ES Walton & Co Limited | Client Privacy Notice
ES Walton & Co Limited are committed to protecting the privacy and security of your Personal Data as we recognise we have a duty of care to the people whose data we hold. This privacy notice will inform you about how we look after your personal data and how the law protects you.
We will only collect and process data when it is absolutely necessary, and when we do so, we will make it clear why we are doing so and how it will be used. We will not share your personal information with anyone else without your permission.
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases yours and your family’s health history. 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.
Understanding what we mean by ‘Your Personal Data’
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 of 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 or providing you with assistance in relation to your finances, requirements of your Personal Data may include:
- Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses, and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing investment products and the terms and conditions relating to these
How we will deal with Your Personal Data
When we speak with you about your financial 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 us 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 insurance providers or 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.
We may also use your Personal Data for marketing purposes, which may include contacting you via email, telephone, or letter with information, news and offers on third party products and our services. You will not be sent any unlawful marketing or spam. We will always work fully to protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt out.
Processing your Personal Data
Where you ask us to assist you with, for example your insurance / ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will 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 / investment 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.
How do we collect your Personal Data?
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, needs and preferences in relation to investments. You will provide information to us verbally and in writing, including email or text.
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, software that is able to verify 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. We may also share your personal data with other companies in our group for services such as ES Walton & Co (Loans and Protection) LLP.
All clients are subject to financial sanction check listed by The Office of Financial Sanctions Implementation we use Sanctions Search which is a service provided by Professional Office Ltd, registered office 45 Market Street, Hoylake, Wirral, registered in England and Wales. Registration number: 06672314.
We use an automated system called Finametrica which is a psychometric risk profiling tool to establish your attitude to risk. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so.
With your permission, we may also use your Personal Data for marketing purposes, which may include contacting you by email, telephone or post. This is likely to be offers on third party products or regarding our services. You have the right to opt out anytime.
What happens to your Personal Data once it is disclosed to us?
In the course of handling your Personal data, we will:
- Record and store your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use your Personal Data for the purposes of responding to any queries you may have in relation to any investments) you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
We will usually store or transfer your personal data within the European Economic Area the “EEA”. The EEA consists of all EU member states; this means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
Sharing your Personal Data
It is likely your Personal Data will be shared with:
- Investment and Insurance Providers
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified.
- Regulated banks or deposits takers (e.g. HSBC Bank)
- Regulated fund managers (e.g. Dimensional)
- Regulated insurance companies (e.g. Aviva)
- Regulated financial dealing companies who operate appropriate electronic portals (e.g. Transact)
- Non regulated (as they are not required to be so regulated) electronic portfolio building software providers or data assessment companies (e.g. Sprint Enterprise and Fina Metrica)
In each case, your Personal Data will only be shared for the purposes set out in this Client Privacy Notice, i.e. to progress your investment enquiry and to provide you with our professional services.
If any of your personal data is required by a third party, we will take steps to ensure that your Personal Data is handled safety, securely and in accordance with your rights, our obligations and the third parties obligations under the law.
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 Client Privacy Notice.
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 becoming accessed unlawfully or maliciously by 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.
Your rights in relation to your Personal Data
- Request copies of your Personal Data that is under our control
- Ask us to further explain how we use your Personal Data
- Ask us to correct, delete or require us to restrict or stop using your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- Ask us to send an electronic copy of your Personal Data to another organisation such you wish
- Change the basis of any content you may have provided us to enable us to market to you in the future (including withdrawing any consent in its entirety).
How to make contact with our Firm in relation to the use of your Personal Data
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:
Contact number: 0151 236 8888
Trading Address: 70 Tradewinds, Liberty Place, East Village, Liverpool, L1 5BG
Registered Address: First floor, 5 Union Court, Liverpool, L2 4SJ
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us using the contact details provided above.
Changes to this Policy
“ES Walton” (and “we”, “us”, or “our”) refers to ES Walton & Co Limited registered in England under company number: 01287566.
“Personal Data ” is any information relating to a living person identified or identifiable. Different pieces of information, which collected together can lead to a particular person being identified, also constitute personal data. This can include names, addresses, contact numbers, email address etc. but it is broader than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified.
“Special Data” includes personal data about a person’s race, ethnic origin, politics, religions, trade union membership, genetics, health, sex life or sexual orientation.
“Data subject” means the person whose personal data is being processed.