Enable Independent Financial Life Planners is a trading style of Enable Independent Ltd. This privacy notice explains how we use any personal information we collect about you
For the purpose of the Data Protection Act 1998 and subsequently the General Data Protection Regulation (the Act), Enable Independent Ltd is the data controller.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect information about you when you engage us for financial planning, financial advice, mortgage advice or investment management services. This information will relate to your personal and financial circumstances and it may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys, provide feedback to us or sign up for newsletters and updates.
COOKIES, IP ADDRESSES AND WEB BEACONS
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, to improve the structure and content of our site and to report aggregate information to any sponsors and our members. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number. Two types of cookies are used by us on our site:
- Session Cookies: which are temporary cookies that remain in the cookie file of your browser until you leave the site; and
- Persistent cookies: which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
Session Cookies allow you to carry information across pages of our site and avoid having to reenter information and to allow you to access stored information.
Persistent Cookies help us recognise you as a unique visitor (just a number) when you return to our website and to allow us to assess and understand our content, which pages are being visited and how long visitors spend on each page.
We specifically use Google Analytics for this. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
INFORMATION ABOUT CONNECTED INDIVIDUALS
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
WHY DO WE NEED TO COLLECT AND USE YOUR PERSONAL DATA?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
HOW WILL WE USE THE INFORMATION ABOUT YOU?
We use information held about you in the following ways:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- Where you have consented to be contacted for such purposes, to provide you with information or services that you request from us or which we feel may interest you.
- To carry out our obligations arising from any contracts entered into between you and us.
- To promote and allow you to participate in any events or features which may offer on our site from time to time, when you choose to do so.
- To notify you about changes to our service.
WHO MIGHT WE SHARE YOUR INFORMATION WITH?
If you agree, we may email you about other products or services that we think may be of interest to you.
We won’t share your information for marketing purposes with companies outside Enable Independent Ltd.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll 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’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit. These measures include password protected portals and secure messaging.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods.
These are, generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records. We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
HOW CAN I ACCESS THE INFORMATION YOU HOLD ABOUT ME?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below. We have 30 days to respond.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post, or by clicking HERE.
MAKING A COMPLAINT
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
0303 123 1113 (local rate)
HOW TO CONTACT US
Or write to us at Enable Independent
25c North Street
01279 755 950 firstname.lastname@example.org