Skip to main content

Privacy Policy

Background

This notice covers our requirement to provide you with information on how and why we use your personal data and your rights under the UK General Data Protection Regulation (UK GDPR).

Every organisation that processes personal data must be registered with the ICO.  Our Data Protection Registration Number is ZA548957.  You can check our details by visiting https://ico.org.uk/ESDWebPages/Search

Personal Data

This privacy notice tells you what to expect when Silverwood Money Management Limited collects personal data about you.  The UK GDPR defines personal data as any information that can be used to identify a living person, directly or indirectly.

This may include:

  • Information you provide when you contact us via our website
  • Information you provide when accessing our client portal
  • Information you provide when completing an application form, a fact find document, our cash flow forecast questionnaire or other questionnaires that may be required
  • Information that you provide us with through direct interaction such as via email, via remote meetings or at face-to-face meetings
  • Any other information you provide us with

By providing us with personal data about yourself, you are considered to be a Data Subject. 

The Data Protection Principals

As we are responsible for gathering and using your personal data, we have to follow strict rules called the data protection principles. As such, we must make sure that your data is:

  • Used fairly and lawfully in a transparent manner
  • Used for explicit and legitimate grounds only
  • Used in a way that is adequate, relevant and not excessive
  • Accurate and kept up to date
  • Kept for no longer than is absolutely necessary
  • Handled according to your rights
  • Kept safe and secure
  • Not transferred outside of the United Kingdom without adequate protection

Who Is Responsible For Your Personal Data

Silverwood Money Management Limited, as the Data Controller determines the purposes for which and the manner in which any personal data is, or is to be, processed.

Data Controllers must ensure that any processing of personal data for which they are responsible complies with UK GDPR.

The person who is responsible for Data Protection is Richard Silverwood whose contact details are detailed below.

Why We Gather Personal Data About You

We provide a range of pension, investment and financial protection products.  We process data provided by you (the Data Subject) and other sources in order to deliver the appropriate products and services to you when you engage us for any financial planning advice and investment management services.

The reasons for processing your data is mainly to:

  • Provide you with financial advice – both initially and on an ongoing basis
  • Provide you with illustrations and quotations for pension, investment and financial protection products
  • Arrange and / or administer your pension, investment and financial protection plans and policies
  • Provide you with service and support in relation to your financial arrangements
  • Inform you about our products and services

We do not collect more data than we need to meet our obligations to you and will not retain it for longer than is necessary.

If we are arranging a financial protection policy for you for example, then some of the personal data we ask you to provide us with may be sensitive (special category data) such as details about your physical or mental health, genetic data, gender information, racial or ethnic origin. 

We are permitted by law to process this data.  We will only ever use your personal data for the purpose of progressing your plans or policies, arranging and / or administering your plans and policies, or fulfilling our legal or regulatory requirements such as fraud prevention, help preventing financial crime and audit purposes.

If you provide us with data about another person, in doing so, you confirm that they have given you permission to provide it to us and that we may use their personal data in the same way as your own as set out in this Privacy Notice.

Legal Basis For Processing Your Personal Data

We are required to have a lawful basis in order to process your personal data and the relevant bases which apply:

Purpose of Processing Lawful Basis
Providing illustrations, quotations, arranging and administering plans and policies Necessary for the performance of a contract
Providing information to your appointed Accountant or Solicitor to ensure alignment of financial advice, tax planning or other financial matters.  Necessary for the performance of a contract
To notify you of changes to our service Our legal and regulatory obligations
To prevent and detect fraud, money laundering and other financial crimes Our legal and regulatory obligations
To meet general legal or regulatory obligations Our legal and regulatory obligations
Provision of information on products and services Our legitimate interests
Provision of market commentaries, budget updates, tax year-end reminders, tax planning opportunities and important regulatory or service-related updates Our legitimate interests for existing clients Consent for individuals who are not clients

Who Do We Share Your Details With and Why

To meet our regulatory obligations and our obligations to you, we may therefore need to share your personal data with:

Product Providers including:

Life insurance companies

Investment and pension providers

Regulatory authorities including:

Financial Conduct Authority

Financial Ombudsman

HMRC

Information Commissioners Office

Financial Services Compensation Scheme

Law enforcement authorities including:

National Crime Agency

Police

Action Fraud

Office of Financial Sanctions

Our service providers including:

External auditors / compliance support providers

IT support providers

Financial services products and services research providers

Anti money laundering service providers

Professional Indemnity Insurance provider

Back-office support provider

Website provider

If appropriate, we may share your personal data with your accountant and / or your solicitor.   We will only share relevant and necessary data about you.  Data will be shared securely and only with the accountant and / or solicitor you have explicitly identified.  You can withdraw consent for this at any time by contacting us. 

Data Retention

During our relationship with you we will retain personal data which is necessary to provide services to you. We shall take all reasonable steps to keep your personal data up to date throughout our relationship.

We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

  • Five years for investment business
  • Indefinitely for pension transfers and opt-out business
  • Three years for financial protection business 

These are minimum periods, during which we have a legal obligation to retain your records. We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so but will not retain your data for longer than 6 years past the time of your death.

The reason we retain data indefinitely for pension transfer and opt-out business, is due to the long-term nature of pension arrangements and the potential for future consumer detriment to arise many years after advice is given.  This retention period meets the applicable statutory limitation periods, and the expectations of the Financial Conduct Authority and Financial Ombudsman Service in relation to record keeping and consumer protection

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above. 

Marketing

We will not share your data with outside companies for marketing purposes.

If you are an existing client, we may contact you by email, telephone, text message, post or other agreed means to provide market commentaries, budget updates, tax year-end reminders, tax planning opportunities and important regulatory or service-related updates which relate to services you currently receive or have previously received from us.

The lawful basis for this processing is our legitimate interests, namely to keep our clients informed and supported in relation to the services we provide. We ensure that such communications are relevant, proportionate and expected, and you may opt out of non-essential communications at any time.  We have considered our legitimate interests against your rights and freedoms and concluded that this processing is proportionate, expected and has minimal privacy impact.

If you are not an existing client, we will only send you marketing communications where you have provided your consent, which you may withdraw at any time.

In either case, you are able to opt out of receiving such communications at any time by making contact as detailed below or updating your marketing preferences through your client portal.

Security

We are committed to protecting the security and privacy of all personal data which we obtain and hold about you. 

We employ appropriate technical security measures to protect your personal data and ensure that it is not accessed by unauthorised persons.  Data is stored on secure computers, and information is encrypted wherever possible.

We use a third-party service provider to help maintain the security and performance of our website. To deliver this service it processes the IP addresses of visitors to our website.

If You Send Us An Email

Any email you send to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with office policy.  Email monitoring or blocking software may also be used.  Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

If You Make A Complaint to Us

If we receive a complaint, we make up a file containing the details of the complaint.  The file is likely to contain the identity of the complainant and any other individuals involved in the complaint. 

We will only use the personal data we collect to investigate and process the complaint.

We usually have to disclose the complainant’s identity to whomever the complaint is about.  This is inevitable where, for example, the accuracy of a person’s record is in dispute.

We also usually have to disclose details of the complaint to our professional Indemnity Insurance Broker and Insurer.

We may also be required to provide a copy of the file to the Financial Ombudsman Service should an adjudicator be required to consider the complaint.

We are required to disclose high-level analytics to the Financial Conduct Authority (FCA) concerning the number and nature of any complaints we receive.  This data does not include names or details that identify the specific data subject.

We will keep personal data contained in complaint files in line with our retention policy.  This means that information relating to a complaint will be retained for 3 years from closure.  It will be retained in a secure environment and access to it will be restricted according to the ‘need to know’ principle.

Use of Data Processors

Data processors are third parties who provide elements of our service for us.  We have contracts in place with our data processors.  This means that they cannot do anything with your personal data unless we have instructed them to do it.  They will not share your personal data with any organisation apart from us.  They will hold it securely and retain it for the period we instruct.

Your Rights

You have rights as an individual which you can exercise in relation to the personal data we hold about you. 

Please ask us for an explanation of each should you wish to have more information:

  • The right to be informed
  • The right of access
  • The right to rectification
  • The right to erasure
  • The right to restrict processing
  • The right to portability
  • The right to object
  • Rights to automated decision and profiling

Your Right To Access

You have the right to access any personal data we hold about you, and the right to know why that data is being processed, how long it’s stored for, and who has had or has access to it. 

You will not be charged for us supplying you with this information however we do reserve the right to apply a reasonable fee where requests are deemed excessive.

We will respond to any such request within the maximum time frame allowed of one month.

Automated Decision Making and Profiling

If you use our online portal, or our cashflow forecast service, your personal data will be gathered through the information you enter onto the system.  If you are unsure about the outcome of this automated process you are welcome to contact us to discuss or challenge the outcome.

We regularly check our systems for accuracy and bias and feed any changes back into the design process.

Our Use of Cookies on Our Website

Cookies are small text files that are placed on your computer by websites that you visit.  They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the website. 

We use cookies for statistical and functionality purposes only, we track how many individual unique users we receive and the frequency they visit our website.


The information that we collect from cookies is anonymous and does not identify people or collect personal data about website visits.

We don’t sell the information collected by cookies, nor do we disclose the information to third parties, except to our associated companies and where required by law (for example to government bodies and law enforcement agencies).

Please refer to our Cookie Policy on our website for full details of what cookies we use and why.

You can set your internet browser not to accept cookies and you can visit http://www.allaboutcookies.org to help remove cookies from your browser.  Please be aware that this may prevent some of our website features functioning properly.

Business Sale, Merger or Reorganisation

In the event that our business is sold, merged, reorganised or transferred, or if we are involved in discussions related to such a transaction, we may need to share personal data with prospective buyers, their advisers and professional firms as part of a due diligence process.

Any such disclosure will be limited to what is necessary, will be subject to appropriate confidentiality obligations and will be carried out in accordance with UK data protection law. Where a transaction completes, personal data may be transferred to the new owner so they can continue to provide services to you.

How To Contact Us

For further information on how your personal data is used, how we maintain the security of your personal data and your rights to access the personal data we hold about you or if you would like to make a complaint, you can write to us, email us, or call us as follows:

Richard Silverwood

Silverwood Money Management Limited

9 The Boardwalk

Mercia Marina

Willington

Derby

DE65 6DW

Tel:      01332 311560

Email:  richard@silverwoodIfa.co.uk

If You Have A Complaint

If you have any concerns about your rights and our practices in relation to data protection, please contact us directly using the details provided above.  We will aim to respond to your concerns and clarify how we have processed your data and with whom.  We will also endeavour to put right anything that’s gone wrong.

If you are still dissatisfied after contacting us, you may report your concern to the Information Commissioner’s Office by contacting them as follows:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Tel:             0303 123 1113

Website:    www.ico.org.uk