Privacy Notice

London Wall Partners LLP is committed to protecting and respecting your privacy. This privacy notice explains how we use any personal information we collect about you.

For the purpose of the data protection legislation (that is, the EU General Data Protection Regulation 2016/679 (or equivalent legislation that is adopted in England and Wales) and any implementing legislation, rules or regulations that are issued by an applicable supervisory authority, and any other applicable laws, orders and regulations relating to the processing of personal data and privacy in England and Wales), London Wall Partners LLP, whose registered office is Salisbury House, London Wall, London, EC2M 5QQ, is the data controller. We are registered at the UK Information Commissioner’s Office; our data protection registration number is Z3412779. We control the personal information that is collected by us about you and the purposes for which we use that information.

What information do we collect about you?

Clients and prospective clients (as appropriate)

We collect information about you when you engage us / are considering engaging us for financial planning and investment advisory services. In particular, we may collect, store and use:

  • information relating to your personal and financial circumstances, including, but not limited to, your name, address, contact details, both personal and business as appropriate (including email addresses and telephone numbers), details of investments both recommended by us and those which we did not recommend but retain information on, and details of other assets, liabilities, employment or estate planning matters that you provide information on and are included in any financial analysis we undertake for you (including account numbers and details);
  • information about you and / or your family members (if you are a private client) or your representatives, trustees, settlors or beneficiaries (if you are one of our charity or trust clients), that you provide when completing forms for investments, non-investment insurance policies or investment accounts, as well as information that is publicly available;
  • information contained in and records of communications between us, including emails, letters, telephone calls and, in some cases, text messages. We may record telephone calls;
  • information regarding your marketing preferences;
  • information voluntarily provided by you by way of feedback;
  • information about your computer and about your visits to and use of our website (www.londonwallpartners.com) using cookies, which are text files placed on your computer to collect standard internet log information and visitor behaviour information (please see “Cookie, IP Addresses and Web Beacons” below);
  • information gathered from sites where you have added your own information for the purposes of communication (including your business website) and potential marketing opportunities with third parties (for example, LinkedIn); and
  • information required in relation to our legal and regulatory obligations, including Know Your Client requirements, Suitability and Anti Money Laundering verification.

With your consent, we may also from time to time collect sensitive personal information about you, such as data about your health, if this is necessary for the provision of our services.

Current, prospective and former employees

We collect, store and use information about you when you apply for a position with us (either directly or through a third party), are employed by us and after you have left our employment. We do not collect more information than we need to fulfil our contractual, legal and regulatory obligations and to progress your application / employment and that includes, inter alia:

  • information relating to your personal, financial and tax circumstances, including, but not limited to, your name, past and current addresses, contact details (including email address and telephone numbers), national insurance number;
  • educational and employment history, including professional qualifications;
  • bank, pension and salary details;
  • proof of identity and qualifications;
  • criminal records declarations;
  • completed recruitment exercises;
  • references obtained;
  • interview notes and appraisal forms;
  • the results of pre-employment checks (for example, credit and DBS checks, where necessary for regulatory purposes);
  • regulatory approvals;
  • emergency contact details;
  • contracts of employment, and variations thereof; and
  • all emails received and sent from the firm’s account.

With your consent, we may also from time to time collect sensitive personal information about you, such as data about your health, if this is relevant to your employment and fitness to work.

Introducers, suppliers, providers and contractors

We collect, store and use information about you when engaging / contracting with us, including:

  • contact information, including, but not limited to, your name, address, contact details (including email addresses and telephone numbers);
  • bank account details (where appropriate);
  • the results of credit checks (where appropriate);
  • references obtained (if any taken); and
  • signed confidentiality agreements and terms of business.

Other individuals accessing our website

See our Cookie Policy below under “Cookies, IP Addresses and Web Beacons”.

Why and on what basis do we collect and use your personal data?

Clients

The primary reason for processing your data is for the provision of financial planning and investment advisory services to you. The information that we collect from / about you is essential for us to be able to effectively carry out the agreed services that you require under the terms of a contract. The contract between us permits us to provide you with marketing information, financial planning and investment know-how and invitations to business events. Without collecting your personal data we would be unable to fulfil our contractual, legal and regulatory obligations.

Where sensitive personal data is required, we will obtain your consent in order to collect and process this information.

Prospective Clients

The primary reason for processing your data is to enable us to communicate with you regarding the proposed provision of financial planning and investment advisory services to you. The information that we collect from / about you is on the basis of a legitimate business interest and / or your consent. We will only provide you with marketing information, financial planning and investment know-how and invitations to business events if you have provided the relevant consent.

Where sensitive personal data is required, we will obtain your consent in order to collect and process this information.

Current, prospective and former employees

The primary reason for processing your data is in relation to your current, prospective or previous employment with us.

For current employees, we will use your personal data to effectively fulfil the terms of your contract of employment, including the provision of salary and other benefits to you. Some of the information we collect about you is required to comply with our legal and regulatory obligations.

For prospective employees, we will collect and process your personal data on the basis of a legitimate business interest and / or your consent (as appropriate) to allow us to complete the recruitment process and make an assessment of your suitability for the role.

For former employees, we will retain your personal data for a period of time after you leave our employment (see below for further details on data retention) on the basis of a legitimate business interest and / or your consent (as appropriate). This will allow us to satisfy our legal and regulatory obligations and / or provide you with any relevant tax, financial or other information (including for the purpose of any references) relating to your employment with us, as required.

Where sensitive personal data is required, we will obtain your consent in order to collect and process this information.

Introducers, suppliers, providers and contractors

The primary reasons for processing your personal data are (i) to facilitate communication between us (including making business referrals to each other, as appropriate), on the basis of a legitimate business interest and / or your consent, or, where a contract is in place between us, (ii) to manage / administer the contractual arrangements, and (iii) to monitor your performance in the provision of services to us. The contract (or business relationship or consent, where no formal contract is in place) permits us to provide you with marketing information, financial planning and investment know-how and invitations to business events.

Other individuals accessing our website

See our Cookie Policy below under “Cookies, IP Addresses and Web Beacons”.

How will we use the information about you?

Clients and prospective clients

We collect and process information about you in order to (as appropriate):

  • provide you with the services in relation to which you engage us and arising from the client agreement entered into between us;
  • discuss the provision of financial planning and investment advisory services with you and other members of your family, such as your spouse, partner or other adult members of your family, or dependents (if you are a private client or prospect), where it has been agreed that our services will include these third parties;
  • discuss the provision of financial planning and investment advisory services with you and your representatives, settlors or beneficiaries (if you are a charity or trust client or prospect), and it has been agreed that our services will include these third parties;
  • manage and administer the relationship between us;
  • support and assist third parties in relation to any financial investments / products they supply to you;
  • comply with our legal and regulatory obligations (such as those of the Financial Conduct Authority);
  • notify you about changes to our services and otherwise communicate with you, for example, responding to queries that you submit to us and providing our financial planning and investment know-how and invitations to business events;
  • train our staff and monitor / improve our performance in the provision of services to you; and
  • assist in and analyse the effectiveness of our marketing activities.

Current, prospective and former employees

We will collect and process information about you in order to (as appropriate):

  • progress your application and assess your suitability for employment;
  • undertake pre-employment checks;
  • confirm your identity, your right to work in the UK and to seek assurances as to your trustworthiness, integrity and reliability;
  • fulfil our obligations to you as your employer, as detailed in your contract of employment;
  • fulfil our legal and regulatory obligations (as necessary);
  • provide you with information about your remuneration (including pension), benefits in kind and / or tax position; and
  • provide information to future employers and other external parties, at your request.

Introducers, suppliers, providers and contractors

We will collect information about you in order to:

  • maintain our contractual or business relationship with you, which may include making business referrals to each other;
  • ensure that we meet our contractual obligations to the clients that use our financial planning and investment advisory services;
  • monitor your performance in the provision of services and / or functions in respect of which we retain legal or regulatory responsibility; and
  • notify you about changes to our services and otherwise communicate with you, for example, responding to queries that you submit to us and providing our financial planning and investment know-how and invitations to business events.

Other individuals accessing our website

See our Cookie Policy below under “Cookies, IP Addresses and Web Beacons”.

Who might we share your information with?

We will not sell or share your information with third parties for marketing purposes.

Clients and prospective clients (as appropriate)

In order to (i) determine the services we might deliver to you and (ii) tell you about those services by way of provision of marketing materials, and subsequently (iii) deliver our services to you effectively, (iv) meet our legal and regulatory obligations, (v) provide you with information about the firm and its financial planning and investment know-how, (vi) invite you to business events and (vii) provide you with information should our contractual arrangement with you cease, we may share your personal information with or send your details to:

  • certain members of your family such as your spouse, partner or other adult members of your family, or dependents (if you are a private client), where it has been agreed that our services will include these third parties;
  • representatives, trustees, settlors or beneficiaries (if you are a charity or trust client), where it has been agreed that our services will include these third parties;
  • third parties where specifically authorised by you or agreed that this is included in the services we will provide to you (for example, your accountant, tax adviser or legal representatives, as appropriate);
  • third parties, such as those that we engage for professional compliance, accountancy, legal, IT or database management services, telephony and telephone recording services, as well as product and platform providers, that we use to arrange financial products for you, and identity verification providers in respect of the prevention of money laundering and other financial crime;
  • third parties that we have engaged as independent advisers to our Policy Board and Investment Committee;
  • third parties, if we are under a duty to disclose or share your personal information in order to (i) comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), (ii) enforce or apply the terms of any agreements we have with or otherwise concerning you (including the client agreement between us), or (iii) to protect our rights, property or the safety of our clients, employees or other third parties; and
  • external agencies and organisations (such as the Financial Conduct Authority, the Financial Ombudsman Services, the National Crime Agency, the police and other law enforcement agencies) for the purpose of preventing and detecting crime and / or fraud (including fraudulent transactions), money laundering and criminal activity.

Where third parties are involved in processing your data, we will have a contract in place with them (excluding your third party advisers who we engage with as part of our agreed service to you) 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 (in addition to their data protection obligations) and that they will only act in accordance with our written instructions.

Current, prospective and former employees

In order to fulfil our obligations to you as your employer, prospective employer or former employer and our legal and regulatory obligations, we may share your personal information with or send your details to:

  • our payroll and pension providers;
  • our insurers (life assurance, health and other);
  • third parties, such as those that we engage for professional compliance, accountancy, legal, IT or database management services, telephony and telephone recording services, as well as identity verification providers in respect of the prevention of money laundering and other financial crime;
  • third parties that we have engaged as independent advisers to our Policy Board;
  • third parties, if we are under a duty to disclose or share your personal information in order to (i) comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), (ii) enforce or apply the terms of any agreements we have with or otherwise concerning you (including your employment contract), or (iii) to protect our rights, property or the safety of our employees;
  • external agencies and organisations (such as the Financial Conduct Authority, the Financial Ombudsman Services, the National Crime Agency, the police and other law enforcement agencies) for the purpose of preventing and detecting crime and / or fraud (including fraudulent transactions), money laundering and criminal activity; and
  • third parties where specifically authorised by you (including estate agents and future employers, for example, where references are requested and professional bodies of which you are a member).

Introducers, suppliers, providers and contractors

In order to (i) fulfil our contractual or business relationship obligations to you and our legal and regulatory obligations, (ii) provide you with information about the firm and its financial planning and investment know-how, and (iii) invite you to business events, we may share your personal information with or send your details to:

  • third parties, such as those that we engage for professional compliance, accountancy, legal, IT or database management services, telephony and telephone recording services, as well as identity verification providers in respect of the prevention of money laundering and other financial crime;
  • third parties, if we are under a duty to disclose or share your personal information in order to (i) comply with any legal obligation or instructions of a regulatory body (including in connection with a court order), (ii) enforce or apply the terms of any agreements we have with or otherwise concerning you (including your employment contract), or (iii) to protect our rights, property or the safety of our employees; and
  • external agencies and organisations (such as the Financial Conduct Authority, the Financial Ombudsman Services, the National Crime Agency, the police and other law enforcement agencies) for the purpose of preventing and detecting crime and / or fraud (including fraudulent transactions), money laundering and criminal activity.

Other individuals accessing our website

See our Cookie Policy below under “Cookies, IP Addresses and Web Beacons”.

How do we ensure security of the storage and transmission of your personal information?

We have installed and regularly update our firewall and antivirus software. We also apply robust access and security controls to our IT systems and have in place resilient data encryption and storage protocols.

Unfortunately, transmission of information via the internet and email is not completely secure. Though we will do our best to protect your personal data, we cannot guarantee the security of data sent over the internet where the security is outside our control; any transmission is at your own risk. Once we have received your information, we will use appropriate and technical and organisational measures to try and prevent unauthorised access, unlawful processing and accidental loss, destruction or damage.

Where it is necessary for your personal data to be forwarded to a third party we will endeavour to use appropriate security measures to protect your personal data in transit. The vast majority of personal data transfers will occur within the United Kingdom or wider European Economic Area (“EEA”). However, sometimes your personal information may be transferred outside the EEA. If we do so, we will ensure that suitable contracts and / or safeguards are in place with the relevant third parties.

How long do we keep hold of your information?

In principle, your personal data should not be held for longer than is required under the terms of our client agreement with you (or in respect of employees, your employment contract, or in respect of suppliers, contractors and other professional organisations, any contract between us). However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any event, subject to regulatory and legal requirements, we will not retain your personal data for longer than seven years past the time of your death or the end of our relationship. 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.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below. A small fee may be payable by you (to meet our costs of providing you with details of the information we hold about you) and we may request proof of identity before we are able to disclose personal information to you.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. If you believe that any personal information we hold about you is incorrect or incomplete, please contact us using the details below.

Marketing and your mailing preferences

We would like to use your personal information to send you information about our products and services, seminars, events, newsletters, investment commentaries and technical notes that we think may be of interest to you, and will seek the relevant consent from you at the appropriate time.

If you have agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post, or click on the unsubscribe link in our email marketing communications.

Cookies, IP Addresses and Web Beacons

We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration, to improve the structure and content of our site. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

For these reasons we reserve the right to use cookies as an anonymous method of recording your usage of our site and would ask that if you do not wish to have cookies recorded on your machine, you amend the settings on your browser to prevent them from being created. The “Help” section in your browser should provide you with the necessary information to adjust your settings and control the creation and storage of cookies on your hard drive.

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are.

A cookie will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.

Two types of cookies are used by us on our site:

  • Session Cookies: which are temporary cookies that remain in the cookie file of your browser until you leave the site; and
  • Persistent cookies: which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

Cookies can help a website to arrange content to match your preferred interests more quickly. Most major websites use cookies. Cookies cannot be used by themselves to identify you.

Session Cookies allow you to carry information across pages of our site and avoid having to re-enter information and to allow you to access stored information.

Persistent Cookies help allow our website to remember your preferences and settings when you visit our website in the future.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

If you alter your browser settings to refuse our cookies you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you access our site.

Our website may contain electronic images known as web beacons, which allows us to count users who have visited those pages and deliver co-branded services. Web beacons are not used to access your personally identifiable information on our site. They are a technique to compile aggregated statistics about our website’s usage. Web beacons collect only a limited set of information including a cookie number, time and date of a page view and a description of the page on which the web beacon resides.

Other websites

Our website may contain links to other websites. However, once you have used a link to leave our website, please be aware that we do not have any control over that website. This means that we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such a website, or which cookies are used.

This privacy notice only applies to our website only, so when you link to other websites you should read their own privacy notices.

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

You 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 notice

We keep our privacy notice under regular review and we will place any updates on this web page. This privacy notice was last updated on 15 May 2018.

How to contact us

If you have any questions about our privacy notice or information we hold about you please contact us by email at contact@londonwallpartners.com or write to us at:

The Data Protection Compliance Manager
London Wall Partners LLP
Salisbury House
London Wall
London
EC2M 5QQ