information, and how we use it.
We are committed to protecting your personal information.
How to contact us:
The Data Protection Officer,
Castle Investment Consultants, (Widelist Investments Ltd., t/a)
19/21, Junction Road,
Totton, Southampton, SO40 9HG.
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 product(s) or service(s) arranged by us e.g. your financial and bank account details.
*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, and details of accidents, claims and convictions, for General Insurance. This information will only be collected and used where it is needed to provide the product or service you have requested, or to comply with our legal obligations.
*Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us.
*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.
*telephone conversations with us.
*emails or letters you send to us.
*meetings with one of our financial advisers.
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
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:
*you have given us your permission [consent] to send you information about the services offered by us.
*it is necessary to provide the product or service you have requested, e.g. if you wish to invest in a pension or investment product, a mortgage, or a life and/or general insurance product, we will require some personal information including your name, address, date of birth, bank account details, and any necessary underwriting information.
*it is necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud.
*it is in the legitimate interests of Castle Investment Consultants, e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you the relevant communications about the products arranged through us; where we use artificial intelligence or computer algorithms to provide quotations or analysis of the products and services offered to you.
*it is in the legitimate interests of a third party, e.g. sharing information with your employer, for the governance of a pension scheme of which you are a member.
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 certain products or services. We sometimes use systems that make automated decisions based on personal information we have – or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we recommend to you now or in the future.
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:
Companies with which you hold, or will hold products and/or policies.
Companies we have chosen to provide products and services we recommend or advise upon, and other research, consultancy or technology companies who can help us provide our service to you; or to digitally make contact with you, for example an internet service provider.
Our Regulators and Supervisory Authorities e.g. the Financial Conduct Authority (FCA), and 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) for the prevention of tax evasion.
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:
The majority of your information is processed in the UK and European Economic Area (EEA). However, occasionally, some of your information may be processed by outside of the EEA, including countries (such as India). Where your information is being processed outside of the EEA, the Companies for whom the data is being processed, take steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws, and those Companies make regular checks to ensure the businesses processing the data meet these obligations.
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 Consultants and Employees also protect sensitive or confidential information when storing or transmitting information electronically, and must undertake regular training on this.
Our security controls are aligned to normal industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we keep your information:
We will keep your personal information only where it is necessary to provide you with products or services while you are a customer. 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. For instance, information regarding Pension contracts, or Employer’s Liability Insurance may be held long-term, for regulatory or evidential purposes.
Your individual rights:
You have several rights in relation to how Castle Investment Consultants uses your information. They are:
Right to be informed:
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 us to continue to have it e.g. legal or regulatory requirements.
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 don’t 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. 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 a product or policy to another provider, or changing Advisor.
Right to object:
You can object to Castle Investment Consultants processing your personal information where: it is based on our legitimate interests for marketing, or if we were using it for research and statistics.
Rights related to automatic decision making:
You have the right to ask Castle Investment Consultants to:
*give you information about the processing of your personal information.
*request human intervention or challenge a decision, where processing is solely by automated processes.
*carry out checks to make sure that any automated decision making processes are working as they should.
How to make a complaint:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire,
SK9 5AF. Tel: 0303 123 1113 (local rate).