Moore Scarrott Privacy Statement

Our Privacy Policy

This privacy policy (“Privacy Policy”) applies to the information we collect about you and/or your business when you use our services, or otherwise interact with us (for example, by collection of your information via our website or social media), unless a different policy is displayed.
This privacy policy explains how we use any personal information we collect about you and/or your business.
This Privacy Policy has been drafted in accordance with regulatory and General Data Protection Regulation, adopted on the 25th May 2018 in line with the minimum requirements for the collection of data on-line within the European Union and also represents information statement to the data subjects according to the European Union privacy law rules and principles (the “Privacy Law”), with which the processing carried out by Moore Scarrott Financial Planning Limited complies.
The Privacy Policy specifies the identity of the data Controller that controls and manages the personal data collected and processed, specifies what is the personal information collected, the data processing purposes and conditions, the extent of personal data communication to third parties, the data security measures adopted in order to protect and safeguard data and the ways in which you may verify the processing of data relating to you and enforce your rights as recognised under the Privacy Law.

The purpose of this Policy

When we provide our services to you, we will collect personal information about you (and others) and we want to be open and transparent with you as to the types of information we collect about you, why we collect it, how we use it and who we may share it with.

Who controls the processing of my personal data? Who is accountable for it?

The data controller of your personal information is Moore Scarrott Financial Planning Limited, (MSFP), a limited company registered at Calyx House, South Road, Taunton, Somerset TA1 3DU with company number 07879893.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this policy in the ‘How to contact us’ section.
Moore Scarrott Financial Planning Limited is the sole owner of the information collected throughout your client journey, or on www.ms-fp.com . Moore Scarrott Financial Planning Limited collects information from our clients at several different points in your client journey or via the enquiry form on our Website.
Your personal data may be collected and processed by Moore Scarrott Financial Planning Limited when you engage with us as a client or interact with the functionalities offered by our Website.

What information do we collect about you and why?

We collect information about you and/or your business when you request us to provide you with quotes for our services and engage us for personal financial planning; corporate financial planning, financial advice, investment management services; group benefits and workplace pension advice.
This information will relate to your personal/business and financial circumstances.
We may ask you to provide personal information by completing hard copy forms and documents or by corresponding with us by telephone, e-mail, letter or otherwise or during the course of our meetings with you.

Types of personal information
Why we collect it
Identity details including your name and date of birth.We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address.
  • To carry out money laundering and financial checks and for fraud and crime prevention and detection purposes.
  • We will only ever use copies of identity documents for this purpose.
  • We collect and process this personal information in order to comply with our legal and regulatory requirements.
Your contact details including your name, postal, phone and email address(es) and other personal details about you including your title, job title, marital status and date of birth.
  • To contact you in order for us to manage, administer and provide our services to you.
  • To respond to any correspondence and service-related enquiries you send to us in respect of our services.
  • To discuss products or services for which you apply or may be interested in applying for.
  • To manage any applications you make for products or services.
  • To communicate any updates to you including any changes to our services, the terms and conditions of any services
  • which we have provided to you, any changes to this Notice and to our websites.
  • To contact you in order to receive your feedback on our services and to participate in related surveys.
Financial information relating to you, including pension contributions and current value, salary, bank account balances; credit card balances details of investments and bank payment card details.
  • To evaluate your eligibility for products, including making credit searches with credit reference agencies and fraud searches with fraud prevention agencies.
  • To enable us to advise you on your financial circumstances and the appropriateness of specific courses of action and products.
  • We collect and process this personal information for our legitimate business interests.
  • To enable you to make payments for our services.
  • We collect and process this personal information as is necessary for the entry into and performance of any agreements between us (i.e. to assess whether you are eligible for products, and once an agreement has been entered into between you and us, so that we can collect payments from your bank payment card).
Details of your dependents (name, address and date of birth)
  • To enable us to provide you with services that you have requested that would involve, or have an impact on, your dependents (who may be adults or minors). Where those dependents are adults, please make sure that you have their permission to provide us with their personal information.
Details of contact that we have had with you such as meetings with you, fact-finding discussions and documentation, recommendations, referrals and quotes.
  • To allow us to provide a professional service to you and to contact you with information about other services of ours that we think you may be interested in).
  • We collect and process this personal information for our legitimate business interests.
Details of services you have received.
  • To allow us to provide a professional service to you and to contact you with information about other services of ours that we think you may be interested in).
  • We collect and process this personal information for our legitimate business interests.
Client experience and other feedback and information you provide to us.
To review your feedback and experience with us so that we can improve our products and services for you and for our other clients
Information about complaints and incidents.
To review your feedback and experience with us so that we can improve our products and services for you and for our other clients
All of the personal information described above.
  • We may disclose your personal information to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a Court Order, regulatory authority or any other third party with the lawful right to request and receive the personal information we hold about you (including law enforcement agencies and tax authorities).
  • We may also use your personal information where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties.

  • We collect and process this personal information for our legitimate business interests including to carry out our own internal business planning, compliance, training, audit and quality assurance purposes.

Depending upon the types of products and services you require, we may also need to collect information from and about you which the law considers to be sensitive, such as data about your physical or mental health, which we refer to as “special category personal data”. The special category personal data that we may ask you to provide, and the reasons why we ask you to provide it, are as follows:

Types of special category personal data
Why we collect it
Information about your physical or mental health or condition
Certain products and services that you request may require this information. Specifically, in order for us to advise you on and to submit applications for health or life insurance products and services, we will need to collect information relating to your physical and mental health in order to obtain accurate quotes and to advise on the suitability of products (as insurance premiums and eligibility for products will in part depend on your physical and mental health). We will usually collect this information in the course of meetings with you, on specific questionnaires or in the process of completing an application form for such products and services.
Information about your sex life or sexual orientation.
Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.
Information about your racial or ethnic origin
Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.

We will only process the special category personal data listed above with your explicit consent. We ask for your consent to the processing of this data by signing our Privacy Statement. You may choose not to provide us with this consent. However, please note that if you do not provide us with your consent to collect and process the information listed in the table above:

  • we may not be able to advise you fully in respect of certain products and services which require this information; in particular those relating to health or life insurance, retirement planning and estate planning;
  • your application may be rejected by the providers of products and services which require this information; or
  • the quotes for such products and services may be higher than would be the case if this information were provided.

In some circumstances, we may receive information about you from third parties. In particular, we will receive information about you from Credit Reference Agencies and Fraud Prevention Agencies. This may include details of the products and services you have applied for, those lenders, finance and credit organisations with whom you have (and have had) an agreement with, the amounts advanced, the amount and frequency of repayments and whether you have made your repayments on time and in full. This will help us make the best possible assessment of your financial situation before we decide whether we can provide you with our services and/or recommend any specific products and services. It is in our legitimate interests to process your personal information for this purpose. We may also ask you to provide Letters of Authority to allow us to receive information about you from providers.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.
We try at all times to keep at all personal data collected and processed accurate and up-to-date. We check the accuracy of data when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken to amend or erase that data, as appropriate.

Information about connected individuals or employees

Corporate Clients

We may need to gather personal information about your employees in order to provide our service to you effectively. In such cases we will seek acceptance of these terms from an authorised individual with the business and if necessary offer guidance to ensure that the business has the consent of the people concerned to pass their information on to us. We’ll make available a copy of our privacy policy for them or, where appropriate, ask you to pass our privacy information to them through your own communication channels.

Personal Clients:

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’ll provide a copy of this privacy policy 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 carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.

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. This may be part of our contract with you in relation to ongoing advice services.
We use tools supplied by 3rd parties for profiling customers and agreements are in place to protect your data in accordance with data protection laws and policies.
We won’t share your information for marketing purposes with companies outside any of the Moore Scarrott businesses or 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 platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
A full list of the recipients who we may disclose your personal information with is summarised below:

  • to providers of financial services, insurance and investment products and services in respect of whom you request us to submit applications on your behalf and to receive updates from such providers in order for us to provide our services to you throughout the lifetime of our relationship with you;
  • to our suppliers and partners in order for them to help us provide our services to you, this includes:
    ○ our IT systems providers to assist us with providing you with an efficient, modern and professional service;
    ○ our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements;
    ○ our accountants, solicitors, insurer(s) and insurance broker(s) and any other provider of professional services to us;
  • to other financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;
  • to Moore Scarrott Partnership LLP and its associated business for the purpose of professional services and referrals to and from these businesses;
  • to a prospective buyer (and its agents and advisers) in the event we intend to sell any part of our business or its assets or if substantially all of our assets are acquired by a third party, in which case your personal information could form part of one of the assets we sell, provided that we inform the buyer it must use your personal information only for the purposes described in this Notice. We will never rent or sell your personal information other than as part of a sale of our business;
  • to any national and/or international regulatory, enforcement body, government agency or court where we believe disclosure is necessary
    as a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC),
    to exercise, establish or defend our legal rights, or
    to protect your vital interests of those of any other person; and
  • to any other person with your consent to the disclosure or where we are permitted to do so by law.

How long do we keep hold of your information?

During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll 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-outs
  • 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’s in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than necessary after our relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
In relation to our Website, we ask for information from the user on our enquiry form. Information gathered through this form will be held in compliance with our Data Protection Policy and may be used periodically to assist in the various marketing activities of Moore Scarrott Financial Planning Limited, but primarily to provide the necessary permission for us to contact you.

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’d like a copy of some or all of your personal information, please email or write to us using the contact details noted below. You may make a subject access request (“SAR”) at any time to find out more about the personal data which we hold about you. We are usually required to respond to SARs within one month of receipt (this can be extended by up to two months or possibly in the case of complex and/or numerous requests, and in such cases the data subject shall be informed of the need for the extension). To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
All subject access requests must be sent to our Compliance Director: paul.cuff@ms-fp.com .
We do not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive. Where a fee is necessary, we will inform you before proceeding with your request.

Your data protection rights

You also have the following rights in respect of your personal data:

  • The right to be informed of the processing;
  • The right to rectification;
  • The right of erasure;
  • The right to restrict processing;
  • The right of data portability;
  • The right to object to processing;
  • The right to understand automated decision making and profiling.

We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others or, if we are otherwise legally entitled to deal with the request in a different way.

To access personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify / erase personal data

You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information) or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our regulatory or legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.

To restrict our use of personal data

You can ask that we restrict our use of your personal data in certain circumstances, for example:

  • where you think the information is inaccurate and we need to verify it;
  • where our use of your personal data is not lawful but you do not want us to erase it;
  • where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
  • where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company, or to meet regulatory requirements.

To object to use of personal data

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).
You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
If you would like to exercise any of your rights, please:

  • email or write to our Compliance Director at paul.cuff@ms-fp.com or Moore Scarrott Financial Planning Limited, Calyx House, South Road, Taunton, Somerset TA1 3DU
  • let us have enough information to identify you, e.g. name, address, date of birth
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
  • let us know the information to which your request relates.

If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. For specific information about our processing of your sensitive category personal data with your consent, please see the “Your consent to us processing your special category personal data” heading below.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

For more details on how to exercise these rights please contact us.

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.

International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). Specifically, our servers are located in the UK.

Marketing

We’d like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

Does this website use cookies? What are they for?

We use cookies to track visitor use of the website and to compile statistical reports on website activity. Our cookies do not run programs on users’ device nor upload viruses on it, and that do not allow any kind of control over the device.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Please click here to accept cookies on this website
Once you have accepted the use of cookies on the Site, your preferences stored in the form of a cookie for your future visits to the Site for as long as you do not remove the cookies stored on your device.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You 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
0303 123 1113 (local rate)
For more information outside of the UK, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available at:

http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll place any updates on this web page when they occur. This privacy policy was last updated on 23/05/2018.

Business Transitions

In the event Moore Scarrott Financial Planning Limited goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users’ personal information will, in most instances, be part of the assets transferred. If as a result of the business transition, the users’ personally identifiable information will be used in a manner different from that stated at the time of collection they will be given choice consistent with our notification of changes section.

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@ms-fp.com

Or write to us at Moore Scarrott Financial Planning Limited Ltd, Calyx House, South Road, Taunton, Somerset TA1 3DU.