At Kingswood we are dedicated to protecting and preserving your personal information. This policy details how we collect, use, disclose and store your personal data. We are responsible for ensuring that we adhere to Data Protection Laws when using your personal data. Under the FCA ‘Consumer Duty’ we also want to ensure our activities put our customers’ needs first by acting in good faith, supporting consumer financial objectives and avoiding foreseeable harm in regards to personal data.
This privacy notice applies to past, potential or current Kingswood clients/intermediaries, it also applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. By continuing your interaction, via the use of any of our services you are acknowledging that you have been made aware of the practices described in this policy and our use of your personal information.
Personal data we collect
We collect information about you when you engage us for financial planning, financial advice or investment management services. The personal data which we collect and use may include things such as your personal details (i.e. name, email address, phone number) and information which is relevant to us providing any services to you (such as financial circumstances, your bank details and records of communications). We may also collect and use some special categories of personal data such as information about health conditions if this is necessary for the provision of our services.
It is compulsory that we ask you for this information in order to enter into an agreement with you whilst fulfilling our regulatory obligations. Failure to provide the information we ask for could mean that we are unable to provide our services either wholly or in part.
Why we collect and use your personal data
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The data provided is essential for us to be able to carry out the services that you require effectively. Without this personal data, we’d also be unable to fulfil our legal and regulatory obligations. Where special category data is required, we’ll obtain your explicit consent in order to collect and process this information.
Personal data is necessary for our legitimate business interests. These include enforcing the terms and conditions of any agreement we have with you, assessing the suitability of any wealth planning or investment decision made directly by you or by us and improving customer service and training staff.
We may also use information to develop and test the effectiveness of marketing activities and to improve our services. In addition, we may use it to provide you with marketing information about services and products we offer which may be of interest to you and to notify you about changes to our services and products. You have the right to request us not to process your information for marketing purposes at any time by contacting us at [email protected].
How we use personal information
We collect information about you in order to provide you with the services for which you engage us, this will allow for Kingswood to provide optimal services for you under our agreement. Data provided will be used to take decisions regarding your account which would include assessing your suitability for certain products and services. Your data may also be used in the interest of Kingswood for statistical and research purposes.
We may use your personal data for the purposes of conducting credit/identity checks and financial crime and anti-money laundering enquiries or assessments. If we are unable to verify your identity, we will require further information in order to perform these checks. There may also be some instances where this personal information could be used in the need to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
Sharing of personal data
We may be under a duty to disclose or share your information in order to comply with any legal obligation or regulatory requirements. This includes sharing information with any relevant authority where we are obligated to do so including but not limited to regulators, government and law enforcement or fraud prevention agencies.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes. We may provide information to our appointed auditors and other professional advisers to the extent that they require such information to provide advice.
In the event we sell or buy any business or assets, we may disclose your information to the potential seller or buyer of such business for due diligence purposes. We may share information in order to enforce the terms of any contract a client has with us.
How long we keep your personal data
During the course of the relationship between the client and Kingswood, we’ll retain personal data which is necessary to provide services to you. Necessary steps will be taken to ensure your personal data is up to date throughout the relationship.
Any personal information that we do obtain from you will be handled in accordance with data protection law. Your personal data will be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will only keep your personal information after this period if there is a legitimate reason to do so. You have the right to request deletion of your personal data and we will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests.
You have rights under data protection law that relate to the way we process your personal data and you can exercise your rights by contacting us with the details below. More information can be found on the Information Commissioner’s website.
Access - You have the right to access the personal data we hold about you and request a copy of this information.
Correction - You have the right to make us rectify any inaccurate data we hold about you.
Erasure – You have the right to make us erase any personal data we hold about you. Note that in certain circumstances we may be legally entitled to retain your personal information.
Restrict or object to processing – You have the right (in certain circumstances) to restrict or object to our processing of the personal data we hold about you. There may be circumstances where we are legally entitled to keep your data.
Data portability - The right to receive personal data you have provided to us in a portable format or otherwise.
Withdraw – You have the right to withdraw your consent where we are relying on it to use your personal data (e.g. for marketing purposes).
Complain – You have the right to make a complaint to the data protection regulator.
Accessing the information we hold
As stated above, you have a right to request a copy of the information we hold about you. You can submit a “data subject access request” which enables you to receive a copy of some or all of your personal information. We have a responsibility to ensure that your details are accurate and up to date.
If you wish to submit a request, please use the contact details of the Senior Manager in charge of Data Protection ([email protected])
With your consent, where such consent is required under the applicable regulations and data protection laws, we will send you information about products and services of ours and other companies in the Kingswood Group which may be of interest to you. It is your right at any time to stop us from contacting you for marketing purposes – as such, you may withdraw your consent or otherwise opt out of receiving this information at any point. If you would like to do so, please contact our Senior Manager in charge of Data Protection using the details below.
You will still receive service notifications that we need to send you containing important information in relation to the service we are providing to you. In order for us to fulfil any agreement, this is necessary.
Changes to our policy
DATA CONTROLLERS WITHIN KINGSWOOD GROUP
KW Wealth Group Limited
KW Investment Management Limited
KW Wealth Planning Limited
Admiral Wealth Management Limited
Regency Investment Services Limited
Money Matters (North East) Limited
Allotts Financial Services Limited
Vincent & Co Financial Limited
Joseph R Lamb Independent Financial Advisers Limited
Sterling Trust Professional Limited
Sterling Trust Professional (North East) Limited
Sterling Trust Professional (Sheffield) Limited
Sterling Trust (York) Limited
Metnor Holdings Limited
IBOSS Asset Management Limited
Casson Beckman Wealth Management
Barry Fleming and Partners Investments Planning Limited
AIM Independent Limited
Strategic Asset Managers Limited
Employee Benefit Solutions Limited
JCH Investment Management Limited
JFP Financial Services Limited
We hope that you will never have reason to complain about the way we process your personal information or with the way we’ve handled a request by you in relation to your rights. However, if something does go wrong please bring it to our attention as soon as you can and we will try to resolve the matter fairly and quickly. Please contact us on the same email address as above. You also have the right to make a complaint to the Information Commissioner’s Office via the below address:
Information Commissioner’s Office
If you have any questions about this Policy or wish to exercise any of your rights please get in touch with us either at [email protected] or by writing to the Senior Manager in charge of Data Protection at the following address:
10-11 Austin Friars
Published March 2023