Robertson Baxter Limited is committed to protecting and respecting your privacy. This Privacy and Cookies Policy (together with any other documents referred to therein) sets out the basis on which the personal data collected from you, or that you provide to us will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation the Data Controller is Robertson Baxter Limited.
YOUR PERSONAL INFORMATION
Information we collect from you
We collect and process some or all the following types of information from you in the course of providing Independent Financial Advice.
- Information that you provide as part of the initial registration process with ourselves or by completing forms on our Website. This includes information provided at the time of subscribing to our service, registering to use the Website or requesting further information or services. We may also ask you for information when you enquire about our services.
- Specifically, personal details such as name, email address, date of birth or any information input using our services or using our website.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to the Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access.
The provision of your name, address and date of birth, as well as other personal data is required from you to enable us to fulfil our regulatory and legal obligations. We will inform you at the point of collecting information from you, whether you are required to provide the information to us.
Information collected from other sources
Robertson Baxter may also obtain personal data from other sources in the course of providing our 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 details from product providers on policies/products that you already hold with them or from identification checking agencies.
USES MADE OF YOUR INFORMATION
Lawful basis for processing
We will only use personal data when the law allows us to. Most commonly, we will only use personal data in the following circumstances:
- The primary legal basis we intend to use for the processing of your data is for the performance of our contract with you. The information we collect about you is essential for us to be able to carry out the services you require from us effectively. Without collecting your personal data we would be unable to fulfil our legal and regulatory obligations.
- The collection and retention of your data may be necessary in order to fulfil a legal obligation e.g. in respect of Money Laundering and Financial Crime legislation as well as any requirements issued by our regulators such as the Financial Conduct Authority or other Government bodies such as HMRC.
- We may use your personal data for the purposes of our own legitimate interests, provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. The collection and retention of your data would be necessary if we had a legitimate interest to do so such as the detection of fraud or criminal activity.
- To provide you with information, products and services that you have requested from us or which we may reasonably believe would be of interest to you. By signing our client agreement you have consented to be contacted for such purposes. Our legitimate interests in this data are to fulfil our contractual obligations to you and to fulfil our legal obligations as authorised and regulated firms.
Purposes of processing
We use information held about you in the following ways:
- To provide you with our services.
- To ensure that content on the Website is presented in the most effective manner for you and for the device(s) you use to access and view the Website.
- To provide you with information and offers that you request from us or which we feel may interest you.
- To carry out our obligations arising from any contracts entered into between you and Us.
- To allow you to participate in interactive features of our service when you choose to do so.
- To notify you about changes to our service.
In addition to the above uses we may use your information to notify you about goods or services which may be of interest to you. Where we do this, we will contact you by electronic means (e-mail or SMS) only if you have consented to such communication. If you do not want us to use your data in this way please either;
- Tick the relevant box situated on your service charter on which we collect your data;
- Unsubscribe from our electronic communications using the method indicated in the relevant communication; or
- Inform us at any time by contacting us at the contact details set out below.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal data to third parties as follows:
- We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
We may disclose your personal data to any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (where applicable).
We may also disclose your personal data to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
- If all or substantially all our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our client agreement/service charter; or
- to protect our rights, property, or safety or that of our affiliated entities and our users and any third party we interact with the to provide the Website; or
- in relation to selected third parties only, only to the extent that you have consented to such selected third parties notifying you about certain goods or services, which may be if interest to you.
Other than as set out above and save insofar as is necessary in order for us to carry out our obligations arising from any contracts entered into between you and us, we will not share your data with third parties unless we have procured your express consent to do so.
STORING YOUR PERSONAL DATA
We take appropriate measures to ensure that any personal data are kept secure, including security measures 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.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Keeping your personal data up to date
If your personal details change you may update them by accessing this data through the wealth platform portal, or by contacting us using the contact details below. If you have any questions about how we use data collected which relates to you, please contact us by sending a request by email to the contact details below or by writing to us as the firm’s address.
We will endeavour to update your personal data within seven working days of any new or updated personal data being provided to us, in order to ensure that the personal data we hold about you is as accurate and up to date as possible.
How long we keep your personal data
- We will hold personal data (e.g. name, address, date of birth and contact details) in line with our regulatory and legal obligations as set out by our regulator, currently a minimum of;
- Five years for investment business
- Three years for mortgage business
- Three years for insurance business
- Indefinitely for occupational pension transfer or opt-out business.
- Two years for prospect data if you do not ultimately become a client of Robertson Baxter
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.
Where we store your personal data
All of the information that we hold about you is stored on our secure servers within the EEA. If you would like further information please contact Robertson Baxter’s Data Protection Manager.
We will not otherwise transfer your personal data outside of the United Kingdom or EEA 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.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- Access to your personal data and to certain other supplementary information that this Policy is already designed to address
- Require us to correct any mistakes in your information which we hold
- Require the erasure of personal data concerning you in certain situations
- Receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- Object at any time to processing of personal data concerning you for direct marketing
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- Object in certain other situations to our continued processing of your personal data
- Otherwise restrict our processing of your personal data in certain circumstances
- Claim compensation for damages caused by our breach of any data protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- Email, call or write using the contact details at the end of this document
- Let us have enough information to identify you g. account number, user name, registration details
- 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 including any account or reference numbers, if you have them
HOW TO COMPLAIN
We hope that our Data Protection Manager can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
We specifically use Google Analytics for this. These cookies are used to store information on previous visits to our website and visitor referrals by other websites. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
You may set most browsers to notify you if you receive a cookie or you may choose to block cookies with your browser.
All questions, comments and requests regarding this Privacy and Cookies Policy should be addressed to:
Stephen Baxter – Managing Director and Data Protection Manager
Alternatively, you can write to us at:
Robertson Baxter Limited
1 Abbey Road,
TELEPHONE: 01484 608095