WHAT INFORMATION DO WE HOLD?
As a client of Consilium Asset Management, the data we hold has been completed from the services you have engaged us to provide in the past as per our agreement with you. We use this data to enable us to carry out specific functions and report writing for which we are responsible. We will not collect any personal data from you that we do not need to provide the services we agreed to provide you.
You have the right to object to this processing, but if you do not provide us with this information, we will be unable to provide the services requested.
THE LAWFUL BASIS ON WHICH WE USE THIS INFORMATION
We collect and use this information to comply with the Financial Conduct Authority (FCA).
WHY DO WE COLLECT THIS DATA?
We collect this data mainly to complete the services for which you have entered into a contract with us. Without knowing any of this information, we would be unable to fulfil our legal and regulatory obligations. Therefore, it is essential we collect this information.
However, we also collect this data because you will have given us consent to do so. Before proceeding, we will ask you to provide us with your consent to process your data.
If we need to collect special category data (e.g. health or mental conditions, trade union membership, biometric data (verification or identification data)), we will obtain your explicit consent first.
HOW WILL WE COLLECT YOUR DATA?
We will collect and record your data from a variety of sources. However, we rely mostly on this information coming directly from you. We will collect this information usually over a series of meetings, but most of this will be collected during our fact-finding meeting.
We may also collect this data from third parties, such as credit checks and your employer, as an example.
STORING THIS INFORMATION
We hold a person’s data for as long as the customer remains with Consilium Asset Management, or we are required to under this Terms of Business. Due to the nature of the service we offer, we may be required to retain personal data even after an account has been closed for legal or operational reasons under the guidance of the FCA.
WHO WE WILL SHARE THIS INFORMATION WITH
We can share this information with UK third-party companies that also follow the guidance of the GDPR legislation and the FCA. We do not share information without consent unless the law and our policies allow us to do so. If you choose to proceed with any of the recommendations our financial adviser gave, we will share your data with external organisations such as fund providers and platforms, where needed.
HOW LONG WILL WE HOLD YOUR DATA?
As we have entered into a contract for services, we will need to retain your data for a certain period to carry out that contract. Throughout the relationship, not just at the beginning, we will take reasonable steps to keep your personal data up to date.
In addition, we are also subject to regulatory requirements requiring us to retain your data for a specified period. These are:
- Three years for mortgage business
- Three years for insurance business
- Five years for investment business
- Indefinitely for pension transfers and opt-out business
If you want more information about how we process your data, ask your adviser for a copy of our Privacy Policy. They will happily supply you with a copy.
If you are concerned about how we are collecting or using your personal data, we request that you raise your concern with us in the first instance. Alternatively, you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/
