This policy sets out LWM’s obligations in relation to clients whose personal data we use, including the way in which we process, store and protect client data.
LWM actively ensures that the necessary steps are taken to protect the privacy of our clients in all their dealings with us. We believe our approach complies with all UK national laws and requirements for user privacy.
What personal data do we hold?
LWM collects personal data (name, address, email, account details, etc.) about our clients as we consider it necessary in order for us to provide our financial planning and investment management services to them. This information will relate to your personal and financial circumstances. 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.
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 you have the consent of the people concerned to pass their information on to us. We will be happy to 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 we collect about you is essential for us to be able to carry out the services you require from us. Without collecting your personal data we would also be unable to fulfil our legal and regulatory obligations in an effective manner. Where special category data is required we will obtain your explicit consent in order to collect and process this information.
How do we obtain personal data?
LWM obtains personal data about our clients only from clients themselves, with their consent, or from other organisations (such as product providers) from whom our clients have agreed that we may obtain information. We do not ‘buy’ information or data about clients or potential clients. Nor do we use social media to gather data, or use your location data if you access our website from your smartphone.
How do we look after personal data?
All personal data we hold is held securely – electronic data is protected by passwords/encryption and is backed up regularly; paper-based data is held in locked storage.
Who might we share your information with?
We will not share your information for marketing purposes with any companies outside LWM.
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 will have a contract in place with them to ensure the nature and purpose of the processing is clear, they are subject to a duty of confidence in processing your data and they will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit. Emails between LWM and our trading partner Raymond James use Transport Layer Security (TLS) encryption protocol to protect data in transit. This is forced between companies which means that emails will not be sent if a suitable encryption method cannot be found. Other insurance providers use secure email systems involving password protection.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we send your details to Raymond James who in use a tool managed by Lexis Nexis for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods.
These are, generally:
- Five years for investment 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 is in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 10 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
What are your rights?
You have the right at any time to request a copy of the personal information we hold about you. Should you wish to receive a copy of this, or would like to be removed from our database, please email or write to us at the contact details below.
You can verify the data we hold about you by contacting your adviser. Our security procedures mean we will request proof of identity before we reveal that information to you. You can also contact us at any time by the same method to change, correct, or delete your personal data controlled by us, or to update us on your details.
You are also free to close your relationship with us at any time. However, we may retain archived copies of your information as required by law or for legitimate business purposes (including helping to avoid fraud and spam).
What can you do if you are unhappy with how your personal data is processed?
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
How to contact us
Or write to us at:
London Wealth Management
22 Soho Square