WEBSITE PRIVACY NOTICE AND TERMS OF USE.

Terms Of Use

Website usage terms and conditions

 

Welcome to our website. If you continue to browse and use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our privacy policy govern Sutton Brook’s relationship with you in relation to this website. If you disagree with any part of these terms and conditions, please do not use our website.

The term ‘Sutton Brook’ or ‘us’ or ‘we’ refers to the owner of the website whose registered office is SBC House, Restmor Way, Wallington, SM6 7AH. Our company registration number is 08834225 and place of registration is England. The term ‘you’ refers to the user or viewer of our website.

The use of this website is subject to the following terms of use:

 

  • The content of the pages of this website is for your general information and use only. It is subject to change without notice.

  • This website uses cookies to monitor browsing preferences. If you do allow cookies to be used, the following personal information may be stored by us for use by third parties: Google Analytics

  • Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information and materials found or offered on this website for any particular purpose. You acknowledge that such information and materials may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.

  • Your use of any information or materials on this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any products, services or information available through this website meet your specific requirements.

  • This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance and graphics. Reproduction is prohibited other than in accordance with the copyright notice, which forms part of these terms and conditions.

  • All trademarks reproduced in this website, which are not the property of, or licensed to the operator, are acknowledged on the website.

  • Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.

  • From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).

  • Your use of this website and any dispute arising out of such use of the website is subject to the laws of England, Northern Ireland, Scotland and Wales

WEBSITE PRIVACY POLICY AND COMPLAINTS PROCEDURES 

1. This Privacy Policy

1.1 The Independent Financial Adviser (“IFA”) referred to in the Contact section of this Web Site, is committed to protecting your personal information and other data provided to IFA via this and any other IFA web site (“Web Site”). Please read this Privacy Policy carefully as it contains important information about the use of any information you provide to IFA via this Web Site. This Privacy Policy explains what information IFA collects about you, and how IFA collects and uses your information, including setting out the circumstances where IFA could provide it to third parties. You should also read the separate IFA User Terms that are applicable to this Web Site. To view the User Terms click on the link shown below.

1.2 Because of the financial nature of IFA’s business, IFA’s products and services are not designed to appeal to or to be sold to persons under the age of 18. Therefore, IFA does not knowingly attempt to solicit or receive any information from children.

2. What information IFA collects and what does IFA do with it

2.1 To take advantage of some of the services offered via this Web Site you may be required to log on or register with the Web Site. IFA and any third parties who hosts or maintains this Web Site may need to collect information about you and your computer to enable you to do so. The information will be collected when you register with the Web Site or when you choose to use one of the services available via the Web Site.

2.2 IFA may use the information which it collects to personalise your experience on the Web Site, to help you to log-in in future, to continue to use the Web Site, and to help IFA select services or materials for inclusion on the Web Site which may be of interest to you. IFA may, from time to time, use your information to recommend other products or services to you. Occasionally, IFA may contact you by letter, telephone or e-mail to inform you about other products and services which may be of interest to you. To exercise your right to “opt out” of this service you should contact IFA via the link shown below.

2.3 IFA may use your information to notify you of news about IFA, changes to the Web Site, special events or new services that IFA thinks may interest you. If, at any time, you would rather not receive any such information, please either tick any relevant “opt-out” box on the page where you are asked to give your information or you may contact IFA via the link shown below. In these circumstances, IFA will need to keep your information on file so that you can continue to use the Web Site and so that IFA can deal with the administration and security of the Web Site, but IFA will not e-mail you or contact you by telephone, fax or post without your consent.

2.4 The nature of IFA’s business is such that IFA may on occasion ask you to provide sensitive personal data as defined in the Data Protection Act 1998 (for example, questions relating to your health where that information is required in order to provide life insurance quotations). Where IFA does so, IFA will request your explicit consent to the use of such sensitive personal data. Where you consent to provide IFA with this information IFA will take appropriate measures to protect such sensitive personal data.

2.5 IFA or third parties hosting servers on IFA’s behalf may also monitor traffic patterns and usage of the Web Site to help it to improve the Web Site design and layout.

2.6 Please note that IFA is not responsible for what any third party content provider or other third party offering goods and services via web sites linked to this Web Site may propose to do with information about you. So please ensure you read their terms and conditions carefully.

3. Sharing of Information with Third Parties

 

3.1 IFA will not disclose your personal information to third parties other than as described in this clause (unless it is legally required to do so). IFA may need to pass your information to third parties who help IFA to maintain, administer or develop the Web Site but, if so, that information is only given to those third parties for that limited purpose. In addition, IFA may provide aggregate statistics about its customers, sales, traffic patterns and related Web Site information to reputable third-parties, but these statistics will include no personally information.

3.2 IFA reserves the right to access and disclose personal data or information to comply with applicable laws and lawful government requests, to operate its systems properly, or to protect itself or its users.

4. Your Consent

 

4.1 You acknowledge and agree that:

 

4.1.1 in the course of registering or using this Web Site and any services offered via this Web Site, certain information about you will be captured electronically (including sensitive personal data where required, but this will be subject to you giving your explicit consent in such cases) or otherwise and transmitted to IFA or and, potentially, to any third parties as set out above, or to third parties who host IFA’s web servers or assist IFA in maintaining this Website; and

4.1.2 IFA may send your information outside of the European Economic Area for processing or use in accordance with this Privacy Policy.

4.2 By using this Web Site, you expressly agree to the collection and use of your information for the purposes set out in this Privacy Policy.

5. Contests and Competitions

 

From time-to-time IFA may request information from users for the purposes of running contests or competitions. Participation in these contests or competitions is completely voluntary and the user therefore has a choice regarding whether or not to disclose this information.

6. IFA’s Responsibilities – How does IFA protect user information?

 

As required by the Data Protection Act 1998, IFA follows strict security procedures in the storage and disclosure of information which you have provided via this Web Site, to prevent unauthorised access.

7. What are ‘Cookies’ and how does IFA use them?

 

7.1 A cookie is a piece of information that is stored on your computer’s hard drive by your Web browser. On visiting the Web Site, your computer server will use the cookie to guarantee a secure connection. Most browsers accept cookies automatically, but usually you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may not be able to use certain features of this Web Site.

7.2 IFA may conduct analyses of user traffic. These analyses will be performed through the use of IP addresses and cookies which are required to ensure a secure server connection. IFA does not use cookies to store any personal data or browsing habits.

7.3 Third parties such as advertising agencies and content providers may use cookies on this Web Site to collect personal information about you. IFA recommends that you read the privacy statement of any third party before using their web site. IFA is not responsible for the use of such cookies or any other ways in which your personal data may be collected or used by such third parties.

8. Changes to Privacy Policy

 

IFA reserves the right to add to or change the terms of this Privacy Policy in its sole discretion, without prior notice to you. If IFA changes this Privacy Policy, IFA will post the new Privacy Policy on the Web Site, and it will become effective from the time of posting to the Web Site. Please visit this Privacy Policy on a regular basis to make sure you have read the latest version and you understand what IFA does with your information. Wherever possible, IFA will give you notice of any changes prior to their implementation.

9. General

 

This Web Site contains links to other web sites. Please be aware that IFA cannot be held responsible for the privacy policies of such other sites. IFA encourages its users to be aware when they leave the Web Site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web Site.

10. Feedback

 

If you have any queries or problems with regard to this Privacy Policy or the uses to which IFA puts your information, please contact IFA via the link shown below.

 

Contact us on info@suttonbrookwm.co.uk if you have a question about our terms or policy.

 

 

Complaints

 

We’re sorry you’ve felt you need to complain but letting us know when you’re unhappy gives us the opportunity to put matters right for you and improve our service for everybody. Please contact us to let us know on info@suttonbrookwm.co.uk

For further information on how we can put things right, please click on the link to see our Complaints Brochure.

Website Privacy GDPR update 27.04.2018

PRIVACY NOTICE AND HOW WE COMPLY WITH GDPR 2018 AND DPA 2017

Sutton Brook Wealth Management understands its obligations in regards to your fundamental right to a private life and has implemented systems and controls to ensure your rights and freedoms are protected.

Sutton Brook Wealth Management undertakes to meet its obligations under the Data Protection Act, the Privacy and Electronic Communications Regulations and the EU General Data Protection Regulation (GDPR).

WHO WILL PROCESS YOUR PERSONAL INFORMATION?

Your personal information will be initially processed by Sutton Brook Wealth Management. Your personal data will be further processed by On-Line Partnership Group Limited on behalf of its subsidiary company The On-Line Partnership Limited who acts as our Principal for regulatory purposes. All parties will process your personal data in accordance with this privacy notice.

WHY IS YOUR PERSONAL INFORMATION REQUIRED?

Your personal information is required to enable us to take necessary steps at your request prior to entering into a contract and to perform such a contract. This may include reviewing assets and liabilities, bank account validation, identity and age verification checks, credit checks, preventing and detecting fraud, money laundering or other crimes and any other requirements in accordance with rules set by the Financial Conduct Authority (FCA) or other applicable legislation.

WHAT HAPPENS IF WE WANT TO PROCESS YOUR INFORMATION FOR OTHER REASONS?

Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about we will notify you.

WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION?

Your personal data is essential to enable us to take steps at your request prior to entering into a contract or to perform a contract to which you are a party. Without this information we will not be able to proceed to provide any financial service.

WHAT MAKES THE PROCESSING LAWFUL?

Because the processing is necessary:

  • For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;

  • for compliance with a legal obligation to which we are subject;

  • for the performance of a task carried out in the public interest;

  • for the purposes of the legitimate interests pursued by us.

KEEPING YOUR INFORMATION UP TO DATE

We will record your information exactly as you provide it. You may ask us to update it at any time and we will action your request promptly and where possible notify relevant third parties of any changes.

WHAT ABOUT SENSITIVE PERSONAL DATA?

Unless we are processing because it is necessary for reasons of substantial public interest, we will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific processing activities. In such cases you will be asked to sign a separate consent form to evidence this and that you understand the purpose(s) of the processing of such data. Your consent may be withdrawn at any time.

HOW WILL WE FURTHER USE YOUR PERSONAL INFORMATION (OUR LEGITIMATE INTERESTS)?

·         To contact you to ensure that our records of your personal information are correct;

·         To respond to questions or complaints you have about our services;

·         To update you with changes in our terms;

·         For statistical or research analysis relating to the performance of our business or that of our principal and understanding the changing needs of our clients;

·         To review, improve and develop services we offer or handle complaints;

·         To pursue debts or unpaid fees;

·         To evidence company practices;

·         To evidence the standards and processes carried out conform to the company’s ethical standards and expectations;

·         For direct marketing activities;

·         To protect the business from risks which might be introduced by an individual.

You have the right to object to processing for these purposes and we shall cease unless we can show we have compelling legitimate grounds to continue.

PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST

We will use the information provided to protect members of the public against dishonesty, money laundering or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group Plc or Creditsafe Business Solutions Ltd.

WHAT INFORMATION IS REQUIRED?

We only collect information that is necessary to carry out the purposes listed above. This includes information you supply and data we receive from reference agencies. Where practical and lawful we will inform you about any personal data we receive about you from third parties that you may be unaware of.

HOW SECURE WILL YOUR DATA BE?

We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security measures will be in place to prevent unauthorised access, alteration, disclosure, loss, damage or destruction of your information. If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding appropriate security measures in place and only process your information in the way we’ve authorised them to. These organisations won’t be entitled to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we’ve set.

WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?

We may share your information with:

·         Appropriate staff such as those who carry out financial or compliance functions.

·         Organisations that need your information because we are required to provide it by law (eg. The FCA, ombudsman services, HMRC etc).

·         Organisations that carry out credit references or identity checks such as GB Group Plc or CreditSafe Business Solutions Ltd. These organisations may keep a record of the information and may disclose the fact that a search of its records was made to its other customers for the purposes of assessing the risk of giving credit, to prevent fraud and to trace debtors.

·         Sometimes other authorised firms with specialist advisers, such as pension specialists, who assist us in providing suitable financial advice and services. You will be provided with their details if this applies.

·         Law enforcement agencies, courts or other public authorities if we have to, or are authorised to by law.

·         Product providers we use to provide financial services or for direct marketing (see below).

·         Where we or our Principal go through a business transaction, such as a merger, being acquired by another company or selling a portion of its assets, your information will, in most instances, be part of the assets transferred.

TRANSFERRING DATA OUTSIDE THE EUROPEAN UNION

We do not usually transfer any of your personal data outside of the EU except when we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies, like Creditsafe Business Solutions Ltd, may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases Creditsafe encrypts any data it sends to other agencies and only transfers information necessary to carry out checks.

(A list of countries used to perform checks include Germany, Netherland, Belgium, France, Sweden, Norway, Finland, Luxembourg, Switzerland, Liechtenstein, Spain, USA, Estonia, Latvia, Lithuania, Poland, Slovakia, Czech Republic, Hungary, Slovenia, Bosnia, Serbia, Montenegro, Croatia, Macedonia, Kosovo, Albania, Bulgaria, Romania, Ukraine, Austria, Denmark, Moldova, Portugal, Italy, Canada, Brazil, Greenland, China, India, Australia, Russia, South Korea, Taiwan, Mexico, South Africa, New Zealand, Hong Kong, UK.)

WHAT ABOUT DIRECT MARKETING?

We will use the information provided now and in the future to carry out direct marketing activities as these are legitimate interests pursued by us. Sometimes this includes, with your consent, sharing data with product providers for their marketing activities. You can choose which method you’d prefer us to use to contact you (by email, telephone, SMS or post) and you have the right to object at any time to the use of your personal data for this purpose and we will cease marketing activity. Just let the person who gave you this form know about your preferences.

AUTOMATED DECISION-MAKING PROCESSES

We sometimes use automated processes when making decisions but you will not be subject to a decision based solely on automated processing, including profiling.

TELEPHONE CALL RECORDING

In line with The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 we may record incoming or outgoing telephone conversations for the following purposes:

·         Establishing facts and evidence for business transactions;

·         Ensuring compliance with regulatory or self-regulatory practices;

·         Ascertaining and demonstrating that standards are being met;

·         Preventing or detecting crime;

·         Investigating or detecting the unauthorised use of that or any other telecommunication system;

·         Safeguarding the effective operation of the telecommunications system.

HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

The Financial Conduct Authority lays down rules relating to how long information should be held for and we will keep your information to meet these requirements. We will not keep your information for longer than is necessary.

REQUESTING A COPY OF THE INFORMATION WE HOLD

You may at any time ask for a copy of the information we hold about you – it is your legal right. We will provide you with a copy of any non-exempt personal information within one month unless we ask you for an extension of time. To protect your personal data, we will ask you to verify your identity before we release any information. We may refuse your request if we are unable to confirm your identity.

IMPORTANT RIGHTS

You have the right, on grounds relating to your situation, at any time to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. We will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defence of legal claims.

You have the right to object at any time to processing your personal data for marketing activities. In such a case we must stop processing for this purpose.

WHAT ARE YOUR OTHER LEGAL RIGHTS?

In addition to the rights above the additional following rights:

·         Where you have given consent, you have the right to withdraw previous consent to processing your personal data at any time;

·         You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning your data;

·         You have the right to receive data you have provided to us in a structured, commonly used and machine readable format;

·         You have the right to lodge a complaint with the regulator (see below).

To exercise any of these rights please contact us (details below).

How our Principal Firm Ensures We Comply With the GDPR and DPA 2017

With forthcoming European legislation coming into effect and the passage of an additional UK data protection Bill through Parliament, this paper highlights what we and our Principal are undertaking in readiness for new requirements, ensuring that we can demonstrate compliance and protect the rights, freedoms and interests of data subjects. At the end of the paper, there is a section providing the contact details of our Principal’s Data Protection Officer should you have any further questions.

Compliance Audit Visits

Our Principal firm carries out on-site compliance audit checks which specifically focus on areas such as data protection. We have to ensure that we have technical and organisational measures in place which are appropriate to meet the risk posed by the type of data we process, or by the process itself. Our contract stipulates that we must comply with all relevant data protection legislation, and sanctions can be raised if we fail to adhere to these expectations.

Personal Data is Processed Securely by our Principal

Given that we input client personal data into our Principal’s systems, security measures have been deployed to transfer, process, encrypt and store data. Connection to the Principal’s website is via a TLS 1.2 secure connection.

Forthcoming GDPR and UK Legislation Module

Whilst the GDPR has already been written into UK law, it will officially apply from 25th May 2018. In order to demonstrate compliance, understand the risks associated with processing, and produce its GDPR Article 30 document of processing activities, each firm will undertake an online audit and submission of its data protection processes.

This will include detail of:

·         Policies adopted.

·         Organisational and technical measures implemented.

·         Processes of activities carried out.

·         Types of data processed.

·         Categories of data subject.

·         Source and format of the data.

·         How the accuracy of data is maintained.

·         The legal basis for each processing activity.

·         Automated decision making processes and safeguards.

·         Third party processors and compliant contracts.

·         Transfers to third countries.

·         How data is stored and what determines the length of storage.

·         Risks associated with specific processing and the actual mitigation in place to reduce crystallisation of the risk.

Client Agreements and Privacy Notices

Our current client agreements and privacy notices are being revised by our Principal in accordance with GDPR Articles 13 and 14.

Evidence of Explicit Consent

Consent by the data subject is freely given, specific, informed and unambiguous and can be easily withdrawn.

GDPR Article 9 Processing Special Categories of Personal Data

Processing special categories of personal data is undertaken only where the law allows. Such data includes:

·         Personal data revealing racial or ethnic origin.

·         Personal data revealing political opinions.

·         Personal data revealing religious or philosophical beliefs.

·         Personal data revealing trade union membership or non-membership.

·         Personal data relating to inherited or acquired genetic characteristics.

·         Biometric data for the purpose of uniquely identifying a natural person.

·         Personal data concerning health.

·         Personal data concerning a person’s sex life or sexual orientation.

GDPR Article 10 Criminal Conviction Data

Processing personal data concerning criminal convictions is undertaken only where the law allows.

 

GDPR Article 8 Processing Children’s Personal Data

Consent is obtained from the holder of parental responsibility before processing the personal data of children under the age of 16.

Further New Data Subject Rights

GDPR Article 15 Data Subject Access Rights:

Our Principal handles all subject access requests and has, to date, delivered all requests within time constraints. The forthcoming legislation does reduce time limits to one calendar month with an option to request an extension, and it is expected that these new time limits will be met without serious impact on the business. In most cases there will now not be a charge for subject access requests.

Furthermore, the following rights are being incorporated into our Principal’s systems, and will form part of forthcoming policies and privacy notices:

·         The right to be informed – providing statutory information via privacy notices (Articles 12-13, GDPR).

·         The right of access to personal data (Article 15, GDPR, see above).

·         The right to rectification of personal data (Article 16, GDPR).

·         The right to erasure of personal data (Article 17, GDPR).

·         The right to restriction of processing (Article 18, GDPR).

·         The right to data portability – receiving personal data in a standard format or to have it transmitted to another data controller (Article 20, GDPR).

·         The right to object to processing, including direct marketing (Article 21, GDPR).

·         The right not to be subject to decisions based solely on automated processing (Article 22, GDPR).

Technical and Organisational Measures

Appropriate technical and organisational measures, including policies, have been implemented and are regularly reviewed;           (GDPR Article 24).

Data Protection is Implemented by Design and Default

Consideration to data protection is given before new processes are implemented or personal data is collected; (GDPR Article 25).

Data Protection Impact Assessments

GDPR Article 35 introduces a requirement to carry out a data protection impact assessment under certain circumstances. Our Principal will be making an online form available for us to record such assessments, where we can evidence that due regard is given to the risk associated with processing operations.

Third Party Processors

When engaging the services of another party to process data, an appropriate written contract protecting the rights and freedoms of data subjects is always put in place before any data transfer, in line with GDPR Article 28.

Transfers to Countries Outside the UK

Our Principal’s forthcoming policy states:

”Data will not be transferred to countries outside the European Economic Area unless:

·         The law allows us to because there are adequacy decisions, appropriate safeguards or binding corporate rules as detailed in Articles 45-47, or;

·         We have the explicit informed consent of the individual and we have informed them of the risks, or;

·         The transfer is necessary to  perform a contract between us and the data subject, or;

·         The transfer is necessary to implement pre-contractual measures at the data subject’s request, or;

·         The transfer is necessary to  perform or conclude a contract in the data subject’s interest where the contract is between us and a third party, or;

·         The transfer is necessary for important reasons of public interest, or;

·         The transfer is necessary for the establishment, exercise or defence of legal claims, or;

·         Another reason permitted by law.

When such transfers must take place, we will document the reasons and legal basis for doing so.

We will take particular care to be aware of this when publishing information on our website/s, which can be accessed from anywhere in the globe. This is because the transfer includes placing data on a website that can be accessed from outside the European Economic Area. Access to the organisation’s website from certain countries has been automatically barred.

We will pay particular regard to any request for information that contains personal data where the request has come from any of our parent undertakings.”

Resource Centre

The online GDPR module will contain the following resources:

·         Industry relevant training in bite-sized chunks.

·         A DPO blog.

·         Links to relevant articles.

·         Examples of documents, policies and forms.

·         A GDPR search and lookup form.

Breach Register and Reporting

In accordance with GDPR Articles 33 and 34, data breaches will be reported to the regulator and those which pose a high risk will be reported to the data subject. In addition to the GDPR requirements, other medium or low risks may be also reported to the data subject to promote transparency and fairness in processing, and to demonstrate a firm’s ability to detect breaches and mitigate risk.

Our Principal will require us to submit breaches to their online breach register so that they may review and audit our processes, offer advice, or reaffirm good practice.

The Data Protection Bill 2017-2019 (aka The Data Protection Act 2017)

Our Principal is monitoring the passage of the Bill through Parliament and has noted in particular the following additions to the GDPR:

1.       When processing sensitive data in the realms of employment law or substantial public interest:

·      There must be a written policy document which explains procedures in place for securing compliance with Article 5 of the GDPR when processing this data, and this must be reviewed.

·      The policy must also explain the Company rules regarding the retention and erasure of this data and gives an indication of how long such data is likely to be retained.

·      The policy document must be retained for 6 months after processing stops and be made available to the regulator.

(Processing in the substantial public interest includes preventing dishonesty, preventing / detecting unlawful acts, equal opportunity monitoring, and preventing fraud, suspicion of terrorism or money laundering).

2.         Criminal offences and unlimited fines of persons for:

·      Re-identifying de-identified data.

·      Processing re-identified data.

·      Preventing disclosure for a SAR request or data portability request.

3.         Punishment for directors, officers or managers whose consent or negligence causes a corporate body to commit an offence under the GDPR.

4.         Requirement to include additional information in the Article 30 document regarding the processing of sensitive data in (1) above.

5.         Compensation is introduced for all other data protection legislation breaches under this Act and not just the GDPR.

Contact Our Principal’s Data Protection Officer

Our Principal’s Data Protection Officer is involved properly and in a timely manner in all issues which relate to data protection. CIPM and CIPP/E qualified, the DPO is available for contact using the details below:

·         In writing:

The Data Protection Officer,

In Partnership Financial Advisers Ltd,

On-Line House, 50-56 North Street,

Horsham, West Sussex, RH12 1RD

·         Telephone:

01403 214200

·         Email:

dpo@inpartnership.net

We Comply With the GDPR and DPA 2017