Privacy Policy
Privacy Notice
Avail Financial Planning understands its obligations regarding your fundamental right to a private life and has implemented systems and controls to ensure your rights and freedoms are protected.
Avail Financial Planning undertakes to meet its obligations under the Data Protection Act, the Privacy and Electronic Communications Regulations, and the EU General Data Protection Regulation (GDPR).
Avail Financial Planning will support customer understanding by ensuring any communication meets the information needs of customers, and any person with a vulnerability is not disadvantaged with the use of format, layout, fonts, and language used. Text should be easy to read and without jargon.
WHAT PERSONAL DATA DO WE COLLECT?
Avail Financial Planning will collect the following data, dependent upon the financial service required: Name, contact telephone numbers, email address, bank statements, passport, council tax and utility bills, driving licence, benefit statements, shotgun licence, payslips, criminal record information, existing pension information, life cover information, investment information, details of assets and liabilities, health information – life policies and long-term care information – annual expenditure, and any other existing relevant policy. Different variations of data are required for each product, so we may not be required to collect all of the data listed above for all products.
HOW DO WE COLLECT PERSONAL DATA?
You directly provide Avail Financial Planning with the personal data we collect by the following methods: Original physical copy, scanned certified email copy, scanned certified postal copy.
WHO WILL PROCESS YOUR PERSONAL DATA?
Access to your personal data is permitted only for those employees who require it to fulfill their responsibilities on your behalf. Your personal data will be initially processed by Avail Financial Planning. Your personal data will be further processed by On-Line Partnership Group Limited on behalf of its subsidiary company The On-Line Partnership Limited, who acts as our Principal for regulatory purposes. In the event of incapacity of your adviser, your data will be shared with an authorized On-Line Partnership Group Limited locum adviser to carry out the responsibilities within your service agreement. All parties will process your personal data in accordance with this Privacy Notice. All parties are subject to information security training to enforce and communicate best practice when handling information.
WHAT HAPPENS IF WE WANT TO PROCESS YOUR PERSONAL DATA FOR OTHER REASONS?
Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about, we will notify you.
WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL DATA?
Your personal data is essential to enable us to take steps at your request prior to entering into a contract or to perform a contract to which you are a party. Without this information, we will not be able to proceed to provide any financial service. Processing will only occur whereby it is necessary to protect the vital interests of our client.
WHAT MAKES THE PROCESSING LAWFUL?
The lawful basis for the processing of your personal data as per Article 6(1) of the GDPR is:
Consent. You can remove consent at any time by contacting our Data Protection Representative (details below).
Necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.
For compliance with a legal obligation to which we are subject.
For the purposes of the legitimate interests pursued by us.
KEEPING YOUR PERSONAL DATA UP TO DATE
We will record your information exactly as you provide it. You may ask us to update it at any time, and we will action your request promptly and notify relevant third parties of any changes.
WHAT ABOUT SENSITIVE PERSONAL DATA?
We will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific processing activities. In such cases, you will be asked to sign a separate consent form to evidence this and that you understand the purpose(s) of the processing of such data. Your consent may be withdrawn at any time. The processing is in order to:
Carry out obligations in respect of FCA requirements.
Carry out obligations in respect of financial application requirements on your behalf.
Protect your vital interests (e.g., we may pass on information about medical conditions to paramedics if you are unable to give consent due to illness).
Sensitive personal data may include data revealing racial or ethnic origin, data concerning health, or data relating to criminal convictions or offenses.
HOW WILL WE FURTHER USE YOUR PERSONAL DATA (OUR LEGITIMATE INTERESTS)?
To contact you to ensure that our records of your personal information are correct and up to date.
To respond to questions or complaints you may have about our services.
To update you with changes in our terms.
For statistical or research analysis relating to the performance of our business or that of our principal and understanding the changing needs of our clients.
To review, improve, and develop services we offer or handle complaints.
To pursue debts or unpaid fees.
To evidence company practices.
To evidence the standards and processes carried out conform to the company’s ethical standards and expectations.
For direct marketing activities.
To protect the business from risks which might be introduced by an individual.
You have the right to object to processing for these purposes, and we shall cease unless we can show we have compelling legitimate grounds to continue.
PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST
We will use your personal data to protect members of the public against dishonesty, money laundering, or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group Plc or Creditsafe Business Solutions Ltd.
WHAT PERSONAL DATA IS REQUIRED?
We only collect data that is necessary to carry out the purposes listed above. This includes data you supply and data we receive from reference agencies. Where practical and lawful, we will inform you about any of your personal data we receive from third parties that you may be unaware of.
HOW SECURE WILL YOUR PERSONAL DATA BE?
We will ensure that your data is only accessible to authorized people in our firm and will remain confidential at all times. Appropriate security measures are in place to prevent unauthorized access, alteration, disclosure, loss, damage, or destruction of your information. If we have a contract with another organization to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding appropriate security measures in place and only process your data in the way we’ve authorized them to. These organizations won’t be entitled to use your personal data for their purposes. If necessary, our security teams will check them to make sure they meet the security requirements we’ve set. Please contact our Data Protection Representative below if you would like further information.
WILL WE SHARE YOUR PERSONAL DATA WITH ANYONE ELSE?
We may share your data with:
Appropriate staff such as those who carry out financial or compliance functions.
Organizations that need your data because we are required to provide it by law (e.g., The FCA, ombudsman services, HMRC, etc…).
Organizations that help us process your personal data to establish your personal characteristic. This is necessary if we are to provide you with the best possible advice and service.
Organizations that carry out credit references or identity checks such as GB Group Plc or CreditSafe Business Solutions Ltd.
HOW DO YOU MAKE A COMPLAINT TO THE REGULATOR?
By telephoning: +44 208 167 9869
By emailing: Info.availfp@sjpp.co.uk
