Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information
relating to your existing circumstances, your financial situation and, in some cases, your health and
family health history (Your Personal Data). This document is important as it allows us to explain to
you what we will need to do with Your Personal Data, and the various rights you have in relation to
Your Personal Data.

What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances.
Your Personal Data may identify you directly, for example your name, address, date or birth, National
Insurance number. Your Personal Data may also identify you indirectly, for example, your
employment situation, your physical and mental health history, or any other information that could
be associated with your cultural or social identity.

In the context of providing you with assistance in relation to your Insurance/
Investment/Mortgage/Finance requirements Your Personal Data may include:

The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your insurance/investment/mortgage requirements we do so on the
basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use
Your Personal Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has
come to an end for whatever reason, we have the right to use Your Personal Data provided it is in
our legitimate business interest to do so and your rights are not affected. For example, we may need
to respond to requests from mortgage lenders, insurance providers and our Compliance Service
Provider relating to the advice we have given to you, or to make contact with you to seek feedback
on the service you received.

On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator
The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to
which we might be subject. In such circumstances, we would be processing Your Personal Data in
order to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance / ethical investments, in particular
life insurance and insurance that may assist you in the event of an accident or illness, we will ask you
information about your ethnic origin, your health and medical history (Your Special Data). We will
record and use Your Special Data in order to make enquiries of insurance / investment providers in
relation to insurance products that may meet your needs and to provide you with advice/guidance
regarding the suitability of any product that may be available to you.

If you have parental responsibility for children under the age of 13, it is also very likely that we will
record information on our systems that relates to those children and potentially, to their Special

The arrangement of certain types of insurance may involve disclosure by you to us of information
relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This
is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data
generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged
freely between insurance intermediaries such as our Firm, and insurance providers, to enable
customers to secure the important insurance protection that their needs require.

How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you.
You will usually provide information during the course of our initial meetings or conversations with
you to establish your circumstances and needs and preferences in relation to
investment/mortgages/finance. You will provide information to us verbally and in writing, including

We may also obtain some information from third parties, for example, credit checks, information
from your employer, and searches of information in the public domain such as the voters roll. If we
use technology solutions to assist in the collection of Your Personal Data for example software that
is able to verify your credit status. We will only do this if we have consent from you for us or our
nominated processor to access your information in this manner. With regards to electronic ID checks
we would not require your consent but will inform you of how such software operates and the
purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:

Sharing Your Personal Data
From time to time Your Personal Data will be shared with:

In each case, your Personal Data will only be shared for the purposes set out in this customer privacy
notice, i.e. to progress your investment/mortgage/finance and/or insurance enquiry and to provide
you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you
marketing or promotional messages: it is shared to ensure we can adequately fulfil our
responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

We do not envisage that the performance by us of our service will involve Your Personal Data being
transferred outside of the European Economic Area.

Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our
legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being
accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring
information to us, such as not sending confidential information over unprotected email, ensuring
email attachments are password protected or encrypted and only using secure methods of postage
when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of
six years, or in instances whereby we have legal right to such information we will retain records

Your rights in relation to Your Personal Data
You can:

How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to
exercise any of your rights set out within it please contact:

If we feel we have a legal right not to deal with your request, or to action, it in different way to how
you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised
disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge
a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their
website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Renew Advice