On this page you can find out everything you need to know about the personal data we keep, how it complies with current legislation and your rights when it comes to opting out.
We have split our privacy notice into separate sections, to make it easier for you to find the information you are looking for:
- Who to contact about the data we hold.
- What information we collect about you and when.
- How we collect your information.
- How we use your information.
- Who we share your data with.
- Your rights.
- At a glance: key facts.
Who to contact about the data we hold
If you have any comments, queries or complaints about this notice, or about how we use your data, please contact our Data Protection Officer:
Portafina Investment Management Ltd,
Medway City Estate
You can also contact the UK information commissioner about anything relating to your personal data or to make a complaint. Visit ico.org.uk to find out how to report a concern. Or, you can write to:
Information Commissioner’s Office
What information we collect about you and when
People come to us for help and information, or we communicate directly with people for all sorts of reasons and in many different ways. And there are different stages to someone’s journey with us, from simply requesting information, to having authorised us to manage their pension for them.
Depending on where you are at in the Portafina journey, we will collect the following data:
- All contact information including: full name, phone number, email address and postal address.
- All relevant ID documents.
- All relevant financial and employment information.
- All relevant personal information including: medical details, beneficiaries and any benefits you are receiving.
- We may also receive your contact details (name, address) from selected 3rd parties, who have collected your information for marketing purposes and disclose this to us, using the legal basis of Legitimate Interest.
- Special category data (sensitive data) will only be used with your explicit consent.
We only keep your personal data for as long as we need to provide the products and services you have requested, or to fulfil our legal and regulatory obligations.
How we use your information
Data protection rules are very clear. We can only use and share your personal data if we have one or more legally-defined reasons to do so. The four legally-defined reasons are:
- Contract: your personal data is processed to fulfil a contractual arrangement (e.g. to carry out your pension review).
- Consent: this is where you agree to us using your personal data for specified reasons (e.g. the latest pension news and updates).
- Legitimate interests: this refers to our (Portafina’s) legitimate interests in managing our business so we can provide you with the best information and services in the most secure and appropriate way (e.g. to send you a free information pack or marketing information about our services). We must then balance this with the interests of the people whose personal data we hold.
- Legal obligation: this is where we are required to share your personal data because of a legal or statutory decree (e.g. a request from the police).
Who we share your data with
Our contracted third parties can and will only use personal data for the agreed purpose and will not:
- Sell your personal data to other third parties.
- Disclose your personal data to other third parties unless it is required by law or as stated in this privacy notice.
Sometimes we need to transfer personal data to third parties outside of the UK. For example: processing email communications through international servers so that we can deliver useful communications to clients.
Your personal data is just that: your personal data. As such, from a legal perspective you have some fundamental rights and these are called your Data Subject Rights. In this section we will cover some of those rights in detail, and summarise the rest.
Your right of access
At any time, you can ask us for details of the personal data we hold about you. You can request this via email or in writing:
Data Protection Officer
Portafina Investment Management Ltd,
Medway City Estate
Once we receive your request and proof of identity, we will provide you with details of the personal data we hold about you within one month (which can be extended is certain circumstances).
You also have the right to challenge the data we hold about you and, where appropriate, have it erased, rectified, restricted or objected.
Important note: At certain stages of our interactions with clients we are required by the Financial Conduct Authority (FCA) to keep personal data for a specific period.
We will only keep your data for as long as is necessary to provide our products and services to you and/or to fulfil our legal and regulatory obligations.
Your right to opt out
As detailed in this privacy notice, we communicate with people in many ways and for specific reasons. At any point, you have the right to opt out of these communications in the following way:
You can request to be opted out of emails by replying to them, phoning or writing to us. Plus, there is an option to opt out included in all our marketing emails.
There is an option to opt out of texts within the SMS message. Plus, you can request to be opted out by phoning, emailing or writing to us.
You can request to be opted out of receiving telephone calls by phoning, emailing or writing to us.
You can request to be opted out of receiving letters by phoning, emailing or writing to us.
Your Data Subject Rights also include:
- Your right of access: You always have the right to ask us for copies of your personal information. There are some exemptions, which means you may not always receive all the information we process.
- Your right to rectification: You always have the right to ask us to rectify information you think is inaccurate or update information you think is incomplete.
- Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
- Your right to object to processing: You have the right to object to processing for direct marketing, tasks carried out in the public interest, or processing where we are using legitimate interest as the legal basis.
- Your right to data portability: For any information that you provide to us, you have the right to ask that we transfer this information to another organisation or provide it to you. This right only applies if we are processing consented information, or we are in talks about entering into a contract and the processing is automated .
For more information on your Data Subject Rights please visit ico.org.uk
At a glance: key facts
This notice covers the privacy of visitors to our website, data supplied to our mailing house for marketing on our behalf, as well as data capture networks and personal data collected by Portafina (as a data controller) under the United Kingdom General Data Protection Regulation (UK GDPR).
Our general commitment and legal obligation
At Portafina, we are all committed to safeguarding your personal information, and we ensure that it is treated securely. And we are legally obliged to use your personal data in line with all laws concerning the protection of personal information, including the UK GDPR and Data Protection Act 2018. This notice is compliant with the UK GDPR.
Our Data Protection Policy sets out the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data.
Our GDPR Statement of Compliance sets out our commitment to processing and protecting personal data in compliance with the GDPR.
Our registration information
We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is: Z176088.
This privacy notice was last updated on:
14 March 2022
What happens to your data when your file is closed?
If your file was closed before we gave you financial advice
We need to retain your data for six months in case you raise a compliant about the service you have received. After that we will destroy all data we hold on you in line with data protection regulations.
If your file was closed after we gave you financial advice
Due to regulatory requirements by the Financial Conduct Authority (FCA), legitimate interest and legal time limits, we currently keep data relating to and evidencing suitability of advice for anyone who has asked us to review their pension, indefinitely. This includes all information gathered as part of our pension review process.
In the future you may want to query the pension information or advice we have given you. You might want to raise any concerns direct with us, via the FCA, through the Financial Ombudsman Service (FOS), or another legal route. In addition, we need to keep the information we hold on you to show we are compliant with our regulatory requirements, should the FCA audit Portafina.
As a result, according to FCA rules we must keep all the information we have on you in relation to our review and advice. And, at the moment, these rules do outweigh data protection legislation.
Please be assured that this data is stored securely, in accordance with current data protection regulations, and would only be processed for the legal and compliance purposes mentioned in the previous paragraph, and only accessed by those who have a legitimate business interest to do so.
Changes to the privacy notice
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