This privacy notice tells you what to expect when Rettie Financial Services collects personal information. Our use of your personal data will be governed by this Privacy Notice.
This privacy notice will apply to you if you are or have been a client of Rettie Financial Services.
Rettie is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.
Changes to this policy
We retain the right to update this policy at any time and we will provide you with a new policy when we make substantial updates.
Our Privacy Policy explained:
What Personal Information is and how and why we collect it and how long we retain it
- Money Laundering
- Legitimate Interest and Disclosures
- Visitors to our website
- Marketing
- Cookies
- Complaints
- Other websites
- Security & performance
What is personal information?
Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.
What personal information do we collect?
We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us. Together with any financial data, status, and history to enable us to offer you financial facilities. Some personal information is classified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions, and sexual orientation. This information is more sensitive, and we need to have further justifications for collecting, storing, and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.
In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, this will be at least one form of photographic identification (such as a passport, a driving licence, or an identification card) and documentation with proof of your place of residence (such as a recent bank statement and/or utility bill). Each provider has their own requirements, and this will be fully detailed in the paperwork provided to you. This is to meet anti-money laundering and counter terrorist financing and prevent fraud.
How we use your personal information
What is the legal basis of our data processing?
Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information.
- For employment-related purposes
- Where we need information to perform the contract we have entered into with you
- Where we need to comply with a legal obligation
- Where the processing is necessary for us to carry out activities for which it is in Rettie Financial Services legitimate interest (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests.
How long do we keep your personal information?
- The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.
Your rights in relation to your personal information
You have a number of rights in relation to your personal information, including the right to:
- Be informed about how we use your personal information
- Obtain access to your personal information that we hold
- Request that your personal information is corrected if you believe it is incorrect, incomplete, or inaccurate
- Request that we erase your personal information
- Ask us to restrict our data processing activities where you consider that:
- personal information is inaccurate
- our processing of your personal information is unlawful
- where we no longer need the personal information, but you require us to keep it to enable you to establish, exercise or defend a legal claim
- where you have raised an objection to our use of your personal information
- Request a copy of certain personal information that you have provided to us and personal information where we are relying on consent to process your personal information
- Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful.
Using your information to help prevent Money Laundering
The UK Government also requires us to verify the identities of individuals and complete due diligence on all our customers to ensure we are complying with the international fight against terrorism and other criminal activities. As a result of this we may need to disclose information to government bodies. We will not sell, distribute, or lease your personal information to third parties unrelated to your enquiry unless we are required to do so by law.
Legitimate Interest
Under the Data Protection Act 2018 we have a number of lawful reasons that we can use (or 'process') your personal information. One of the lawful reasons is called 'legitimate interests'.
So, what does this mean?
When you provide your personal details to Rettie Financial Services, we use your information for our legitimate business interests to carry out our Financial Services work. Before doing this, though, we will also carefully consider and balance any potential impact on you and your rights. Some typical examples of when we might use Legitimate Interest are for direct marketing, preventing fraud, maintaining the security of our system, data analytics, enhancing, modifying, or improving our services, identifying usage trends, and determining the effectiveness of our campaigns.
Disclosures of your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the "Purposes for which we will use your personal information data" table above. We have agreements in place with our third parties that restrict their use of your personal data. We only allow third parties to use your personal data for specified purposes and in accordance with our instructions.
- External Third parties acting as processors in the United Kingdom who provide IT and system administration services; anti-money laundering service providers; and/or financial services to enable us to perform our contract with you.
- If you are obtaining mortgage services, we will disclose personal information that needs to be submitted to lenders in order to fulfil our obligations to seek funding options for you.
- If you are an insurance customer, we will disclose information to be sent to a selected panel of insurance providers in order to obtain suitable options for insurance products for your requirements.
Professional advisors acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accountancy services.
FCA,PRA, HMRC, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Visitors to our website
Rettie Financial Services is committed to protecting and respecting your privacy and we always pledge to handle your data fairly and legally. We are also dedicated to being transparent about what data we collect about you and how we use it. We have structured our website so that you can visit Rettie Financial Services without revealing yourself or any personal information. When someone visits www.rettie.co.uk we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Once you choose to provide us with any information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy statement. For your protection, we are registered under the Data Protection Act 2018 and have given all appropriate notifications to the Information Commissioner.
Marketing
We use your marketing information for marketing purposes, this includes contacting you with relevant newsletters, bulletins, and other information about our services, inviting you to events. We review our communications to ensure that the content that we create is relevant and useful. Our lawful basis for this is your consent. You have the right to withdraw this consent or amend your marketing preferences at any time by contacting compliance@rettie.co.uk
We hold your social media information while operating our social media accounts on Twitter, Facebook, LinkedIn, YouTube, and Google. Our lawful basis for this is that it is necessary in order to pursue our legitimate interest in maintaining a visible, engaging, and relevant social media presence.
Web Banner Advertising
If you visit our website, you may receive personalised banner advertisements whilst browsing other websites. Any banner advertisements you see will relate to products you have viewed whilst browsing our website on your computer or other devices.
These advertisements are provided by Rettie via market leading specialist providers using ‘cookies’ placed on your computer or other devices (see further information on the use of cookies in our Cookie Policy). You can remove or disable cookies at any time.
Use of Cookies by Rettie Financial Services
You can read more about how we use cookies on our link https://ico.org.uk/for-organisations/guide-to-pecr/cookies-and-similar-technologies
Complaints
When we receive a complaint from a person, we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint. We will only use the personal information we collect to process the complaint and to analyse the level of service we provide to improve our customer experience. We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for two 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.
If you have any complaints about the way, we use your personal information please contact the Data Protection Officer at fscomplaints@rettie.co.uk who will try to resolve the issue. If we cannot resolve any issue, you have the right to complain to the Information Commissioner Office at https://ico.org.uk/make-a-complaint.
Other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Security and Performance
Rettie Financial Services uses a third-party service to help maintain the security and performance of the website. To deliver this service it processes the IP addresses of visitors to our website.
Changes to this Privacy Notice
We keep our Privacy Notice under regular review. This privacy notice was last updated on 10th January 2022.
How to Contact Us
If you want to request further information about our privacy policy, how we maintain the security of your personal information and your rights to access your information you can email us at compliance@rettie.co.uk or write to:
Data Protection Officer
Rettie Financial Services Limited
11 Wemyss Place
Edinburgh
EH3 6DH