Data Privacy Notice

We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are


Court Ross Financial Management Limited collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “Court Ross”, “we”, “us” or “our” we are referring to Court Ross Financial Management Limited.
Court Ross Financial Management Limited is a company registered in England and Wales (company number 02105259) whose registered office is at 3rd Floor, Colston Tower, Colston Street, Bristol BS1 4XE. Court Ross Financial Management Limited is authorised and regulated by the Financial Conduct Authority. Financial Services Register number is 131794.
We provide specialist wealth management advice to individuals, trustees and businesses.

The personal data we collect and use


In the course of providing our service to you we may collect the following personal data when you provide it to us:

  • Your personal contact details (such as name, date of birth and email/postal address);
  • Documentation confirming your identity, tax residency and legal authority;
  • Information about your finances, including employment status;
  • Information connected to the product or services you use (for example, bank account details);
  • Information you provide about other people (for example, for joint applicants or beneficiaries for products or services);
  • If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below;
  • Your correspondence with us (such as letters, emails, calls or meetings);
  • Information collected automatically via cookies when you visit our website;
  • Information relating to your lifestyle;
  • Information relating to your health, marital or civil partnership status (only where it is necessary to provide the product or service you have requested or if required to comply with our legal obligations).

Information collected from other sources


We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
The personal data we obtain from other sources may include the following:

  • Product providers;
  • From identification and verification checking agencies:
  • – identity information;
  • – sanction check information;
  • Appointed agents;
  • Publicly available sources such as Companies House.

How we 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. Please read this notice carefully to understand how we use and protect the information that you provide to us. It is important you read this notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
In general terms, we collect and use personal information about you to:

  • Deliver our services and meet our legal responsibilities
  • Verify your identity where this is required
  • Contact you by post, email or telephone about important changes to our Website, products or services
  • Maintain our records
  • Process financial transactions
  • Prevent and detect crime, fraud or corruption

To ensure that we are providing an efficient and effective service we will sometimes be required to share the information we have collected with third parties that support us in providing this service. These third parties are:

  • Companies we have chosen to support us in the delivery of our products and services, for example, IT service providers, consultants and companies that provide administrative services and compliance services
  • HM Revenue & Customs, regulators and other authorities
  • Companies you ask us to share data with
  • Credit reference agencies to carry out anti-money laundering or identity verification checks
  • Product providers to apply for investment and pension products on your behalf
  • Pension fund trustees (if you invest in a SIPP)
  • Fund managers (or their appointed representatives) of the relevant fund(s) you have invested in
  • Product providers to apply for quotations for protection general insurance on your behalf
    Whenever we share your personal information, we will do so in line with our obligations to keep your information secure.
    You can find out more about the bodies we share your information with by contacting us by post or email.

Special category data


Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process health information and lifestyle information when providing intermediary services in relation to a protection insurance product; and/or
In the course of our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.

Marketing


We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent or have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.
You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please contact us:

  • By phone: 0117 930 0056
  • By email: reception@courtross.co.uk
  • By Post: Court Ross Financial Management Ltd, 3rd Floor, Colston Tower, Colston Street, Bristol BS1 4XE.


Whether information has to be provided by you, and if so why


We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.

How long your personal data will be kept


We only keep information for as long as is necessary in order to discharge our statutory and legal obligations. This will vary depending on the particular circumstances. As a general rule, we will retain records for a minimum period of six years following the termination of the contractual relationship between us, unless there are circumstances which mean we must retain the records for longer periods. There are various reasons why we must keep records for longer time periods, such as where the record is relevant to legal proceedings, a criminal investigation or where the record is subject to a statutory retention period (for example, data in relation to pensions).

Transfer of your information out of the EEA


We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Your rights


You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

  • To access personal data
  • To correct / erase personal data
  • To restrict how we use personal data
  • To object to how we use personal data
  • To ask us to transfer personal data to another organisation
  • To object to automated decisions
  • To find out more about how we use personal data

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 will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
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 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.

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.

To contest decisions based on automatic decision making

If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.

You can contact us for more information

If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.
If you would like to exercise any of the above rights, please:

  • email or write to our Data Protection Officer at reception@courtross.co.uk or 3rd Floor, Colston Tower, Colston Street, Bristol BS1 4XE;
  • 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.


Keeping your personal data secure


We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our supervisory authority


If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before the ICO.

How to contact us


Please contact our Data Protection Officer if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact our Data Protection Officer, please send an email to reception@courtross.co.uk or write to Court Ross Financial Management Limited, 3rd Floor, Colston Tower, Colston Street, Bristol BS1 4XE.

MAY 2018