| Gen2 Financial is a trading style of Premier Independent Investments UK Limited which is Authorised and Regulated by the Financial Conduct Authority. The Financial Conduct Authority (FCA) regulates financial services in the UK and you can check our authorisation and permitted activities on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register or by contacting the FCA on 0800 111 6768 |
During the course of dealing with us, we will ask you to provide us with detailed personal informationrelating 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.
For employees of our Corporate Clients we will follow strict protocols to ensure that we only hold personal data for a limited period, see retention policy below. We require personal data from Employers for the purpose of ensuring cover is provided for individuals, this will include market exercises when we look to obtain competitive terms for the policies. We will also hold Personal Data whilst dealing with underwriting and claims.
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. 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.
In the context of providing you with assistance in relation to your Investment, Mortgage, and/or Insurance requirements, including Companies where Gen2 Financial provide advice and administer policies for employees, the Personal Data may include:
When we speak with you about your investment, mortgage, and/or 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 Your 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 mortgage lenders, insurance 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 Your 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 Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
As an example, where you ask us to assist you with your insurance needs, in particular life insurance and insurance relating to an accident or illness, we may need to ask you information about your ethnic origin, your health and medical history (Your Special 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/guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, 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 Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category 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.
We will collect and record Your 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, mortgages, and/or insurance. You may 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 Your Personal Data, for example online verification of 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.
In the course of handling Your Personal Data, we will:
From time to time Your Personal Data will be shared with:
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your investment, mortgage, and/or insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your 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 Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Security and retention of Your 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 Your 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, 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.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Personal Data to be deleted from our records:
Whilst we will require certain personal data to provide the requested services from us we will not retain any data that we only collect to pass on to Investment providers, mortgage lenders or insurance providers in carrying out the ‘transaction’. The following data will be deleted within two months (or as annotated below) from completion of the transaction. This will include Data attached to emails, hard drives or cloud facilities;
For all business areas – Identification documents i.e. passport, driving licence:- these will be deleted once held on the cloud facility (the company CRM system, currently Intelligent Office) along
Investment:
Bank Statements if requested for identification purposes.
Payslips/P60 or any evidence of income i.e. SA302/tax computations/accounts for self-employed
Mortgage:
Bank statements
Mortgage statements
Payslips/P60 or any evidence of income i.e. SA302/tax computations/accounts for self-employed
Insurance
Direct debit/bank account information.
Medical declarations
Group Insurance Policies
Employee data will be requested in spreadsheet format (password protected and by encrypted email) three months prior to renewal date and will be deleted within three months of renewal as long as reconciliation to be carried out by the provider has been completed
You can:
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:
Garry Guest, Managing Director at Gen2 Financial, Unit 23G The Print Rooms, Holly Farm Business Park, Honiley, Kenilworth, Warwickshire, CV8 1NP; Telephone: 0330 0552068, email [email protected]
If we feel we have a legal right not to deal with your request, or to action, it in different way to that 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/or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.