Beckett Investment Management Group – Privacy Notice

IF YOU WOULD LIKE THIS DOCUMENT IN LARGER PRINT OR IN ANOTHER FORMAT, PLEASE CONTACT US.

Including Beckett Financial Services Ltd as part of the Beckett Investment Management Group Ltd.

We take your privacy seriously and are committed to handling your personal information lawfully, fairly and transparently under the UK GDPR and the Data Protection Act 2018.

This privacy notice explains how we collect, use, share, store and protect your personal information – including where we use artificial intelligence (AI) or automated tools.

In providing the services to clients, our companies will act as a data controller of any personal data which we collect from or about our clients in connection with the provision of our services.

Where other companies and/or third parties provide support services, such as I.T. development and maintenance, there may be occasions where data is accessible to such parties. Our companies have the appropriate safeguards and agreements in place with each service provider to ensure data is protected and meets Data Protection Regulation requirements.

Contact details

Please contact us if you have any questions about our privacy policy or personal information, we hold about you.

Via post           Dettingen House, Dettingen Way, Bury st Edmunds IP33 3TU

Via phone       01284 754500

Via email        [email protected]

What information do we collect about you?

We collect information about you when you engage us for financial planning, investment management and employee services.

This information will relate to your personal and financial circumstances.

The information could include:

Individual details:

Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, nationality, employer, job title and employment history, and family details, including their relationship to you.

Identification details:

Identification numbers issued by government bodies or agencies, including your national insurance number, passport number, tax identification number and driving licence number.

Financial information:

Bank account, income or other financial information.

Risk details:

Information about you and other connected individuals which we need to collect in order to assess the services required. This may include data relating to health or other special categories of personal data (see below).

Policy information:

Information about the financial products you hold and the insurance policies you take out.

Credit and anti-fraud data:

We’ll verify your identity before providing any services through the use of an electronic identity verification system called Smart Search. We will also conduct these checks from time to time throughout our relationship, not just at the beginning. The check may leave a ‘footprint’ on your credit file but it won’t affect your credit rating.

In certain circumstances if it is necessary for the provision of our services, we collect special categories of data which could include health, criminal convictions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric, or data concerning sex life or sexual orientation.

Communications

to keep accurate records and meet regulatory requirements we may record:

  • Emails, notes of telephone call, meeting notes
  • Records required to meet the FCA’s requirements

Information about connected individuals

We may need to also gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We will provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

How we collect your personal information

We collect personal information from client meetings, calls, emails, online forms and completion of feedback surveys. We will collect personal information about you from you directly but also potentially from your family members, employer or representative, other market participants, credit reference agencies, anti-fraud databases, sanctions lists, court judgements and other judicial databases, government agencies such as the HMRC, open electoral register and any other publicly available data sources.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

How and Why We Use Your Personal information

We must have a lawful basis to process your personal data. Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

We have a contractual obligation

This is the primary legal basis that we intend to use for processing your data. The personal information that we collect about you is essential for us to be able to effectively carry out the services that we have agreed to deliver to you.

We have a legal obligation

Sometimes, collecting personal data is needed to meet our legal and regulatory obligations. For example, UK anti money laundering legislation may require us to collect personal information to verify your identity.

We will obtain your consent

Special category data, such as that relating to health matters, is often required to provide our services. When this is required, we will obtain your explicit consent to collect and process this information.

From time to time, we may wish to contact you to offer additional products or services which may be of interest to you. To do this, we will obtain your consent.

You may withdraw your consent at any time by notifying us at our main business address.

We have a legitimate interest

We rely on legitimate interest to retain relevant data for the purposes of assessing the appropriateness of our services, defending future complaints, and meeting our Professional Indemnity Insurer’s expectations.

We collect information about you in order to provide you with the services for which you engage us.

Who might we share your personal information with?

If you have agreed to and signed our declaration showing you have agreed, we’ll pass on your personal information to our group of companies so that they may offer you their products and services.

We won’t share your information for marketing purposes with companies outside our group of companies / other companies.

Where third parties are involved in processing your data, we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions. These third parties may include:

  • Financial product providers such as insurers, investment platforms and pension providers
  • Compliance consultants, auditors and professional advisers who help us meet regulatory requirements
  • Discretionary investment managers where relevant to your service
  • IT service providers and secure cloud platforms that support our systems
  • Regulators and authorities such as the FCA, HMRC and the Financial Ombudsman Service
  • Credit reference agencies, but only when necessary

Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.

Where we are required to transfer Special Categories of Data for example health information, we will transfer this information via secure postal services or through the use of encryption software to ensure the safe and secure receipt by the intended product provider.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime, we may send your details to third party agencies for identity verification purposes.

Using artificial intelligence (AI) / automated tools to process your personal information

We may use AI tools to help us review information more efficiently and provide you with faster, more accurate services. The AI doesn’t make decisions about you on its own — a member of staff always checks the results.

Purpose of AI use

AI tools may be used for:

  • Generation of Marketing Content
  • Analysis of operational data to support data visualisation and to assess improvement in client service
  • Improving client service through the use of meeting note recording and transcription.

We do not use any systems for making automated decisions. All outputs and decisions made by AI are subject to human review and approval before being used or relied on.

Purpose and lawful basis for processing

The purpose of processing your personal information using AI is to enhance the service we provide to you.

Human review

Any AI assisted output is reviewed by a member of staff before being used or relied on.

Data sharing and storage

Where AI tools are used:

We Will :

  • Ensure only the minimum necessary personal information is processed
  • Anonymise or pseudonymise, where possible, personal information
  • Ensure processing occurs in secure, regulated systems

We do not use AI tools that use your personal information to train public models.

How long do we keep hold of your information?

During the course of our relationship with you, we will retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship, and whenever you inform us about any changes we will update this information at the earliest opportunity.

Please help us to do this by letting us know whenever there are changes to your personal data. If you are providing information about someone else, you confirm that they have appointed you to act for them, to consent to the processing of their personal data, including special categories of personal data, and that you have informed them of our identity and the purposes (as set out in this Privacy Notice) for which their personal data will be processed.

We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:

  • Five years for investment business
  • Indefinitely for pension transfers and opt-out business
  • Three years for insurance business

We also have to keep Identity verification documents (required under UK anti money laundering rules) for:

  • At least 5 years after our relationship with you ends
  • Up to 10 years if we still have an ongoing relationship

These are minimum periods, during which we have a legal obligation to retain your records.

We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so.

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

Your data protection rights

You have several rights under data protection law. This helps you understand and control how your personal information is used.

  • Right to be informed – You can ask us to explain how we collect, use, share, and store your personal information.
  • Right of access – You can request a copy of the personal information we hold about you, along with details of how we use it.
  • Right to rectification – If you think any of your information is wrong or incomplete, you can ask us to correct or update it.
  • Right to erasure – In some situations, you can ask us to delete your personal information.
  • Right to restrict processing – You can ask us to limit how we use your information in certain circumstances.
  • Right to object – You can object to us using your personal information, for example for direct marketing.
  • Right to data portability – You can ask us to send your personal information to you, or directly to another organisation, in a structured, commonly used electronic format.
  • Rights related to automated decision making and profiling – If a decision about you is made without human involvement, you can challenge it and ask for someone to review it.

We will respond to any request you make about your data protection rights within one month.

To make a request, please contact us using the contact details at the top of this privacy notice.

Marketing

We may like to send you information about our products and services and those of other companies in our group, which may be of interest to you at some future date but only if you have agreed to receive marketing information.

You may choose to opt out from receiving any marketing information at anytime.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us immediately by either post telephone or email.

Cookies

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information.

They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. For example, cookies are used to remember users’ preferences and to help navigate between pages efficiently. Our websites may use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

For further information visit http://www.allaboutcookies.org

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Changes to our privacy policy

We keep our privacy policy under regular review and any changes we may make to our Privacy Notice in the future will be posted on our website. Please check back frequently to see any updates or changes to our Privacy Notice.