How we use your information
This privacy notice tells you what to expect when CFPML collects personal information. It applies to information we collect about you. To enable us to provide the services we have agreed and for other related purposes – including updating and enhancing customer records, analysis for management purposes and statutory returns, crime prevention and legal & regulatory compliance – we may obtain, use, process and disclose personal data about you.
We may collect and process the following data about you:
• Information that you provide by filing in forms on our site www.cfpml.com.
• Information that you provide to us by telephone; e-mail or face to face.
• If you contact us, we may keep a copy of that correspondence.
Visitors to our websites
When someone visits www.cfpml.com we use a third-party service, CFPML, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow CFPML to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why. These cookies are used to collect information about how visitors use our website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form,including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited.
People who email us
Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy. Email monitoring or blocking software may also be used. Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.
People who make a complaint to us
When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We usually have to disclose the complainant’s identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person’s record is in dispute. We usually have to disclose details of the complaint to our professional Indemnity Insurance Broker and Insurer. We may be required to provide a copy of our file to the Financial Ombudsman Service should an adjudicator be required to consider the complaint case. We are required to disclose to The Financial Conduct Authority (FCA) high level analytics concerning the number and nature of complaints received. This data does not include names or details that identify the specific data subject.
We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for 6 years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.
Alternatively, you have the right to lodge a complaint with the supervisory authority for data protection.
Information Commissioner’s Office
0303 123 1113 (local rate)
People who use our services
CFPML provide a range of Financial Services to Data Subjects. We process data provided by the data subject and other sources in order to deliver the appropriate products and services to Data Subjects.
We have to hold the details of the people who have requested the service in order to provide it. However, we only use these details to provide the service the person has requested and for other closely related purposes. When people do agree to our services, they can cancel their agreement at any time and are given an easy way of doing this.
Use of data processors
Data processors are third parties who provide elements of our service for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. Our Data processors / Third parties that we use include:
• Banking arrangements: Barclays Bank
• Accountants: Deeks Evans
• Regulatory and Compliance opinion where required: Threesixty Services LLP & Millen Compliance Limited
• Sanctions and PEPs checking (Anti Money laundering): Smartsearch
• Back Office Systems: Iress Adviser Office & Bluecoat Software (FinPlan)
• Research Software Tools: Exweb, FE Analytics
Under the General Data Protection Regulations (GDPR), you have rights as an individual which you can exercise in relation to the information we hold about you.
Access to personal information (Portability)
Data Subjects may submit a Subject Access Request - in order to obtain a copy of the personal data that we hold about them in a structured and portable manner. All SAR requests should be sent to:
Toni Fox-Bryant at T.Fox@cfpml.com
Confirmation of whether, and where, the controller is processing their personal data
CFPML is the Data Controller and a Processor. CFPML undertakes data processing within the EEA.
Right of Data subjects to erasure (Right to be forgotten)
Data Subjects may notify CFPML if they wish to exercise their right to erasure. Such a withdrawal of Consent does not affect the lawfulness of processing based on consent prior to the withdrawal. Data Subjects that exercise this right will be removed from any marketing or future contact. CFPML may retain a copy of any personal data and be retained by the Controller if the processing is necessary for the establishment, exercise or defence of legal claims.
Right of rectification
CFPML will seek to ensure that inaccurate or incomplete data will be rectified. Data Subjects have the right of rectification.
Right to object to processing for the purposes of Direct Marketing
Data Subjects may notify the Firm if they wish to exercise their right to be removed from any Direct Marketing activities. CFPML may still contact the Data Subject in order to fulfil any contractual obligations concerning the policies and services provided.
Disclosure of personal information
In many circumstances we will not disclose personal data without consent. However, when we investigate a complaint, for example, we will need to share personal information with the organisation concerned and with other relevant bodies.
Sharing Information with Third Parties
We may share your information with third party service providers such as insurance providers, compliance, and other agents relevant to the business activity.
Changes to this privacy notice
We keep our privacy notice under regular review. This privacy notice was last updated on 21st February 2019.
How to contact us
Campbell Fisk Chambers
12-13 April Court