Breed Elliott LLP is committed to protecting your personal information.

This Privacy Notice contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Notice. If there are important changes such as changes to where your personal data will be processed, we will contact you to let you know.

This version of our Privacy Notice was last updated in March 2018.

Who we are

We are Breed Elliott LLP. We were founded in 1993 and we are a Chartered Firm of Financial Planners.

Our aim is to help our clients to feel comfortable and confident about their future financial security so protecting your personal data is of utmost importance to us.

How to contact us

If you have any questions about our Privacy Notice or the information we collect or use about you, please contact our Data Protection Officer:

Jeremy Glynne-Jones, Breed Elliott LLP Tel: 07900 906104
Email: jeremy@breedelliott.co.uk

Information we collect and use

Information about you that we collect and use includes:

• Information about who you are e.g. your name, date of birth and contact details
• Information connected to your personal financial planning e.g. details of your assets and liabilities and your income and expenditure.
• Information about your contact with us e.g. meetings, phone calls, emails / letters
• Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it is needed to provide the advice you have requested or to comply with our legal obligations
• Information you may provide us about other people e.g. joint applicants or beneficiaries
• Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender).

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

• an application form for a product or service 
• phone conversations with us
• emails or letters you send to us
• face to face meetings with one of our financial planners
• participating in research surveys to help us understand you better and improve our advice and service
• our online services such as our website and our Personal Finance Portal

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

• it is necessary to understand your personal and financial circumstances and your future objectives so that we can ensure that the advice we give is suitable and tailor-made to your situation.
• you have given us your permission [consent] to send you information about our services which we believe may be of interest and benefit to you
• if you wish to invest in a pension or investment product, we will require some personal information including your name, address, date of birth, bank account details
• It is necessary for us to meet our legal or regulatory obligations e.g. to send you regular portfolio reviews, tell you about changes to our Client Agreement or for the detection and prevention of fraud
• It is in the legitimate interests of a third party e.g. sharing information with a product provider with whom we are recommending you take out a new investment.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our planning advice.

Who we may share your information with

We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’

These third parties include:

• Savings, investment, protection or pension product providers
• Administration platforms
• Our regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
• Law enforcement, credit and identity check agencies for the prevention and detection of crime
  HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Where your information is processed

All of your information is processed in the UK.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our financial planners and any other employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

We store the majority of your personal data on our back-office system, Intelligent Office, which is administered by Intelliflo Ltd. ISO27001 is an industry benchmark for secure data management recommended by the FCA and Intelliflo is holds ISO27001 certification.

How long we keep your information

We will keep your personal information only where it is necessary to provide you with our advice and services while you are a client.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.

Your individual rights

You have several rights in relation to how Breed Elliott LLP uses your information. They are:

Right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this through this Privacy Notice and through our face to face meetings.

Right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request (DSAR).

Right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

Right to request erasure

You can ask for your information to be deleted or removed if there is not a compelling reason for Breed Elliott LLP to continue to have it.

Right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we do not use it in the future for those reasons you have restricted.

Right to data portability

You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way. For example, if you were moving to an alternative financial planner.

Right to object

You can object to Breed Elliott LLP processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.

Rights related to automatic decision making including profiling

You have the right to ask Breed Elliott LLP to:

• give you information about its processing of your personal information
• request human intervention or challenge a decision where processing is done solely by automated processes
• carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Notice, please contact our Data Protection Officer, Jeremy Glynne-Jones.

If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113