Privacy Policy
Medical & General Independent Financial Advisers Ltd, which includes Investments Direct and Mortgages for Doctors (the “Company”).
This Client Privacy Notice explains how we use any personal information we collect about you.
WHAT INFORMATION DO WE COLLECT ABOUT YOU
We also collect information about you if you enquire about our services, download one of our brochures or guides, sign up for a webinar or provide information to us as part of other marketing activity.
We also collect information in the form of log files when you use our website. Please see the section on Cookies for more information.
INFORMATION WE COLLECT ABOUT YOU IF YOU BECOME OUR CLIENT
We collect information about you when you engage us for financial planning, financial advice, investment management services, non-investment insurance contracts, mortgage advice, equity release, pension planning and NHS Pension forecasts.
The information we collect about you if you become a client will relate to your personal and financial circumstances. It may also include special categories of sensitive personal data such as data about your health if this is necessary for the provision of our services.
Personal data and sensitive personal data may include however, is not limited, to the following (where applicable):
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and supporting documents.
- National Insurance number, employment and remuneration information (including salary, bonus schemes, overtime, sick pay and other benefits), employment history and supporting documents.
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents and supporting documents.
- Health status and history, details of treatment and prognosis, medical reports, lifestyle questionnaire and supporting documents.
- Any pre-existing investment, mortgage, finance and/or insurance products and the terms and conditions relating to these.
- If you have any parental responsibilities or responsibility for anyone that is financially dependent on you under the age of 23, it is very likely that we will record personal data relating to those children or person(s).
- The arrangement of certain types of insurance may require disclosure of any historic or current criminal convictions or offences.
We may also obtain some information from third parties - For example: Credit checks, information from your employer, searches of information in the public domain such as the electoral register.
We use technology solutions to assist in the collection of your personal data and in order for us to be able to do this, we need your consent and that of our nominated processer to access your information - For example: Software that is able to verify your identity and your credit status. We do not require your consent for electronic ID checks.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We may use your information collected from our website to compile statistical reports on website activity.
When we send our financial services update webinar recordings and newsletters, we will use the click-through rates to compile statistical reports of client engagement.
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.
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 e-mail ensuring e-mail attachments are password protected or encrypted and only using secure/tracked methods of postage when original documentation is being sent to us.
INFORMATION ABOUT CONNECTED INDIVIDUALS
We may need to gather personal information about your close family members and dependants in order 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 will provide a copy of this Privacy Notice for them or, where appropriate, ask you to pass the privacy information to them.
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 agreement/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 would also be unable to fulfil our legal, regulatory and compliance obligations.
Where special category (sensitive) data is required, we will obtain your explicit consent in order to collect and process this information.
With your consent, also collect data for the purpose of informing you about our products and services and analysing the performance of our communications.
HOW WILL WE USE THE INFORMATION ABOUT YOU?
We collect information about you in order to provide you with the services for which you engage us.
In order to provide you with with our services we will, record and store your data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud IT systems)
WHO MIGHT WE SHARE YOUR INFORMATION WITH?
If you agree, we will pass on your personal information to our group of companies/trading styles so that they may offer you their products and services.
From time to time, we will send our financial services update webinar recording and a newsletter to you by e-mail, which is included within our service offering to you. Should you not have access to an e-mail account, please let us know and we will arrange for these to be sent to you by other means.
If you do not wish to receive our financial services update webinar recordings or newsletter, please just click on the ‘unsubscribe’ link at the bottom of every e-mail.
When necessary, we will send you an e-mail with any updates to our agreements, terms and conditions or our Client Privacy Notice. Should you not have access to an e-mail account, please let us know and we will arrange for these to be sent to you by other means.
We will not share your information for marketing purposes with companies outside our group of companies/trading styles.
In order to deliver our services to you effectively, we may send your details to third parties such as those that we engage for professional compliance, accountancy, legal services, estate agents, as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data, we will have an agreement/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 will only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party, we will use appropriate security measures to protect your personal data in transit and all data personal data is encrypted when at rest. In some specific limited circumstances, we may transfer your personal data to third parties that are based outside the European Economic Area. In such cases we will have a data processing agreement in place or operate under the US-UK data bridge. Transfer risk assessments are conducted in line with guidelines from the Information Commissioner's Office.
To fulfil our obligations in respect of prevention of money laundering and other financial crime, we will send your details to third party agencies for identity verification purposes.
We may also engage the services of third party providers of professional services, in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of their agreement/contract with us.
Please note that by us sharing your personal data with third parties, this does not entitle the third party to send you marketing communications and neither is this authorised by us. Your personal data is only shared with the third party to ensure that we can adequately fulfil our responsibilities to you and as otherwise set out in this Client Privacy Notice.
On occasion, we will use your personal data for responsibilities that we need to comply to for the Financial Conduct Authority (FCA) or for wider compliance with any legal, regulatory or voluntary obligation to which we might be subject.
HOW LONG DO WE KEEP HOLD OF YOUR INFORMATION?
During the course of 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 are also subject to regulatory requirements to retain your data for specified minimum periods.
These are generally:
- Five years for investment business.
- Indefinitely for pension transfers and opt-outs.
- Three years for mortgage business.
- Three years for insurance business.
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. For example - We may need to respond to regulatory or voluntary requests from the Financial Conduct Authority (FCA) or we may make contact with you to seek feedback on the service that you have received.
You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
HOW CAN I ACCESS THE INFORMATION YOU HOLD ABOUT ME?
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please e-mail or write to us using the contact details noted below.
When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
MARKETING
We may send you information about our products and services and those of other companies/trading styles in our group which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes please contact us by e-mail or post at our office address (point 16 below).
You can click on the ‘unsubscribe’ link at the bottom of every e-mail at any time.
COOKIES
We use cookies to track visitor use of the website and to compile statistical reports on website activity.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, disabling cookies may cause our website to funtion incorrectly. However, in a few cases some of our website features may not function as a result.
OTHER WEBSITES
Our website may contain links to other websites. This privacy policy only applies to our website so when you link to other websites, you should read their own privacy policies.
E-MEETINGS
To ensure we carry out your instructions accurately, to help us to continually improve our service and in the interests of security, we may record and monitor your E-Meetings with us.
TELEPHONE CALLS
To ensure we carry out your instructions accurately, to help us to continually improve our service and in the interests of security, we will record and may monitor your telephone calls with us.
CCTV
We have CCTV installed at our office for security purposes. We need to bring this to your attention in the event that you visit us at our office.
WHAT CAN YOU DO IF YOU ARE UNHAPPY WITH HOW YOUR PERSONAL DATA IS PROCESSED?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
CHANGES TO OUR PRIVACY POLICY
We keep our privacy policy under regular review.
HOW TO CONTACT US
Please contact us if you have any questions about our privacy policy or information we hold about you:-
By e-mail: info@medicalandgeneral.co.uk
In writing: Medical & General Independent Financial Advisers Ltd
Cadhay Barn, Cadhay, Ottery St Mary, Devon, EX11 1QT
You should also make contact with us as soon as possible on becoming aware of any unauthorised disclosure of your personal data so that we may investigate and fulfil our own regulatory obligations.
YOUR CONSENT
By using our website, you consent to us processing your information in accordance with this privacy policy for the purpose of allowing us to deliver this website, answer your enquiry or provide you with any marketing or communications you've requested.
If you become a client you consent to us processing your information in accordance with this privacy policy for the purpose of allowing us to deliver the service you have engaged us to provide.