The purpose of this Notice
This Privacy Notice explains how we use any personal information we collect about you.
SR Finance and its Appointed Representative takes the privacy and security of your personal information very seriously. In this notice, "we", "us" or "our" means the SR Finance and Sands Financial Management Ltd entity that processes your personal information and interacts with you. These entities are listed below. We are committed to protecting and respecting your privacy.
Under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), we are required to give you certain information about the way your personal information is used.
This notice (together with our Statutory disclosures and any other documents referred to in it) (“Privacy Notice”) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us.
The relevant entities referred to above are:
SR Finance Ltd (a company registered in England and Wales under company number 9017107, whose registered office is at 6-7 Castle Street, Hertford, Hertfordshire, SG14 1HD.
Sands Financial Management Ltd (a company registered in England and Wales under company number 9243208, whose registered office is at 6-7 Castle Street, Hertford, Hertfordshire, SG14 1HD.
The above stated entities are the data controllers/processors of the personal information we hold about you.
What information do we collect about you?
We collect information about you when you engage us for financial services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our 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?
Your personal information will be used for the purposes of providing financial advice and the administration and processing of applications. Under data protection law, we can only use your personal information if we have a lawful reason for doing so. A lawful reason could be when we have:
- your consent
- it is necessary to enter into or perform a contract
- it is necessary to comply with a legal obligation
- when it is in our legitimate interests.
Where we rely on our legitimate interests, we mean our:
- pursuit of our commercial activities and objectives, or those of a third party
- compliance with applicable legal and regulatory obligations and any codes of conduct
- improvement and development of our business operations and service offering, or those of a third party
- protection of our business, employees and clients, or those of a third party.
We have set out our reasons for using your personal information in the table below under the heading Legal Basis. Where we rely on our legitimate interests, we have set out those interests in the table on the page below.
|To provide you with any services and/or information you request from us (which includes carrying out any obligations arising from any contracts entered into between you and us).||To fulfil our contractual obligations.|
|To comply with any instructions, you give to us.||To fulfil our contractual obligations.|
|To notify you about changes to our service.||It is in our legitimate interests to use your personal information for this purpose.|
|To provide you with information by post, email, telephone or otherwise about products and services of a similar nature to those you have previously purchased or expressed an interest in which are offered by our firm and which we think may be of interest to you.||We rely on your consent to send you these communications.|
|To administer our website and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes.||It is in our legitimate interests to use your personal information for this purpose.|
|To improve our website to ensure that content is presented in the most effective manner for you and for your computer.||It is in our legitimate interests to use your personal information for this purpose.|
|To measure or understand the effectiveness of content we serve to you and others, and to deliver relevant content to you.||It is in our legitimate interests to use your personal information for this purpose.|
|To deliver targeted marketing to you, where consent has been given to do so.||We rely on your consent to carry out this marketing.|
|As part of our efforts to keep our website safe and secure and to prevent and detect money laundering, financial crime and other crime.||Comply with our legal obligations|
|To prevent and detect fraud, including to share your personal information with Fraud Prevention Agencies for this purpose.||It is in our legitimate interests to use your personal information for this purpose.
This may in some circumstances be necessary for us to comply with our legal obligations.
Who we share your information with?
For the purposes set out above, we may share your information with selected third parties including:
- our partners, such as:
- True Potential LLP (back office, client portal and compliance services)
- Paradigm Consulting (compliance Services)
- governmental or judicial bodies or agencies such as:
- HM Revenue & Customs
- Financial Conduct Authority
- UK Financial Services Compensation Scheme
- other regulatory bodies and authorities
- fraud and anti-money laundering prevention agencies, other companies and organisations to prevent or detect financial and other crime such as:
- National Crime Agency (NCA)
- Credit Safe
- data, service and software providers that assist us in the improvement and optimisation of our website
- any party linked with you or your business’s product or service
- companies we have a joint venture or agreement to co-operate with
- organisations that introduce you to us
- companies you ask us to share your data with.
Safeguarding your personal information
Keeping your personal information safe is very important to us so we will take all steps necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice and applicable data protection legislation.
Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access.
Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit, such as password protection and/or encryption of data.
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 investment business
• Indefinitely for pension transfers and opt-outs
• Three years for mortgage and 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 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.
We would like to send you information about our products and services which may be of interest to you. If you have 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. If you no longer wish to be contacted for marketing purposes, please contact us by email or post or update your General Data Protection Regulation Options within the client portal.
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
0303 123 1113 (local rate)
How to contact us
Data Protection Officer: Deborah O’Hare
Sands Financial Management Ltd
Ground Floor, Unit 1
Arlington Business Park
Whittle Way, Stevenage