Client Privacy Notice

Scope and Responsibilities

Our scope is all data subjects, whose personal data is collected, in line with the requirements of the UK GDPR. The Data Protection Officer (DPO) is responsible for ensuring that this notice is made available to data subjects prior to King’s Court Financial Planning LLP collecting/processing their personal data.

All employees of King’s Court Financial Planning LLP who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their personal data is secured.

Who we are?

King’s Court Financial Planning LLP is an advisory firm of financial planners and asset managers. We help individuals, families, charities, and businesses achieve their financial goals by creating, enhancing, and stewarding their wealth, providing peace of mind and enabling them to achieve their goals.

King’s Court Financial Planning LLP collects, uses and is responsible for certain personal information about you.

When we do so we are regulated under the UK General Data Protection Regulation, which is underpinned by the Data Protection Act (2018)

We are responsible as the ‘data controller’ and ‘data processor’ for all personal information collected for the purposes of those laws. The Data Protection Officer (DPO) is Mark Crofts of King’s Court Financial Planning LLP, Arlington House, 72 Fore Street, Trowbridge, Wiltshire, England, BA14 8HQ.

King’s Court Financial Planning LLP can be contacted via email to office@kcfp.co.uk or by phone on 01225 777 343.

The personal information we collect and use

Legal bases for processing of personal data:

The lawful bases for processing are set out in Article 6 of the UK GDPR. At least one of these must apply whenever King’s Court Financial Planning LLP processes your personal data:

• Contract – the processing is necessary for King’s Court Financial Planning LLP to fulfil the obligations of their Terms of Business for the provision of our goal based financial planning, wealth management, later life planning, estate planning and other services. Both parties would be provided with a signed copy of the Terms of Business and a copy of this privacy notice.
• Legal Obligations – the processing is necessary for King’s Court Financial Planning LLP to meet the requirements of a UK law and/or regulatory compliance. King’s Court Financial Planning LLP will identify the source for obligation (e.g., Financial Conduct Authority) and explain why your personal data is required to meet such obligations.
• Legitimate Interests – the processing is necessary, as King’s Court Financial Planning LLP has ascertained the legitimate interest of the individual/organisation and explained why the processing of personal data is required to action the legitimate interest.

You can find more about the UK GDPR lawful bases by visiting www.ico.org.uk

Special Category data:

Special category data is personal data that needs more protection because it is sensitive. Such data is personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

To lawfully process special category data, King’s Court Financial Planning LLP must identify both a lawful basis under Article 6 of the UK GDPR (see above) and a separate condition for processing under Article 9. These do not have to be linked.

Each individual data subject and their relevant special category data will be assessed.

Subsequently, King’s Court Financial Planning LLP will identify one of the following ‘conditions’ for processing the special category data:

• Explicit Consent – the data subject has given explicit consent to the processing of their personal data for one or more specified purposes, except where domestic law provides that the prohibition referred to may not be lifted by the data subject.
• Employment, social security, and social protection (if authorised by law) – processing is necessary for the purposes of carrying out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law in so far as it is authorised by domestic law or a collective agreement pursuant to domestic law providing for appropriate safeguards for the fundamental rights and the interests of the data subject.
• Vital Interests – processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.
• Not-for-Profit bodies – processing is carried out in the course of its legitimate activities with appropriate safeguards by a foundation, association or any other not-for-profit body with a political, philosophical, religious or trade union aim and on condition that the processing relates solely to the members or to former members of the body or to persons who have regular contact with it in connection with its purposes and that the personal data are not disclosed outside that body without the consent of the data subjects;
• Legal claims or judicial acts – processing is necessary for the establishment, exercise, or defence of legal claims or whenever courts are acting in their judicial capacity.
• Archiving, research and statistics (with a basis in law) – processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89 (1) (as supplemented by section 19 of the 2018 Data Protection Act) based on domestic law which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

If King’s Court Financial Planning LLP is relying on Employment, social security and social protection (if authorised by law) or Archiving, research and statistics (with a basis in law) as the ‘condition’ for processing the special category data then we will also abide by and meet the associated condition in UK law, set out in Part 1 of Schedule 1 of the Data Protection Act (2018).

Information collected by us

While providing our services King’s Court Financial Planning LLP collects the following personal information when you provide it to us:

• Names and contact details (e.g., contact names, email addresses, contact numbers)
• Financial details (e.g., bank account names, sort codes and account numbers for processing of invoices, customer payments, management of financial products, etc.)
• Addresses (e.g., business addresses and other nominated addresses)
• Legal Identifiers (e.g., UK Passport or UK Driving Licence number, NI number, proof of ID, personal tax reference number, etc.)

How we use your personal information

King’s Court Financial Planning LLP uses your personal information:

• To pre-qualify which of our products and services are suitable for your requirements (e.g., providing estimates, quotations, proposals)
• To provide and maintain our services (e.g., provision of contracts, engagement letters, emails, calls)
• To notify you about changes to our services (e.g., direct communications through secure and trusted King’s Court Financial Planning LLP communication channels)
• To allow you to participate in any interactive features of our services when you choose to do so (e.g., online account management software, video calls and meetings)
• To provide customer care and support (e.g., after sales support and contract renewal)
• To monitor the analysis/usage of the services (e.g., non-personal data via Google Analytics in relation to the King’s Court Financial Planning LLP website)
• To produce fee notes documentation for our services (e.g., fee notes, direct debit mandates)
• To provide compliance with all legal requirements of England and Wales (e.g., FCA/HMRC requirements)

Who we share your personal information with?

King’s Court Financial Planning LLP may share certain personal details with our approved financial product providers and partners, in addition to any required legal bodies, such as the Financial Conduct Authority (FCA). We would always inform you ahead of acting on any instructions to proceed with any of our services, should this be the case.

This data sharing enables King’s Court Financial Planning LLP to supply the above documented services to you in a professional and timely manner, whilst undertaking quality control and regulatory compliance procedures. Furthermore, it ensures compliance with all necessary UK GDPR and Data Protection Act (2018) lawful requirements.

King’s Court Financial Planning LLP will share personal information with law enforcement or other authorities if required by applicable law. We will not share your personal information with any other third party.

Whether information must be provided by you, and if so, why?

The provision of certain personal data including (but not limited to) contact name, registered address, email address, telephone number and certain financial information is required from you. This enables King’s Court Financial Planning LLP to provide our services to you. We will inform you at the point of collecting information from you, whether you are required to provide this and any other additional information to us.

How long your personal information will be kept?

Your Personal Data will be retained by us either electronically or in paper form indefinitely.  This data will only be used if the data subject makes a complaint against King’s Court Financial Planning LLP or King’s Court Financial Planning LLP make a complaint against a third-party provider.

Reasons we can collect and use your personal information

King’s Court Financial Planning LLP collects your personal data to enable us to provide our services to you.

King’s Court Financial Planning LLP may also contact you by email, phone, video call or letter in line with the service you have paid for. We may occasionally email you or send a letter about something relevant to the service you have paid for.

Furthermore, we may contact you, to inform you of company updates and items of interest via our official communication channels.

Your rights

Under the UK GDPR, Data Protection Act (2018) and ICO guidance you have several important rights free of charge. At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the Information Commissioner’s Office (ICO) on individuals rights under the UK General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• Call, email, or write to us in the first instance.
• Let us have enough information to identify you,
• Let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
• Let us know the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business and / or legal need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.  Any hard copy personal data that is to be destroyed, is securely stored pre-destruction and is destroyed with a Certificate of Destruction in line with our UK GDPR Secure Disposal Policy.

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 email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator (e.g., ICO) of a suspected data security breach where we are legally required to do so.

If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses, and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Cookies

We use cookies to collect, store and share bits of information about your activities when you use our website.

Cookies do different things, like letting you navigate between pages quickly and generally improving your experience of a website. If a website does not use cookies, it will think you are a new visitor every time you move to a new page on the website – for example, when you enter your login details and move to another page it will not recognise you and it will not be able to keep you logged in.

King’s Court Financial Planning LLP only use non-personal data essential cookies on this website to track the performance of the website via Google Analytics. This non personal data helps us to understand how to improve the website content for the benefit of all users. If you want to block cookies, then you can do this through your browser via the help function. You can also visit www.aboutcookies.org for further guidance.

How to complain

We hope that we can resolve any query or concern you raise about our use of your personal data.

The UK General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioners Office (ICO) who may be contacted here or by telephone on 0303 123 1113.

Changes to this privacy notice

This privacy notice was last reviewed and published on 01 July 2021.

King’s Court Financial Planning LLP is a UK based limited liability partnership, registered in England and Wales, under company registration number OC302355. We only provide our services to UK based data subjects.

We may change this privacy notice from time to time, when we do, we will inform you via letter or email.

How to contact us

Please contact us if you have any questions about this privacy notice or the information, we hold about you.

The Data Protection Officer (DPO) is Mark Crofts.

If you wish to contact us, please send an email to office@kcfp.co.uk or write to King’s Court Financial Planning LLP, Arlington House, 72 Fore Street, Trowbridge, Wiltshire, England, BA14 8HQ or call 01225 777343.