All Saints Disclosure Document. – click here
SCHEDULE (3) – GDPR
‘GDPR’ stands for ‘General Data Protection Regulation’ which came into force in May 2018. This new EU regulation is an extension of the existing regime, and introduces new protections for our clients, so we have adopted its standards in advance of the implementation date.
(A) Our Firm’s Policy
All Saints Financial hold personal client data safely and securely for the following specific objectives:
- Compliance with the FCA’s ‘Know Your Client’ regulations
- Compliance with the Anti-Money Laundering regulations
- Conducting the kinds of diagnostic computations which allow us to prescribe targeted financial solutions which match the client’s needs
- To assist in selecting the most appropriate products on the open market
- To support our ongoing annual review process
- To ensure that accurate information is conveyed to authorised third-parties, on the client’s behalf, for transactional purposes
These six objectives frame the types of data that we work with, as well as the extent of the information that we will request from you.
(B) Your Rights
- All Saints Financial will not hold or process your personal data without first obtaining your written consent to gain, maintain and process your personal data – in practice, we achieve this via this ‘Retail Client Agreement’ which you must sign to confirm that you are happy for us to proceed.
- We will be always be explicit with you as to the rationale underpinning our use of client data (as outlined in section A above).
- Clients of All Saints Financial have the following rights:
- The right to be informed about the data that we hold about you – this requires the effective use of the ‘FactFind’ (a formal summary of your financial data);
- The right to have errors in your data rectified, upon request – in practice, we invite this participation, be sending you a copy of our FactFind, and asking you to confirm its accuracy.
- The right to have your data erased, unless so doing would interfere with our own statutory responsibilities under FCA regulation. In practice, if we have provided regulated services to you, this would involve your data being archived, rather than erased.
- The right to restrict the data All Saints Financial have available to work from – which in practice may well prevent us from doing our job properly. We will confirm to you if such restrictions would prevent us from delivering a satisfactory service.
- The right to obtain and re-use your personal data, for your own purposes – this could apply if you are resigning as a client of our firm and moving to a new Adviser.
(C) Our Process in Holding Your Data
- Initial meeting – in our introductory discussion, we will usually take some written notes in order to have a record of the main points. If you decide not to proceed any further with the advice process, this information will then be destroyed.
- FactFinding exercise – by this stage, you will have signed our RCA to confirm that you wish us to act for you, and we therefore confirm that this financial information will be held permanently and securely in order for us to discharge our regulated advisory service. You may view a copy of this information at any time – and we will, in any case, be sending you a copy of the ‘FactFind’ for you to verify that the data we retain is accurate.
- Currency of information – we confirm that we will actively seek to maintain and update any financial data that we hold about you, so long as you remain a client of All Saints Financial.
- Diagnostics and research – we use systems to help us interpret your financial data (CashCalc or Voyant) and confirm that the printed output from these systems will reflect the extent and quality of the information that we hold about you, allowing you to verify its accuracy at any stage.
- To be absolutely clear, if you refuse to share financial data with us, we will withdraw from the provision of advice, as the non-cooperation prevents us from safely supplying a regulated service. We will only ever ask for information which is entirely relevant to the objectives of a given financial planning assignment.
- Client data will at all times be subject to internal checks and balances designed to maximise security.