Good Green Money Ltd (‘Good Green Money’, ‘we’, ‘us’, or ‘our’) is committed to protecting your identity and the information you or others share about you.
The purpose of this privacy notice is to explain why Good Green Money collects personal data about you and how it is used. Good Green Money is a controller of your data and responsible for how it is used.
Why should you read this document?
During the course of 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; and
- it explains how your personal data is protected (via General Data Protection Rules (GDPR)) and how your personal data is processed by us to perform the services we have agreed with you.
1. Personal Data
What do we mean by your “Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Examples of your Personal Data that we may collect include:
- Personal information
Your name, marital status, national insurance number, tax code, date of birth.
- Contact details
Your address, phone and email details and how you would prefer us to use them.
- Financial details
Your income and expenditure, savings, existing investments, goals and ambitions.
- Transactional data
Details about payments to and from you and other details of services we have provided to you.
- Family relationships
Information relating to your partner and dependents.
- Official documents
A copy of your birth certificate, marriage certificate, drivers licence, passport, wills.
- Your other advisers
Solicitors, accountants, powers of attorney, trustees, beneficiaries.
- Usage data
Details about your use of our website.
- Marketing and communications data
Details concerning your preferences in receiving marketing from us and third parties.
- Special categories of data (“Special Data”)
Some data is particularly sensitive and has special treatment in law. In order for us to provide an effective financial planning service, we will often need to collect data that falls under this category, particularly in relation to health, and we will only collect or use this type of data if you explicitly consent to us doing so.
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.
The basis upon which our Firm will deal with your Personal Data
When we speak with you about your Investment and Insurance requirements, we do so on the basis that both parties are entering a contract for the supply of services.
In order 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 in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use 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 Product providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use 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 Personal Data in order to 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
We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance 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, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Personal Data generally, as set out in this Privacy Notice.
Information on Special Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect your Personal Data?
We will collect and record Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to Investment and Insurance. 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 Personal Data, for example, software that is able to 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?
In the course of handling your Personal Data, we will:
- Record and store Personal Data in our computer systems (cloud facilities, websites, email, and hard drives), mobile devices and occasionally in paper form. This information can only be accessed by employees within our Firm and only when it is necessary to provide our service to you and to perform any administrative tasks associated with or incidental to that service.
- Submit Personal Data to Investment and Insurance Product providers. 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 Personal Data for the purposes of responding to any queries you may have in relation to any Investment product or Insurance policy you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware
If you choose not to provide data
We may need to collect data from you that is required by law, or to enter into or fulfil our contractual or regulatory agreement with you. If you choose not to give us this information, it may prevent us from fulfilling our legal or contractual duties. This may mean that we cannot continue to provide you with advice or continue to manage your financial or tax planning arrangements. Similarly, if we are unable to collect or use the data of any relevant individual (as referred to in Information you provide on others above), this may affect our ability to manage your financial or tax planning arrangements.
Advice to children
Sharing Personal Data
From time to time Personal Data will be shared with:
- Investment Providers and Insurance 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, our Compliance advisers, Product specialists, and providers of legal services such as estate planners (in each case where we believe this to be required due to your particular circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this privacy notice, i.e. to progress your Investment and Insurance enquiry and to provide you with our professional services.
Please note, that this sharing of 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 Privacy Notice.
Where you have subscribed to receive marketing correspondence from us we will keep your personal data for six years from when you subscribed to receiving marketing information from us or until you unsubscribe from receiving such correspondence from us (whichever is earlier).
We will not transfer any customer personal data outside the European Economic Area (“EEA”).
Security and retention of 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 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, ideally sending it via our Portal, 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.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of three years for insurance business, five years for investment business, or in instances whereby we have the legal right to such information we will retain records indefinitely.
Your Personal Data will be retained by us either electronically or in paper format for as long as we require your goods and/or services subject to a maximum of six years from the date of our last contact with you.
Your rights in relation to your Personal Data
- Request copies of your Personal Data that is under our control
- Ask us to further explain how we use 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 Data to 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 make contact with our Firm in relation to the use of Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
Haydon Waldek, 18 Highwoods Park, Brockhall Village, Lancashire, NN6 8HN. Tel. 01254 247 913
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should also make contact with 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/, by calling 0303 123 1113, or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
2. Data Protection
We will collect and store your personal and financial information which will be handled in accordance with the Data Protection Act 1998 as amended, extended, re-enacted or consolidated from time to time (including without limitation the implementation of the General Data Protection Regulation 2016/679/EC) (data protection legislation). For the purposes of data protection legislation, we are the data controller and we will process your Data in accordance with articles 6 (1)(b), 6 (1)(c) and 9 (2)(a) of the General Data Protection Regulation 2016. We will use your information to ensure proper performance of our agreement with you and to comply with our legal obligations when providing the services as further described below.
We will use your name, address, email address, contact number, date of birth, national insurance number and financial information (‘personal information’) to provide our services to you and verify your identity and this may require us to pass your personal information to our group companies, electronic verification providers, product providers or other financial firms such as lenders, banks, insurers, fund managers and platform providers. Should you decide not to proceed with our services, we will delete your personal information.
We will pass your personal information to Tenet Compliance Services Ltd as they provide compliance services to us. Further detail regarding how Tenet will use your data can be found on it’s website at www.tenetgroup.co.uk or by contacting Tenet on 01132390011.
We may be required to pass on your personal information to the Financial Conduct Authority (FCA), Financial Ombudsman Service (FOS) or the Financial Services Compensation Scheme (FSCS) to help with an investigation or complaint or other authorities as required by law.
We may need to collect sensitive personal data including information about your health, ethnic origin, or criminal prosecutions from third parties such as employers and credit reference agencies, fraud prevention agencies and other similar organisations in order to provide you with the services, for example where you require advice on protection or annuity products.
By ticking the relevant consent box on our website and / or via our online ‘Come On Board’ process, you consent to us obtaining your sensitive personal data from the third parties referred to above for the purpose of providing you with the services and sharing it with third party providers to obtain quotes on your behalf for example where we are providing you with annuity or protection advice as part of our services and Tenet Compliance Services Ltd.
You may exercise your right to withdraw your consent to the processing of your sensitive personal data at any time by contacting Haydon@goodgreenmoney.co.uk