We’ll collect personal data about you for various reasons (as further detailed in this privacy notice) including: 1) so that we can deliver the products and services you’ve requested from us, 2) to meet our legal responsibilities, 3) to understand how you are using our website, and 4) to send marketing communications to you.
Your personal data includes things such as your name, your address and, if you go through our BiggerPicture process, your personal and financial circumstances. We use data like this to help us deliver services, to let you know about any changes to our services and other purposes set out in the In detail section below.
We take our responsibility for keeping your data safe and secure very seriously. As such, we have implemented suitable technical and organisational measures to ensure the confidentiality, integrity and availability of your data.
As a financial planning business, there are lots of lawful reasons for having to process your data. We’ll usually keep your personal data for at least six years after we’ve stopped working with you, but our regulator or insurers may require us to keep it for longer than this.
We may have to share your personal data with third parties (for example where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so).
You have lots of rights when it comes to your data. You can see what data we have about you at any time. Where you have previously provided consent to us processing your data, you can withdraw your consent to us keeping it too. And of course, you can ask us a question about it at any time.
You can do this by sending an email to our Technical and Compliance Manager, Abi Thomas, at email@example.com.
Please note: there are some areas where regulatory obligations or legitimate interest might prevent us from getting rid of all your data.
More information about your rights is set out in the in detail section below.
1. Cooper Parry Wealth Limited (registered company no. 04220777) (we’ll refer to ourselves as “the business”, “we” or “us” for the rest of this policy) and the other companies in our group (that’s: Cooper Parry Group Holdings Limited; Cooper Parry Advisory Limited; Cooper Parry Holdings Limited; Cooper Parry Group Limited; Creaseys Wealth Limited; Horizon Accounts Limited; Future Perfect Financial Planning (UK) Limited; Future Perfect Solutions Limited; Snapshot Software Limited; Cooper Parry Audit Holdings Limited; and Cooper Parry Audit LLP), take data protection seriously.
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you get in touch, login to your account or register for one of our events.
This website is not intended for children.
It is important to read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements any other notices and privacy policies and is not intended to override them.
We are the controller and are responsible for your personal data.
2. We will collect personal data about you when:
3. Here’s the kind of information we might keep hold of:
Personal data means any information about an individual from which they can be identified (not including any data which has been anonymised). We may collect, use, store and transfer the following types of personal data:
If you fail to provide personal data:
Where we need to collect personal data by law, or under the terms of the contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
4. How we use personal data we hold about you
In order to process your data, we are obliged to identify at least one of what’s called our “lawful basis for processing”.
We may process your personal data:
Where we process any special category data, we recognise that we need to take even more care over it. When using your special category data, we will use it in accordance with the law and will ensure that suitable and specific measures are in place to safeguard your fundamental rights and interests. We process special categories of personal data under Article 9(2)(a) GDPR, where you have provided explicit consent (this is “explicit consent”). Examples of when we may process special category data about you includes health information we receive from you as part of providing certain services to you (i.e., wills, probate and administration of trusts matters).
We might use your personal data for more than one of these purposes at the same time.
We might use your personal data to:
5. How long do we keep your personal data?
We’ll retain personal data for as long as reasonably necessary to fulfil the original purpose for which it was collected.
When assessing how long we keep your personal data, we consider:
We’ll keep your data for at least six years too – even if we stop working with you
Legislation, regulations and our professional indemnity insurers ask us to retain your data after we’ve stopped acting for you.
The period of data retention varies from one type of service to another – for some types of service (such as some types of pension transfer), it’s indefinite! (Feel free to ask us for more information about this if you have any concerns).
6. Where there’s a change of purpose
If we need to use your data for another purpose other than the reason we collected it, we’ll only do this if the new purpose is compatible with the original one.
If we think it’s necessary to use your personal data for a new purpose, we’ll do so transparently by keeping you informed and reminding you of your rights before we start any new processing of your data.
7. Who has access to your personal data?
We may share your personal data with third parties for the purposes set out in this policy, this may include:
Let’s be clear – we won’t sell or rent your personal information to third parties.
Any of our people with access to your information have a duty of confidentiality under the ethical standards that we are held to by the Financial Conduct Authority, which we’re all required to follow. We will require any of our people with access to your information to respect the security of your personal data and treat it in accordance with the law.
8. People or businesses (“Third Party Service Providers”) working on our behalf
In some cases, we use other people or business (we call them “Third Party Service Providers”) to deliver professional advice and cloud-based information storage facilities.
Third Party Service Providers includes other third parties that provide us with services such as IT and cloud services, third party agencies for identity verification purposes or product providers to help us with any recommendation.
Whenever we use Third Party Service Providers, we disclose only the personal information that’s necessary to deliver the service. We also have a contract in place that requires them to keep your information secure and not to use it for their own purposes.
All of our Third Party Service Providers are required to put in place appropriate security measures to protect your personal data.
We’ll not release your information to other third parties unless:
9.Our security measures in place to prevent the loss, misuse or alteration of your personal data
We’ve put security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They’ll only process your personal data on our instructions and they’re subject to a duty of confidentiality.
We’ve put procedures in place to deal with any suspected data security breaches. In the event of an actual or suspected breach of your data, we’ll notify you and any applicable regulator of a suspected breach where we’re legally required to do so.
10.International transfers of personal data:
Whilst your data will usually be processed in our offices in the UK, to allow us to operate efficient digital processes, we sometimes need to transfer your personal data outside the UK, as some of our external third parties may be based outside the UK. This is ordinarily done within the European Economic Area (EEA), but on some occasions, we may process your data outside of the EEA.
Whenever we transfer your data outside the UK, we ensure a similar degree of protection is afforded to it and will ensure that adequate safeguards and protection measures are in place in compliance with the applicable data protection laws.
We have applied due diligence and have suitable contractual agreements in place with these third-party service providers that meet all relevant regulatory requirements.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
11.Your duty to inform us of changes in your personal data
It’s important that the personal data we hold about you is accurate and current. If it changes, please let us know of any changes of which we need to be made aware by getting in touch with your usual Cooper Parry Wealth contact or using the contact details below.
12.Your rights in connection with personal data
Under certain circumstances, the law gives you the right to:
If you wish to exercise any of these rights, please get in touch with us. Our contact details are below.
We try to respond to all legitimate requests within one month but if we are unable to, we will notify you of this and keep you updated.
At this point it’s worth mentioning you usually won’t have to pay a fee to exercise any of these rights, however, we may charge a reasonable fee if your request for access is clearly unfounded or excessive and whilst it’s not like us, we might even decline to comply with the request in such circumstances. It’s also possible that we may not be able to comply with the request for compliance reasons.
As a final note, if you choose to exercise any of these rights, without exception we will ask you to confirm your identity, which means we might need to request specific information from you. This is to make sure your personal information isn’t disclosed to anyone who has no right to receive it.
13.Your right to withdraw consent
Where you have previously provided consent to our processing your data, you have the right to withdraw your consent at any time. To withdraw your consent, please get in touch using the contact details below.
Once we’ve received notification that you’ve withdrawn your consent, we’ll no longer process your personal data for the purpose or purposes you originally agreed to. That’s unless we have another lawful basis for doing so.
14.Changes to this privacy notice
We keep this privacy notice under regular review and will place any updates on our website at www.cooperparrywealth.com/privacy-notice. You can get paper copies of this privacy notice by sending an email to firstname.lastname@example.org.
This privacy notice was last updated on 19 April 2023.
If you have any questions regarding this notice or if you’d like to speak to us about how we process your personal data, please email our Technical and Compliance Manager, Abi Thomas, at email@example.com.
You also have the right, at any time, to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Here are the ICO’s contact details:
Information Commissioner’s Office
Telephone: (0303) 123 1113 (local rate) or (01625) 545 745