Quilter Financial Planning Limited (“Quilter”) is committed to protecting your privacy and ensuring that your personal information is collected and used appropriately, lawfully and transparently. This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
This Privacy Notice explains:
- Who we are
- What personal information we collect
- How we use your personal information
- Who we share your information with and why
- How we keep your information secure
- Your rights
- How to contact us
Who we are
Quilter is a network of adviser firms based in the UK who provide financial planning solutions; financial advice; wealth management products and services; pension advice; asset management solutions and discretionary investment management to customers.
Quilter is part of the Quilter Group of Companies. You can find further details on the companies in our group, here.
We deliver service, supported by a comprehensive range of compliance, governance and training solutions which enables member firms to provide and create financial plans that can adapt to your client’s financial objectives, circumstances and changing needs.
What personal information we collect
We collect personal information about you when you use our website, contact us about joining Quilter and about our services, visit or contact our recruitment managers, complete our application form or register to receive our newsletters. We will also gather information about you when you join our network to allow us to undertake our role as Principal.
The type of personal information we may collect will depend on the purpose for which it is collected but may include:
- Information to verify your identity;
- Previous occupation and employment history;
- Family, lifestyle, health and financial information; and
- Information relating to criminal and/or civil offences
We may ask for personal information at the start of our relationship and in subsequent communications (such as periodic “Fit and Proper” or competency checks) in order to check your identity, provide network support as Principal and to undertake compliance and monitoring activities. This is a regulatory requirement imposed by the Financial Conduct Authority (FCA).
Special categories data
Quilter may also gather more sensitive personal data, called special category data, as part of our role of Principal firm, for example, as part of recruitment. This type of data can include racial or ethnic origin, genetic or health information or sexual orientation. The processing of some of this data is necessary for us to fulfil the obligations on us as Principal. In such cases, we will always explain this during the onboarding process and explain what information we require and why it is needed. Where we do require it, we will always get consent. Special category data will always be processed and stored securely.
We also collect information about you from other sources. For example, our website automatically collects information from your computer using “cookies” which provides us with limited personal information. Cookies are small text files that are placed on your computer by websites that you visit. They’re widely used in order to make websites work, or work more efficiently, as well as to provide information to the website owners. For further information visit www.aboutcookies.org or www.allaboutcookies.org.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements.
Advice data is retained for 50 years to meet our regulatory requirements.
Personal information will be securely disposed of when it’s no longer required, in accordance with our Data Retention and Disposal Schedule. A copy of this is available using the contact details below.
On what basis do we collect data
The processing of your personal data is allowed under a number of lawful bases. The data required for the provision of our network services is processed on the basis there’s a contract with you to do so. Any relevant marketing activity we undertake is done because, as a firm, we have a legitimate interest to do so. However, you have rights, as listed below, which impact how we can use and process your data.
How we use your personal information
We process your information in order to support and maintain our contractual relationship with you as a director or principal of a member firm, and to comply with legal and regulatory requirements. This includes the following:
- As part of our recruitment process;
- Providing authorisation, monitoring, FCA submissions;
- Confirming and verifying your identity for security purposes;
- Confirming and verifying your employment and debt history for “fit and proper assessments” and FCA approval;
- Credit scoring and assessment, and credit management (where applicable); and
- Detecting and preventing fraud, crime, money laundering or other malpractice
We also process your data for specific business purposes, for example to send you updates of our services and information from our panel of lenders/providers.
Our business purposes include the following:
- Enhancing, modifying, and personalising our services for the benefit of our member firms;
- Providing communications which we think will be of interest to you;
- Audit and record keeping purposes; and
- Enhancing the security of our network and information systems
- The testing and maintaining of systems
You have the right to object to this processing if you wish, please see “YOUR RIGHTS” section below.
We may also process your personal data as part of an acquisition or sale. Should this happen, you’ll be notified about any change to processing or data controller arising as a result of this activity.
Basic identifiers about you (eg your name and address) is matched with information from Experian Marketing Services to create demographics and infer customer ‘types’ so that Quilter Financial Planning and the Quilter group of companies can define groups based on factors like interests, age, location and more. This helps Quilter Financial Planning and the Quilter group of companies better understand our customers in order to adapt and improve our products and services.
If you would like to know more about the information we receive from Experian Marketing Services, you can visit their website which explains who Experian Marketing Services are, what they do and why.
Who we share your information with and why
We share your information with trusted third parties who perform tasks for us and help us to provide the services you require these include:
- The Quilter Group of companies to enhance the services we can offer you;
- Other third parties (including our panel of providers/lenders) where you have given your consent to receive marketing information;
- A third party to verify your identity, in line with anti-money laundering, financial crime prevention or other requirements (this may involve carrying out checks with credit reference databases);
- Third parties who perform tasks for us to help us provide compliance and monitoring checks (these third parties may be based in countries outside UK);
- Other organisations, including regulatory bodies, police authorities and fraud prevention agencies, to prevent and detect fraud; and
- Third parties where required by law, court order or regulation
- Third parties as part of an acquisition or sale
How we keep your information secure
We’re committed to ensuring the confidentiality of the personal information that we hold and we continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.
When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.
If we work with third parties in countries outside the UK, we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards.
In limited circumstances, data may be accessed outside of the UK ie by employees when they travel. In these circumstances, we ensure there are appropriate information security measures in place to safeguard your information.
Quilter tries to be as open as it can be in terms of giving people access to their personal information and therefore have outlined your rights below. This privacy notice was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found here.
You have the right to opt out of marketing information and tell us what your communication preferences are by contacting us using the details provided at the end of this notice or by using the opt out option below or on any email marketing. You may opt out at any time if you don’t want to receive any further marketing information.
Individual data rights and requests
As a data subject you have the right to make the following requests:
- The purposes of the processing;
- The right to be informed – You can request that we provide ‘fair processing information’, typically through this privacy notice;
- The right of access - You may request a copy of the personal information we hold about you using the contact details found on the end of this privacy notice;
- The right to rectification - The accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information;
- The right to erasure – You may request the deletion or removal of personal data where there’s no compelling reason for its continued processing;
- The right to object – You may object to the processing of your data based on legitimate interests;
- The right to restrict processing – You have a right to request we ‘block’ or suppress processing of your personal data;
- The right to data portability – You may request to obtain and reuse your data; and
- The right not to be subject to automated decision-making including profiling
If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us at the address listed below.
How to contact us
If you have questions about this notice, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us using the following details:
The Office of Data Protection
Quilter Financial Planning Limited
85 Queen Victoria Street
London EC4V 4AB
How to complain
If you wish to raise a complaint about how we have handled your personal data, you can contact The Office of Data Protection who’ll investigate the matter.
If you’re not satisfied with our response, or believe we’re not processing your personal data in accordance with the law, you can complain to our regulator:
Information Governance department
Information Commissioner's Office
0303 123 1113