At Argyle, we take client privacy and confidentiality seriously and we will only use your personal information to provide the products and services that you have requested from us.
What Personal Data Will We Collect From You?
During the course of providing you with our Wealth Management services, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data).
Your Personal Data may include:
- Title, names, 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, 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, Pension, Insurance and/or Mortgage Finance products and the terms and conditions relating to these.
How We Will Use Your Personal Data
When we speak with you about your circumstances and requirements, we do so on the basis that both parties are entering a contract for the supply of services.
In order to fulfil our contract to supply you with our Wealth Management services (including Pensions, Investments and Insurance), we have the right to use Your Personal Data:
- In the course of initial discussions with you or when the contract between us has come to an end, provided it is in our legitimate business interests to do so, and your rights are not affected.
- To provide you with the information, products and services that you have requested from us.
- To complete any transaction you are undertaking with us.
- To manage and operate your financial plan with us, including sending you information relating to your products and services.
- To meet a legal or regulatory obligation to which we are subject, even when the contract between us has ended, for whatever reason.
How We Use Certain Parts of Your Personal Data
Where you ask us to assist you with for example your Insurance needs, 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, or, in the case of ethical investments, your religious or philosophical beliefs (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to insurance products and investment providers that may meet your needs and to provide you with advice 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.
Information on Special Category Data 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. We will use Your Special Data in the same way as Your Personal Data generally, as set out in this policy.
How do we Collect Your Personal Data?
We will collect and record Your Personal Data:
- Directly from you - both verbally and in writing, including email.
- From third parties, for example, from your employer or your other Professional Advisers, such as Accountants, Solicitors and/or Mortgage Advisers.
If we use technology solutions to assist in the collection of Your Personal Data, 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.
What Happens to Your Personal Data When 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. 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.
- Submit Your Personal Data to Product Providers (Investments, Pensions and/or Insurance products), both in paper form and on-line via a secure portal, to allow us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any Investment, Pension and/or Insurance policy 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.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment, Pension 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. These third parties will include but may not be limited to, our Compliance Advisers, Product Specialists and other Professional Advisers, such as Accountants, Solicitors and Mortgage Advisers, where we believe this to be required due to your particular circumstances.
In each case, your Personal Data will only be shared for the purpose of providing you with our professional services, as set out in this customer privacy notice. Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
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 all reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a 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, such as to meet the requirements of our regulatory body, 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 should you wish.
- Change the basis of any consent you may have provided 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: The Compliance Manager, Argyle Consulting Limited, 239 St Vincent Street, Glasgow, G2 5QY, or telephone 0141 572 4000.
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time. You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.