Talon Associates Limited Customer Privacy Notice

Why should you read this document?

While dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data).This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

What information do we collect about you?

We collect information about you when you engage us for financial planning services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

Information about connected individuals

We may need to gather personal information about your close family members and dependants to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances.   Your Personal Datamay identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity. 

In the context of providing you with assistance in relation to your investment, pension, life assurance or mortgage requirements Your Personal Data may include:

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity

• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history 

• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents

• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically in respect of the processing we may undertake in relation to this type of information) 

• Any pre-existing investment, pension, life assurance or mortgage products and the terms and conditions relating to these

How will we use the information about you?

We collect information about you to provide you with the services for which you engage us.

Why do we need to collect and 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.

The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your investment, pension, life assurance or mortgage requirements we do so on the basis that both parties are entering a contract for the supply of services. 

To perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.

Alternatively, either during our initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected.  For example, we may need to respond to requests from mortgage lenders and life assurance providers relating to the advice we have given to you, or to contact you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject.  In such circumstances, we would be processing Your Personal Datato meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist you with for example your life assurance or ethical investments, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data to make enquiries of life assurance or investment providers in relation to life assurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you.    

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investment, pension, life assurance or mortgages.  You will provide information to us verbally and in writing, including email. 

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll.  If we use technology solutions to assist in the collection of Your Personal Data for example software that can verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used. 

What happens to Your Personal Data when it is disclosed to us?

During the handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service

• Submit Your Personal Data to platform providers, product providers, investment providers, mortgage   lenders and life assurance providers

• Both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.

• Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment, pension, mortgage or life assurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware

Sharing Your Personal Data 

From time to time Your Personal Data will be shared with:

• Platform providers, product providers, investment providers, mortgage lenders and life assurance providers

• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, product specialists, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your investment, pension, mortgage or life assurance enquiry and to provide you with our professional services.  

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area. 

Security and retention of Your Personal Data

Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

Where it’s necessary for Your Personal Data to be forwarded to a third party we’ll use appropriate security measures to protect Your Personal Data in transit.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

How long do we keep hold of your information?

During our relationship with you we will retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep Your Personal Data up to date throughout our relationship.

We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

• Five years for investment business

• Three years for mortgage business

• Indefinitely for pension transfers and opt-out business

These are minimum periods, during which we have a legal obligation to retain your records.

We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain Your Personal Data for longer than 80 years.

Your rights in relation to Your Personal Data

You can:

• request copies of Your Personal Data that is under our control

• ask us to further explain how we use Your Personal Data

• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)

• ask us to send an electronic copy of Your Personal Datato another organisation should you wish

• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to contact our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document, or wish to make contact to exercise any of your rights set out within it please contact:

Data Protection Officer

Talon Associates Limited

224 Wallace Street

Glasgow

G5 8AE

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK's data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.