Who we are
Independent Women is a trading division of Succession Wealth Management Ltd (the controller), also known as Succession Group, whose registered office is situated at Drake Building, Plymouth Science Park, Derriford, Plymouth, Devon, PL6 8BY. Data controller registration number ZA005958.
Legal basis under which your data will be processed
Independent Women, Succession Wealth Management Ltd or any third party associated with us, will only process your personal data for the purpose of fulfilling our contractual obligations to you as detailed in our Terms of Business, or to meet a pre-contractual request. This lawful basis is referred to as ‘Contract’. However, we will only process special categories of data with your explicit consent.
Important Privacy Statement
We take privacy very seriously and therefore urge you to read this notice very carefully as it contains important information about the data we collect about you, what we do with that data and who your data will be shared with. By consenting to us processing your special category personal data, you are giving us permission to perform the actions referred to in this notice. If you do not wish us to continue to process your data, you must inform us immediately.
Who should you contact about your personal data?
Please write to the Succession Group’s Data Protection officer at the address above or telephone 01752 762140. You can also email firstname.lastname@example.org.
What is personal data?
Under the EU General Data Protection Regulation, personal data is defined as:
“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier, such as name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
All data subjects whose data is processed by Succession Wealth Management Ltd, Succession Group and associated companies.
What information do we need to hold?
In order to provide our services, in most cases (but not limited to), we would need to collate information on your personal circumstances, needs and objectives. Personal data for this purpose may include details of your name, address, date of birth, your marital status and details of dependents, your employment status, your income, investments, pensions and liabilities, your tax status and other associated tax details, any life assurance you hold or inheritance tax plans, details of your will, powers of attorney or other legal documents, any identity verification documentation or any other information necessary to provide the service you have requested.
This information may be provided by you directly or with your consent, via a third party.
How do we process children’s personal data?
Generally, we would only process a child’s name and date of birth, unless further details were required to fulfil a service that you have specifically requested, such as to establish investments for or on behalf of the child, school planning purposes or to establish health or life insurance. Whenever we collate information for children, we would always explain why the information is needed. Where a child is party to the contract, we would always consider the child’s capacity to understand the contract they are entering into.
We will never use the child’s personal data for marketing purposes.
How is your data protected?
Your personal information is very important to us.
The information that you provide to us, or others on your behalf, as part of the financial planning process is subject to the General Data Protection Regulation. Some information provided may also contain special categories of personal data (also referred to as ‘sensitive’ personal data).
We take seriously our obligation to implement technical and organisational measures to consider and integrate data protection into all our processing activities.
Under the General Data Protection Regulation “Special Categories” are defined as:
- Ethnic origin
- Political opinions
- Religious beliefs
- Trade union membership
- Biometric data
- Health data
- Data concerning a natural person’s sex life
- Sexual orientation
Where we ask for special categories of personal data we will always tell you why this is needed and how the information will be used.
Why we need to collect your data?
In order to provide you with the services described in our service agreement, we may need to process, both manually and by electronic means, your personal data and where necessary, your sensitive personal data, for the purposes of providing advice, administration, transacting and management or any other purpose necessary for the service you have requested. “Processing” includes obtaining, recording, holding and storing information or data and transferring it to other companies associated with us, product providers, our compliance consultants, the FCA or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.
In any event, Independent Women and Succession Wealth Management Ltd are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.
What are your rights?
This section details your rights in brief, but should you require further details or you have any concerns about our information rights practices, you can refer to the full Succession Fair Processing Notice as detailed at the end of this summary or contact the Succession Group’s Data Protection Officer. If we are unable to resolve your concerns, you have the right to refer these to the Information Commissioner’s Office. Full details can be found at: https://ico.org.uk
Your rights under the EU General Data Protection Regulation include:
If you have any concerns about Independent Women, Succession Wealth Management Ltd, Succession Group or associated companies processing your personal data you must inform us prior to its collection or as soon as possible thereafter.
A right to be informed about the collection and use of personal data
At the time we collect the information, we will always inform you about the purpose for processing your personal data, the retention period for that data and who the data will be shared with. This is called ‘Privacy Information’. Where personal data is collected from another source, in most cases, we will provide this privacy information as soon as possible or within one month of receipt.
A right of access to your personal data and supplementary information
Under the EU General Data Protection Regulation, you have the right to obtain:
- Confirmation that your data is being processed
- Access to your personal data
- Other supplementary information
This is so that you can verify if necessary, the lawfulness of the processing.
A right to have personal data rectified if it is incorrect or incomplete
If you believe that the personal data we hold is inaccurate or incomplete you have the right request that this rectified. This request may be extended to a third party, where the incorrect or incomplete information has been shared.
We would normally respond to such a request within one month, unless particularly complex, where an extension up to an additional two months may be applied. We would always provide an explanation where this is the case and you also have the right to complain to the Information Commissioner at https://ico.org.uk
The right of erasure where there is no compelling reason to continue processing
The right of erasure does not provide an absolute right to ‘be forgotten’, but it does provide a right in certain circumstances to have personal data erased and to prevent further processing, for example where there is no overriding legitimate reason for continuing processing, particularly where processing causes unwarranted and substantial damage or distress. Full details can be found on the ico website highlighted above.
A right to restrict or ‘block’ further processing
This may apply if you contest the accuracy of the personal data being processed or where your interests override the legitimate interests of Independent Women, Succession Wealth Management Ltd, Succession Group or associated companies or where you oppose erasure and request restriction instead.
A right to data portability
In certain circumstances, this allows you to obtain and reuse your own personal data across different services,such as, moving, copying or transferring data from one IT environment to another in a safe and secure way. Full details can be provided upon request or by visiting the ico website.
A right to object to processing based on direct marketing, including profiling
You can withhold or withdraw your consent to direct marketing, including profiling at any time.
Your rights relating to automated decision making (including profiling)
We would only use your data to carry out this type of decision making, where it is necessary for the entry into or the performance of a contract, including verifying your identity to meet Succession’s anti-money laundering and other financial crime obligations and always with your explicit consent. Consent can be withdrawn at any time.
Before we can exercise your rights or release data, we will always undertake checks to verify your identity.
How will my data be stored?
Product providers, lenders and investment managers may administer your policy, any existing policies you may have with them and provide other services, from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of data protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the Regulation even when your personal information is processed outside Europe. We will only store data outside of the UK, where suitable protection is in place.
We treat all personal data and sensitive personal data as confidential and will not process it other than for a legitimate purpose. Steps are taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary. Measures are also taken to safeguard against unauthorised or unlawful processing, accidental loss, destruction or damage to the data.
Subject to certain exceptions, you are entitled to have access to all personal and sensitive personal data held by us. Succession Wealth Management Ltd will provide this free of charge, unless the request is manifestly unfounded, excessive or repeated. If a fee is charged, this will only reflect the costs incurred in delivering the information.
How long will you keep my personal data?
We will keep your personal data securely for as long as is necessary for the purpose it was collected.
Generally, we will retain most data for the duration of the relationship and time limits are applied thereafter, based on the type of data. Some records need to be retained indefinitely to meet FCA regulation.
Our Data Retention policy is available upon request. Actual retention periods may vary depending on each individual’s circumstances, but we would always inform you as part of our privacy information obligations.