Westcotts Financial Management Limited’s Privacy Notice – General
Data Controller
Westcotts Financial Management Limited
26-28 Southernhay East
Exeter EX1 1NS
Any reference to ‘Westcotts Financial Management Limited’ or the ‘Firm’ as Data Controller within this privacy notice also refers to the wider firm which includes ‘Westcotts Chartered Accountants’, ‘Westcotts Business Recovery LLP’, ‘Westcotts Financial Management Limited’ trading as ‘Westcotts Chartered Financial Planners’ and ‘Westcotts Secretarial Limited’.
Data Protection Officer
To enquire about any aspect of this document or your associated data protection rights please contact Westcotts’ Data Protection Officer:
Mr P Tigwell
26-28 Southernhay East Exeter
Devon EX1 1NS
Email: patrick.tigwell@westcotts.uk
All initial contact should be in writing (by post or email).
General
Westcotts Financial Management Limited collects and processes personal data relating to its Clients to manage the client relationship. We are committed to being transparent about how we collect and use that data and to meet our data protection obligations.
Lawful reason for processing personal data
The processing of non-client and non-employee data will be undertaken predominantly to market the services and expertise of Westcotts Financial Management Limited and will be carried out for the purpose of legitimate interests pursued by the Firm, upon receipt of consent of the data subject or with a view to take steps to enter into a contract. Information circulated will relate to changes to legislation or to Westcotts Financial Management Limited itself to which the Data Subject should be made aware.
Westcotts Financial Management Limited will as the data Controller in accordance with GDPR.
There may be occasions where communication takes place or to comply with a legal obligation placed on the Firm. If a data subject has opted out of circulations then we may still choose to override this if it is deemed necessary to satisfy a legal obligation.
Categories of personal data collected by Westcotts Financial Management Limited
We collect and process a range of information about you. This includes:
• Name
• Client code
• Address
• Email address
• Phone number
• Organisation/employer
• Position/Job Title
• Areas of interest
The organisation may collect this information in a variety of ways. Most data will be supplied by the data subject, representatives of the data subject or authorised third parties. In some cases gaps in the data provided may be obtained from a public source
Intended recipients of the personal data
Campaign Master, Stormpress are processors of Westcotts Financial Management Limited. Information is passed to these organisations to allow successful distribution of information/invitations etc on behalf of Westcotts Financial Management Limited. Westcotts Financial Management Limited are satisfied that Campaign Master and Stormpress themselves are GDPR compliant and only hold the data for a limited period in line with their legal requirements.
Information is not shared with any other third parties.
Legitimate interest of the controller
The Firm has professional expertise that it wishes to share through direct marketing purposes in pursuing the legitimate interests of the Firm.
Retention period
The Firm intends to maintain data until consent is withdrawn or we identify another reason to cease processing the data.
Where data is held but there is no interaction with Westcotts Financial Management Limited over a reasonably considered period, then Westcotts Financial Management Limited will contact the Data Subject and inform them that they will cease processing their data after a further period of time/number of communications. At which point the Data Subject would need to contact Westcotts Financial Management Limited and provide additional consent and opt back in to allow processing of data to continue.
Information passed to third party processors (Campaign Master, Stormpress) is deleted once Westcotts Financial Management Limited are satisfied that they no longer need that data for review. It is intended that this is held for no more than 13 months.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to the Firm. However, if you do not provide the information, the Firm may not be able to communicate with you effectively.
Use of Data Processors
• E-newsletters
As data controller we use a third party data processor, Campaign Master UK Ltd, to deliver our e- newsletters. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletters. For more information, please see Campaign Master’s privacy policy.
• Postal mail shots
As data controller from time to time we may use a third party data processor, Stormpress Ltd, to deliver circulations by post. Information is held by Stormpress Ltd for no longer than is necessary prior to being destroyed. For more information, please see Stormpress’s privacy policy.
• Event organisation
As data controller from time to time we may use a third party data processor, Eventbright, to issue tickets for events. Information is held by Eventbrite, Inc., a Delaware corporation. Eventbrite, Inc. participates and complies with the EU-U.S. Privacy Shield Framework. In the event that payment is required for an event then this information is held and managed by Eventbrite Operations (IE) Ltd.
For more information, please see Eventbrite’s privacy policy.
Information held by Eventbrite will be held within that platform for no longer than is necessary prior to being removed.
Information in respect of Event attendances may be held for a longer period outside of Eventbrite but again, this will be held for no longer than is necessary prior to being removed.
Your rights as data subject
Right of access – where Westcotts Financial Management Limited is processing or has processed your personal data you have rights as an individual to get a copy of the information that we hold about you. This is known as a subject access request.
For these to be managed effectively, subject access requests must be made in accordance with the guidance issued by the Information Commissioner’s Office (www.ico.org.uk/for-the-public/). All requests should be submitted to Westcotts’s Data Protection Officer.
Failure to submit a subject access request in this format may result in the request being rejected.
The right to rectification – you have the right to request rectification of your personal data where errors have been identified.
Any such request must be made verbally or in writing by post or via email to the Firm and a response will be issued within one month of receipt.
Please note that there may be instances where such requests cannot be fully satisfied and in such cases a full explanation will be provided within the response.
The right to erasure – you have the right to request erasure (also known as ‘the right to be forgotten’) of your personal data.
Any such request must be made verbally or in writing by post or via email to the Data Protection Officer and a response will be issued within one month of receipt.
Please note that there may be instances where such requests cannot be fully satisfied and in such cases a full explanation will be provided within the response.
Right to restriction of processing – you have the right to obtain from us a restriction of processing where one of the following applies:
a) The accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data.
b) The processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead.
c) We no longer need the personal data for the purposes of processing, but you require us to retain the data for the establishment, exercise or defence of legal claims.
d) An objection to the processing of personal data has been raised by you, for a period enabling us to consider whether your rights are overridden by our legitimate reasons to retain the data.
Right to data portability – where it is practicable to do so we will provide an active secure self-service system to provide your personal data held by us.
Where it is not practicable to provide an active self-service system, upon receipt of a ‘right of access request’ information held will be made available via a secure self-service system and direct access will be granted to you.
Where possible the data will be provided in a suitable electronic format which complies with the GDPR guidelines on data portability. Where this is not possible this will be explained.
Please note that the right to obtain access to personal data through a remotely accessed secure system should not adversely affect the rights and freedoms of others.
The right to object – you have the right to object to:
• processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling);
• direct marketing (including profiling); and
• processing for purposes of scientific/historical research and statistics.
Westcotts Financial Management Limited will adhere to the guidelines set by the Information Commissioner’s Office upon receipt of an objection. The objection can be made verbally or in writing to the firms marketing department or Data Protection Officer.
All processing will cease upon receipt of a relevant objection. The Data Protection Officer will issue a formal response to the objection within one month of receipt.
Automated decision making and profiling
The firm does not perform any tasks which rely solely on automated decision making or profiling.
Complaints or queries
Westcotts Financial Management Limited tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice has been drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Westcotts Financial Management Limited’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address above.
If you want to make a complaint about the way we have processed your personal information, in the first instance please contact the Data Protection Officer. If the Data Protection Officer is unable to satisfactorily deal with your complaint, or you are not satisfied with our response or believe our processing of your personal data is not in accordance with the law you can complain to the Information Commissioner.
Links to other websites
This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.