This Privacy Notice explains how at MM Wealth Limited (‘MM Wealth’) we use any personal information we collect about you, and complies with the EU General Data Protection Regulation 2018 (‘GDPR’) and UK Data Protection Act 1988 (‘DPA’).
What information do we collect about you?
We collect information about you when you engage us for wealth management or financial planning services. Most of the information is provided to us directly by you. 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.
Your information is stored in an electronic format on our back office system and servers. Any original paperwork which has to be retained is stored securely in the office, and when no longer required, safely shredded.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
We won’t share your information for marketing purposes with any other companies.
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 carry out the services that you require from us. Without collecting your personal data we would also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we will obtain your explicit consent in order to collect and process this information.
How will we use the information about our clients?
We collect information about you in order to provide you with the services for which you engage us, as detailed in our Terms of Business and our Private Client Service Proposition documents.
We may need to gather personal information about your close family members, dependants, power of attorney etc, 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 share their information with us and to pass the Privacy Notice to them.
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, as well as custodians, 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 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 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.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to a third party company for identity verification purposes. The outcome of the check may include some additional information about you.
Where your assets are held in a third country (outside of EU) we will share your personal information for the purpose of contractual reason.
Any personal data that you submit to MM Wealth for the purpose of applying for employment will be used for the purpose of matching you to current or future job vacancies at MM Wealth. We will store your personal data securely and only share it within the organisation with those individuals involved in the recruitment process and for the purposes of assessing your suitability for a position with MM Wealth. We will only disclose your personal data outside of the organisation if we reasonably believe we are obliged to do so for legal reasons e.g. to HMRC for the purpose of tax collection or in connection with a criminal investigation.
By submitting your personal data you are consenting to your data being processed within third party software, including cloud based packages, on MM Wealth servers and by our staff. We are entitled to hold your personal data for the legitimate purpose of human resource management so if your application is successful and you become an employee your data will be transferred into our personnel system and files. In the event that your application is unsuccessful we will keep your personal data for 12 months after which time it will be destroyed.
How long do we keep hold of your information?
During the course of our relationship with you we will retain your 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 will retain your personal data for as long as permitted and required by law. In any case, we will not retain your personal data for longer than 10 years past the notification of the time of your death. However, we are subject to regulatory requirements to retain data for specified minimum periods. These are:
- Three years for insurance business
- Five years for investment business
- Indefinitely for pension transfers and opt-out business
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.
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 to request a copy of some or all of your personal information please email or write to our Data Protection Manager using the contact details noted below.
We will have one month to provide you with the information (two months in case of complex or numerous requests). We are obliged to verify your identity for this request.
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.
In summary, under data protection law your rights include:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
For further details please request a copy of our GDPR Rights Policy.
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Our website, www.mmwealth.co.uk, contains links to other websites. This Privacy Notice only applies to this website so when you link to other websites you should read their own privacy policies.
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
0303 123 1113 (local rate)
We keep our Privacy Notice under regular review and place any updates on our website. This Privacy Notice was last updated on 30/05/2020.
How to contact us
Please contact us if you have any questions about our Privacy Notice. If you would like a copy of information we hold about you please request this by emailing your adviser or our Data Protection Manager, Magda Korwin, at firstname.lastname@example.org. Or write to us at Wellbrook Court, Girton, Cambridge, CB3 0NA.