Privacy Notice

Solidus IEP Ltd (Solidus) is committed to full compliance with the requirements of the General Data Protection Regulations (GDPR), the DPA (Data Protection Act) [pre GDPR enforcement] and the PECR (Privacy and Electronic Communications Regulations). Solidus will follow procedures which aim to ensure that all employees, legal and professional partners, who have access to any personal data held by or on behalf of Solidus, are fully aware of and abide by their duties under the above regulations.

Solidus is committed to protecting the privacy of the visitors to our website www.siep.co.uk (referred to in this Policy as the “website”) and, in that respect, Solidus fully endorses and adheres to the six fundamental principles of GDPR, DPA and PECR. Use of this website by you constitutes acceptance by you of this privacy policy.

Six Principles of Data Protection

Data must be processed fairly and lawfully
Data must be collected for specified, explicit and legitimate purposes
Data we hold must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
Data must be accurate and, where necessary, kept up to date
We must not keep data for longer than necessary
Data must be kept securely and we must guard against its loss

What data do we collect

Rationale/ Reason for Processing:
Application form collected by Licencees – including client contact details, financial information, policy details, family details, NI Number, Date of Birth.

Lawful basis for Processing:

Contract- Where we use your personal information for the purpose of providing services, advice or assistance to you on the basis it is necessary to meet the requirements of the contract between us and the client.

Consent- if we have gathered/ been provided with sensitive information about your circumstances in order to provide a service to you.

Legal Obligation- We may collect data in line with our legal obligations such as monitoring and quality purposes in order to comply with a legal obligation.

Rationale/ Reason for Processing:

Financial Information – Bank Account Details

Lawful basis for Processing:

Rationale/ Reason for Processing:

Marketing - To write to you about third-party products or services that we may believe would be of interest.

Lawful basis for Processing:

Consent-If we retain your explicit consent for marketing preferences.

Rationale/ Reason for Processing:

Monitoring of personal data
To monitor activities where we are required to do so by law
To monitor and review data for training and monitoring purposes

Lawful basis for Processing:

Legal obligation- we may collect data in line with our legal obligations such as monitoring and quality purposes in order to comply with a legal obligation
Legitimate interests- to monitor quality and to take action on complaints or for training and monitoring purposes.

Special Category Data

Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.

In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering a will and or trust or (ii) for the establishment. Exercise or defence of legal claims.

In some circumstances we may process your data to protect the vital interests of a person or for a substantial public interest under laws that apply to us where this helps us to meet our broader social obligations or safeguards others such as:

Processing of special categories of personal data such as your health or if you are a vulnerable customer.
When we share your personal information with other people and organisations, such as your relatives. Social services, your carer, the person who has control of your affairs e.g power of attorney, court appointed deputy, someone with parental responsibility, if they need to know that you are a vulnerable customer; and
When we share your personal information with other organisations to help prevent and detect fraud or financial crime.

Collecting your information

You can access most of the pages on our website without giving us your personal information. However, you may choose to provide us with your personal information on some pages of our website, for instance, by completing a contact request form. The Privacy Policy is for you to understand our views and practices regarding your personal data and how we will treat it. The Policy explains how we use any personal information we collect from you through our website.

Under no circumstances will Solidus sell, lease or distribute your personal information to third parties unless we are required to do so by law. However, we may be required to give access to select legal or professional providers, for a specified purpose such as verifying legal documents, maintaining our IT services, or producing financial documents etc.

How and when can you withdraw your consent?

Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds as outlined above. For processing data that is based on your consent, you have the right to withdraw your consent for future processing any time. It is important to remember, when withdrawing consent for marketing purposes that you will not receive any marketing from us or any data may not be processed if we are using consent for the legal basis for processing.

IP Logging and Use of Cookies

When you visit our website, our server will automatically record your IP address and the time and duration of your visit.

As required by legislation, where applicable, this website uses a cookie control system, allowing the user to give explicit permission or to deny the use of /saving cookies on their computer/device.

A cookie is a small file which is placed on your computer’s hard drive which helps analyse web traffic or lets you know when you visit a particular site. We use traffic logging cookies to identify which of our web pages are being used. The data collected is analysed to help us identify ways to improve the website so that we can tailor it to our visitors needs. Further information about cookies can be found at www.aboutcookies.org.

Using your Information

We shall use any personal information you give us in accordance with the six fundamental principles of Data Protection (see above) which form the basis of this policy and the privacy statements that appear on the forms through which you submit your personal information.

If you are a Financial Planner and give us your personal information, we may from time to time contact you by telephone or email to provide information that may be of interest to you, including details about the services we offer, newsletters and invitations to events. In addition, your details may be forwarded to prospective clients looking for a Financial Planner within their area.

Please remember that Solidus will NEVER sell or share your personal information to third parties for the purpose of marketing

How Long will your personal data be kept

We will hold your personal data for differing periods of time depending on the reason we have for processing it. These retention periods are set out below. We will usually retain Licensee data is held for a period of up to twenty-four months following cancellation of their registration with Solidus. Client data is stored securely until Solidus is notified of the Client's death whereupon the data will be deleted/destroyed after six years after death.

Transfer of your information out of the EEA

We are based in the UK but sometimes your personal information may be transferred outside of the European Economic Area (EEA). There are certain suppliers we deal with as part of the services we offer to you which are outside the EEA. On some occasions we may transfer your data outside of the EEA.

Some countries do not have the same data protection laws as the United Kingdom and EEA and we will, therefore, conduct due diligence on such suppliers to ensure your privacy rights are protected.

You have the right to ask us more information about the suppliers and safeguards we have put in place as mentioned above. To learn more, please see your rights section.

What should you do if your personal details change?

You should tell us without delay, so that we can ensure your records are kept up to date and accurate. We are unable to provide you with our services, without accurate records of your personal information.

Your Rights

You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:

To access personal data
To correct/ erase personal data
To restrict how we use personal data
To object to how we use personal data
To ask us to transfer personal data to another organisation
To object to automated decisions
To understand how we protect information transferred outside of Europe
To find out more about how we use personal data
Your right to complain

In some circumstances we may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.

We may not ask for a fee unless in exceptional circumstances.

We aim to respond to all valid request as quickly as possible. We will always let you know if we think a response will take an extended period of time. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.

To access your personal data

You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.

To rectify/ erase personal data

You can ask that we rectify any information about you which is incorrect about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.

You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.

You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.

We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with a legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.

To restrict our use of personal data

You can ask that we restrict our use of personal data in certain circumstances for example:

Where you think the information is inaccurate and we need to verify it
Where our use of your personal data is not lawful, but you do not want us to erase it
Where the information is no longer required for the purpose for which it was collected but we need it to establish, exercise or defend legal claims or;
Where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.

We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.

To object to use of personal data

You have the right to ask us to review and explain our legitimate interests to you where we are collecting, storing and using your personal data on a legitimate interest basis, including where we collecting, storing and using for profiling or by automated means. You have the right to object our legitimate interests and that collection, storage and use unless we can demonstrate that we have compelling legitimate interests to use the personal data. You also have the right to object to us sending you marketing communications as stated above.

To request a transfer of personal data

You can ask us to provide your personal data to you in a structured, commonly used, machine readable format, or you can ask to have it transferred directly to another data controller (e.g another controller).

You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.

Security and Data Privacy

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised manner, altered or disclosed. You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the Economic Area. We are not required to share details of these safeguards where sharing such details would affect our commercial position or create a security risk.

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Our supervisory authority

If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office (ICO). It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).

We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact us in the first instance and we will try to resolve your complaint.

How to contact us

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

Sarah Griffett – sarah@solidustrusts.co.uk

Privacy Notice

What data do we collect

Company

Licensees

Address & Contact