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Privacy Policy

Partners Wealth Management is aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to processing your data securely and transparently.  This privacy notice sets out, in line with GDPR, the types of data that we hold on you. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

In this policy we refer to ourselves as “PWM” and or “we”.

Who we are

This is the privacy policy of Partners Wealth Management, 20 St Andrew Street, London, EC4A 3AG, telephone 020 7444 4030, email info@pwmllp.co.uk. Our business is the provision of financial planning and investment advice and in our engagement with clients and prospective clients we will hold your personal information.  We set out below important information about our processing of data relating to living individuals and reference to the purposes for which we do so in the context of our business.

The information we collect

So we can provide you with a service that meets your precise financial goals and needs we obtain certain information about your personal and financial situation and may collect the following information:

  • Identity details: Such as your name, age, date of birth, gender and national insurance number
  • Personal and Professional Contact details: This includes your address, email, phone number and mobile number
  • Personal financial information:
    • Employment details
    • Family details
    • Information regarding your current health condition
    • Associated third party information, this includes your spouse, children or beneficiaries of trusts
    • Financial details, this includes source of wealth, existing investments, tax returns, and bank details
  • Details concerning your attitude to investment risk. This is collected via the completion of a questionnaire with guidance from our Advisers
  • Lifestyle information (such as hobbies and interests)
  • Account activity. This information is generated and collected through the provision of our services to you through third party providers
  • Information on your children and dependants: Where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
  • Internal Protocol (IP) address: This information is collected passively when you use our website or client portal
  • Use of our website: This information is collected through cookies as further explained in our Cookies Policy

We may be provided with the information listed above by:

  • Your relatives and other mutual contacts
  • Your parent(s) or legal guardian in relation to minors
  • Trustees of a trust you are connected with, and
  • Trust beneficiaries
  • Your registered agent or introducer

How and why we use this information

We have published this policy so that you understand what we do and why, and in order that, if you wish to challenge us, you have information about your rights.  This policy is not detailed with respect to all aspects of our processing of personal data because so much depends on your needs and individual circumstances.  We have given as much information as we can by way of default, and we supplement this where appropriate in other documentation.

The purposes are as follows:

  1. Marketing to you as a prospective client
  2. Welcoming you as a client
  3. Dealing with you as a client
  4. Performing our services to clients which involve processing personal data about others associated with them, such as a spouse, parent, guardian, child, other family member, a representative of our client, or a trustee, settlor or beneficiary
  5. Operating our business

We have included sections dedicated to describing your rights, our contact information generally and how you can make a complaint.

  1. Marketing to you as a prospective client

We take pride in our business which has been built on reputation through providing excellent service resulting in many personal introductions. However, we do continue to attract new clients through marketing our services to existing and potential clients.

The marketing we use to attract potential clients bring us directly and indirectly into contact with them.  We are not intrusive and always respect the wishes of individuals once we are aware of them and have introduced a PWM Preference Service to comply with GDPR requirements, enabling prospective and existing clients to confirm their marketing preferences:

  • Communicate directly with you via telephone, e-mail, and other forms of electronic communication
  • Send you materials about our business, marketing commentary and information relating to investments
  1. Welcoming you as a client

Where we agree to work together there are initial steps we need to take before we enter into a contract with you.  The process of welcoming you as a client has two main parts:

  • Compliance requirement to satisfy our legal obligations for us to know our clients and to prevent money laundering and terrorism financing; and
  • Obtaining the information we need from you to provide advice and our services

Verification documentation: This is collected from you to assist us with verifying your identity and contact details. We need to verify this information to fulfil our legal obligations, and for this purpose we occasionally use public and privately available electronic information sources (we may use third party credit and identity check agencies for this purpose).

  1. Our dealings with you as a client

Once you have entered into a service agreement with us, we are able to act for you and carry out your instructions. However, we are also under legal obligations to:

  • Know our clients and to prevent money laundering and terrorism financing
  • To monitor changes in our relationship with you and your affairs

Thus, from time to time we are required to repeat the steps we take when welcoming you as a client, and the same considerations apply in relation to the processing of personal data relating to you.

The nature of the information we need to provide our services depends on your instructions.  Our requirements are reflected in the forms we ask you or others to fill in, and in questions we ask in correspondence and e-mail, or when meeting you or others in person or speaking on the telephone.  However, we will not collect information for which we do not have a reasonable need in order to carry out your instructions.

Personal data relating to your health is only collected where it is necessary to fulfil your instructions.  We will ask you to consent to our obtaining of such information and to its processing for that purpose.

Unfortunately, if you do not consent or we are not provided with the information we need in full, we may not be able to fulfil your instructions adequately or at all.

  1. Performing our services and processing information about others

It is in the legitimate interests of our business to process personal data relating to people other than our clients where necessary in order to provide services to our clients.  In some cases, the processing is also in the interests of the third party.

The nature of the information we need to provide our services depends on your instructions.  Our requirements are reflected in the forms we ask you or others to fill in, and in questions we ask in correspondence and e-mail, or when meeting you or others in person or speaking on the telephone.  However, we will not collect information for which we do not have a reasonable need in order to carry out your instructions.

As above, Personal data relating to health is only processed where it is necessary to fulfil our client’s instructions.  We will ask you to consent to our obtaining of such information and to processing it for that purpose.

  1. Operating our business

This section is concerned with the systems we use to process personal data and our processing of personal data for internal purposes.  It is not concerned with the nature of the data, the classes of individual on whom we process data, the classes of the data, the sources and disclosures of the data, nor the period of time which we hold data.

We process personal data using the following principal systems and networks:

  • A client relationship management system which is the repository of all information we hold on current, past and target clients.  This system is operated and maintained by PWM staff and is hosted on our behalf by a third party
  • Wealth Platform, which is a web-based portal through which our clients are able to access and manage information relating to them and their investments and products. Wealth Platform is operated by PWM staff and is hosted on our behalf by a third party
  • The communications services which form part of our network are procured from a third party, and all data transmitted across the network are transmitted by PWM staff or representatives or third parties with whom we are dealing in the course of business
  • Corporate systems for the processing of all other data

PWM staff use computer and communications equipment to access these systems, to perform their duties, and in particular work stations, laptop computers, other mobile computing devices and mobile phones. Personal data is stored on these devices appropriate to the use for the time being.
Additionally we may use Personal data for internal Training purposes, Corporate governance, management and reporting on a company basis.

Who we share your information with:

The legal basis on which we deal with people who are not clients or associated with a client depends on the circumstances. In all cases we make sure that we have a legitimate reason to do so in connection with our business.

We communicate and deal with all manner of people in the ordinary course of our business, whether suppliers, regulators, other competent authorities, and others incidentally in connection with our business from time to time. In the course of doing so, having regard to the nature and purpose of those dealings, we will obtain and process personal data. We do not use the data for any purpose other than for which it was given to us.

The reasons why we disclose personal information, to whom depends on the services you have instructed us to provide and our legal obligations as a provider of financial planning and investment advice. Where we are unsure whether or not you are aware of the disclosure to be made, we will inform you beforehand wherever possible.  However, on occasion we disclose information to:

  • HM Revenue & Customs
  • Custodians of your assets
  • Members of your family, including your spouse, partner or other adult members of your family or dependants if you are one of our private clients, where it has been agreed that our services will include these third parties
  • Representatives, trustees, settlors or beneficiaries if you are one of our charity or trust clients, and in each case, where it has been agreed that our services will include these third parties
  • Very infrequently, we are required by law to report matters to law enforcement agencies for the prevention and detection of crime, including the police, the National Crime Agency. In certain circumstances we are not permitted to inform you that we’ve done so or intend to do so
  • The Financial Conduct Authority, The Financial Ombudsman, and the Information Commissioner’s Office

To fulfil our commitments to you, we share your information with several third party organisations that perform certain tasks on our behalf. Information is only shared with these third parties to the extent necessary in order to enable them to provide the services required on our behalf. These third parties act on our instructions and are processors of your information. These organisations:

  • Provide financial crime prevention or credit reference services
  • Firms such as registrars and custodians that hold your assets
  • Are approved providers and administrators of financial products (including Pension administration services (e.g. SIPPs), and Insurance administration services)
  • Provide us with professional advice/support (such as our accountants, lawyers, marketing support and compliance consultancies)
  • We also may share your information with third parties you have a direct contractual relationship with (such as your appointed agent) or to assist in facilitating your acquisition of a third parties products and services. In these instances the third party is likely to also be a controller of your information for their own purposes. We ensure that we have in place strong data sharing protocols with these third parties to govern and guide the sharing of your information in these circumstances.

How we protect information

The security and confidentiality of your information is extremely important to us.

All personal data which is collected and recorded, whether on paper or electronically, has appropriate safeguards applied in line with our legal obligations.

Data is protected by our internal policies and procedures designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees undertake regular training in relation to data protection and are subject to duties of confidentiality which apply to the personal data we obtain and process.

Our Information security controls are aligned to industry standards and good practice. This provides a secure control environment that effectively manages risks to the confidentiality, integrity and availability of information. Additionally our controls ensure we can restore your data in situations where the data is corrupted or lost in a disaster recovery situation.

Where appropriate, we use encryption or other security measures which we deem appropriate to protect your information. We also review our security procedures periodically to consider appropriate new technology and updated methods. But, despite our reasonable efforts, no security measure can ever be perfect or impenetrable.

If you would like more details or are concerned about any particular issue, please contact our Compliance Director at the details below.

Where your information is processed

Your information is processed in the UK and European Economic Area (EEA).

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as required by applicable data protection laws.

How long do we keep your information?

We have a legitimate interest to keep all records relating to our business for our internal purposes and to deal with queries or complaints which may arise.

As a regulated business we also need to keep records for 5 years or longer if required.

We keep personal data of clients only where and for so long as it is necessary to provide you with our products and services while you are a client and afterwards for so long as necessary to meet our legal or regulatory obligations or, if longer, for in relation to claims which could be made against us. Our normal practice is to keep client information for at least 5 years after you cease to be a client.

Handling telephone calls and other electronic communications

We retain electronic communications to monitor our communications, provision of our services and for audit and training purposes. We occasionally, with your consent, record telephone instructions securely in accordance with our retention policies and applicable laws. Access to those recordings is restricted to those individuals who have a need to access them for the purposes set out in this Privacy Policy.

Our website and cookies

A cookie is a small file that is saved onto your computer or other device when you visit our website. They store small pieces of information, for example, to record you have visited our website or performed a certain action, and to improve your experience when you visit our website. Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. By using this Site you agree to our Privacy Policy including our use of cookies.

Our website may contain links to other websites of interest. However, once you have used these links to leave our website, please be aware that we do not have any control over that website. This means that we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites, or which cookies are used. Such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Your rights in relation to Data Protection

You have several rights under Data protection Law with respect to how your personal information is held and used by us. More information can be obtained from the Information Commissioner’s website. If you wish to request to exercise any of these rights or if you would like further information about them, you can contact us using the details set out in the ‘How to Contact Us’ section below. We will grant your request only to the extent that it follows from our assessment of your request that we are allowed and required to do so under DP Law.

You have the right to withdraw your consent to us processing special categories of your personal information at any time. This will not affect the lawfulness of any processing of these special categories of your personal information that we carried out before your withdrawal. If you choose to withdraw your consent to us processing these special categories of your personal information, we may not be able to provide you with certain products and services.

You have the right to ask for a copy of the personal information we hold about you in a written format, free of charge.

You also have the right, at no cost, to require us, and any third parties who we have shared your personal information with, to correct any inaccuracies in your personal information. In order for us to do so, you must inform us of any changes to your personal information so that we can keep it up to date.

In some cases, you have the right to restrict or suppress further use of your personal information. When you have exercised this right, we can still store your personal information but may not use it further unless you provide your consent for us to do so or as otherwise permitted by law.

You have the right to have the personal information we hold about you erased in certain circumstances unless it prevents us from carrying out the services you have requested or prevents us from meeting our legal obligations. We may not be able to provide our products and services to you if you ask us to erase your personal information.

You have certain rights to obtain and reuse your personal information for your own purposes across different organisations for example, if you wish to move to a new financial services provider. This enables you to move, copy or transfer your personal information easily between our IT systems and another provider’s safely and securely, without affecting its usability.

How to contact us

If you have any questions about this Privacy Policy or the personal data we will obtain and process about you, please contact:

Compliance Director,
Partners Wealth Management,
20 St Andrew Street,
London,
EC4A 3AG.

Email us: info@pwmllp.co.uk

If you do not believe we have handled your information as set out in our Privacy Policy, or you otherwise wish to complain about our handling of personal data relating to you, please contact our Compliance Director at the above address.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) at:

Information Commissioner’s Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire
SK9 5AF.

Tel: 0303 123 1113

www.ico.org.uk

Policy changes

If we decide to change this privacy policy, we’ll post the updated privacy policy on our website so that you’re always aware of what personal information we collect, how we use it and under what circumstances we disclose it.

This privacy policy was last updated on 11 May 2018.

For further information on how we can help you build and protect your wealth, please contact us.

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