Blackstone Moregate may hold personal data about you. Also, during the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your financial planning needs in the areas of Pensions, Investments, Inheritance Tax Planning, Protection and Mortgages and other financial matters requirements Your Personal Data may include:
When we speak with you about your financial planning needs in the areas of Pensions, Investments, Inheritance Tax Planning, Protection and Mortgages and other financial matters requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
Where you ask us to assist you with for example your insurance / ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance / investment providers in relation to insurance products that may meet your needs and to provide you with advice/guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Statement.
Information on Special Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to financial planning needs in the areas of Pensions, Investments, Inheritance Tax Planning, Protection and Mortgages and other financial matters. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
In the course of handling Your Personal Data, we will:
From time to time Your Personal Data will be shared with:
In each case, your Personal Data will only be shared for the purposes set out in this Privacy Statement, i.e. to progress your financial planning needs in the areas of Pensions, Investments, Inheritance Tax Planning, Protection and Mortgages and other financial matters enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Privacy Statement.
As required by data protection legislation, we have strict security procedures regarding the processing and disclosure of personal data. The personal data that is collected about you may be processed in one or more countries outside the European Economic Area (EEA) which has not yet been deemed by the European Commission to offer adequate data protection. It may also be processed by staff operating outside the EEA who work for Blackstone Moregate or for third parties. In such cases, we have taken steps to ensure an adequate level of data protection in the recipient country as required under GDPR, and as described above under retention of personal data. Where we outsource, all data processing and analytics are conducted within the framework provided by us, and within our infrastructure.
If there were circumstances where we could not ensure such an adequate level of data protection, your personal data will not be transferred outside the EEA.
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it, please contact:
Blackstone Moregate Limited
Suite 2 Courtyard Offices
Essex CM8 3GA
t: 020 3376 1444 ext 201
f: 4420 3761 1916
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible if you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.