Privacy Notice

ESJ Financial Planning LLP is committed to being transparent about how we collect and use personal data. This privacy notice explains how we use any personal information we collect about you.

What information do we collect about you?

We collect information about you when you engage us for financial planning services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data, such as confidential information about your health, if this is necessary for the provision of our Regulated Advice 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 that you have the consent of the people concerned to pass their information on to us. We will 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 effectively carry out the services that you require from us in relation to the provision of Financial Advice. Without collecting your personal data we would be unable to fulfil our legal and Regulatory obligations.

Where special category data is required we will obtain your explicit consent for us to collect and process this information.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage us, namely the provision of Regulated Financial Advice.

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. However we will not share your information for marketing purposes with other companies.

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/or Investment Platform Providers used to provide financial arrangements for you.

Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of their 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 our written instructions.

Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures such as password protection and/or encryption of documents to protect your personal data in transit.

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 any investment arrangements
• Indefinitely for any pension fund transfers and/or ‘opt-out’ elections
• Three years for insurance contracts

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.

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.

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 would like a copy of some or all of your personal information please email or write to us using the contact details noted below.

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.

Marketing

We do not carry out direct marketing to our clients although from time to time we will send you information which may be of interest to you. For example, we may make contact if you have engaged us for investment services to notify you of opportunities regarding your ISA Subscription before the end of a tax year.

You have a right at any time to stop us from contacting you for marketing purposes and should you chose to exercise your right, please contact us by email or post.

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

Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Changes to our privacy policy

We keep our privacy policy under regular review and we will inform you of any changes when they occur. This privacy policy was last updated on 4th February 2021.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you: by email at info@esjfinancial.co.uk.

Or write to us at:

ESJ Financial Planning LLP

Hildenbrook House
The Slade
Tonbridge
Kent
TN9 1HR