protecting the personal privacy of UK citizens came into force in May 2018.
These increase the existing duties on businesses and organisations to ensure your personal
information is protected and fairly processed.
When you first approach us to become a client, we will obtain information about you directly
and from other sources. Typically, these sources will include those financial services providers
with whom you have existing arrangements, and those services necessary to determine your
identity for the purposes of complying with our statutory obligations.
The information we collect will include details of your personal circumstances, financial
affairs, and your goals and objectives. Where relevant, we may also collect sensitive
information such as details of your health, medical history, religious considerations and
ethical preferences.
We hold your information in both paper and electronic
formats. Typically, we will maintain a paper file with
your most recent information, which is used for day-today
servicing of your affairs. These files are periodically
updated and electronically archived to our computer
server.
Unless we receive your consent, we process your
information only in relation to those services we have
agreed to provide to you, and which are set out in the
Customer Agreement you have signed and agreed to.
Where you have given your consent, we will use your
contact information to provide you with regular copies
of our newsletter, birthday and Christmas cards, or to
contact you from time to time on matters we
reasonably believe will be of relevance and interest to you.
We will not, at any time, release your information to any other source for the purposes of
marketing to you.
We will only share your information with another party where necessary to fulfil the
contractual obligations set out in our Customer Agreement, or where subject to a statutory
obligation.
Page 16 of 34 General Disclosure Document 23/3/2022