Effective date: Monday, 21st May 2018
De Carteret Wealth Ltd (DCW) is licensed and regulated by the Jersey Financial Services Commission in Jersey (IB0287). This Privacy notice tells you what to expect when DCW collects, uses and stores your personal information.
We are committed to ensuring that your privacy is protected. We will therefore respect your privacy at all times and will process your personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and any other applicable privacy laws.
How to contact us
Or alternatively, you can find us at:
24 Sand Street
What is personal data?
When we refer to “personal information” or “personal data” in this Privacy Notice, we mean information which identifies you as an individual, or is capable of doing so. In the context of this Privacy Notice, the terms “personal information” and “personal data” may be used interchangeably.
Personal data can include an individual’s name, address and contact details and may include online identifiers such as IP addresses. Data may be held;
- Electronically – on a computer;
- In a paper format – in a filing system; and
- Through accessible records – such as some medical information or employment records
We may hold and use data about you in your capacity as a consumer, business customer, individual, or any other capacity.
What type of personal data we might collect
We may collect any of the following personal information:
- Generic Information about who you are (e.g: Name, Date of Birth, Address and Contact Details)
- Information connected to a service or product (e.g. Bank Account Details)
- Information regarding our communication (e.g. Emails, letters, telephone calls and face-to-face meetings)
- Information that is collected automatically (e.g. via cookies from our website)
- ‘Sensitive’ personal details – this information will only be collected when it is required to comply with our legal obligations or to provide the service/product requested (e.g. Health records or Marital details)
- Information you may provide regarding other relevant people for products you have with us (e.g. Beneficiaries or joint applicants)
- Information relating to children who may be named as a beneficiary on a policy taken out by a parent or guardian on their behalf (In these cases DCW will only use the information required to identify the child (e.g. Name, Gender and Age)
Under Data Protection law, some data may be considered as ‘sensitive’. This could include information relating to race, ethnicity, political, religious, health or criminal activity.
What are cookies?
A cookie is a small data file that certain web sites write to your hard drive when you visit them. The only personal information a cookie can obtain is information a user supplies him or herself. A cookie cannot read data from your hard disk or read cookie files created by other sites.
Cookies, however, enhance our web site performance in a number of ways, including:
- Providing a secure way for us to verify your identity during your visit to our web site
- Personalising your experience on our site, making it more convenient for you
- Using cookies so that we can serve you better
- Information about how visitors come to the website
- Which pages they visit
- Other actions that visitors make whilst on the site
This data is then used in order to improve the user experience of the web site. All user data collected in this manner is anonymous.
How we collect your personal information
Your personal information may be collected either directly from yourself or from a variety of other sources including:
- A service or product application form
- Telephone conversation with an employee/representative of DCW
- Emails or letter correspondence
- Face-to-face meetings
- Our website or other on-line sources
- Research survey participation e.g. a feedback survey on our products and services to aid us in improving them or better understanding our clients
Due to the regulations set out by the General Data Protection Regulation 2018 (GDPR), accuracy of your personal data is of high importance. Therefore, DCW may also collect personal data from publicly available sources, in order to keep our personal records of you up to date and accurate.
Please be aware that we may also be provided with personal information on your behalf from your financial adviser if you are a member of any employer schemes.
How we use your information
DCW will collect and use your personal data only when it is lawful, fair and necessary. We use information held about you in the following ways:
- Where we have been given consent to keep you informed about products and services which we believe might be of interest to you. The information we send will be relevant to you and will relate to products and services either offered by DCW or by select third parties. You may opt out of receiving this information when we collect your details or at any other time;
- To process your application to use our services;
- To undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
- To comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- To help protect your information and prevent unauthorised access to it;
- To deal with any queries, complaints or problems reported by you;
- If required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
- To notify you of changes to our services; and
- To help improve the services we provide to you.
Unless otherwise stated in this Privacy Notice, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests described above.
How we protect your information
We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we provide annual staff training to ensure that all our employees are aware of their responsibilities.
Despite our efforts regarding security it is important to bear in mind that the internet is not a secure means of communication. Personal information communicated through the internet may be intercepted by other people. We cannot guarantee the security of personal information sent to us via email. You accept that you use email to communicate with us at your own risk.
Disclosure of your information
We work alongside a number of service providers in order to ensure that our clients receive the highest quality advice and service. It is for this reason that we may share your personal data with third parties. Circumstances where we may disclose your information include:
- Our, IT providers, service providers and agents in order to provide and maintain the provision of the services;
- Our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information in order to advise us;
- Providers of investments or services we recommend, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, discretionary management services, mortgages, mortgage protection products, insurance products or other such products or services. We may also be required to share information with auditors appointed by the providers of such products or services;
- If required to do so by the Jersey Financial Services Commission or any relevant regulatory authority where they are entitled to require disclosure;
- If required to do so to meet applicable law, the order of a Court or codes of practice applicable to the circumstances at the time;
- To investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
- If tax regulations require us to collect information about each investor’s tax residency. In certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions;
We will not lend or sell your information to third parties without your express consent or where we are required to do so by law.
We will keep your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.
You have a number of rights in relation to how your personal data is used or processed:
- Right of access – you have the right to know what personal data we hold about you and how we use it. If you would like to receive a copy of the personal information held by DCW, you can make a data subject access request. DCW will aim to reply to such requests within the 40 day period specified in the law. Where this might not be possible we will contact you to advise you of this. A data subject access request should be addressed to ‘The Managing Director’ using the contact details found at the end of this notice.
- Right to rectification – you have the right to have any errors in the data we hold you corrected
- Right to erasure (to be forgotten) – you have the right to request the deletion of all personal data relating to you. Please note that DCW may be obliged to retain data in order to meet regulatory or legal requirements.
- Right to restriction of processing – you have the right to restrict how we use your data, e.g. you can request that we do not process your data for any particular purpose or to share it with third parties
- Right to data portability – you have the right to be supplied with all of the personal data that we hold you. for instance to allow you to move your pension to an alternative provider.
- Right to object – you have the right to object to our use of your data
- Right not to be subject to a decision based solely on automated processing – DCW does not base any decision solely on automated processing of your personal data, but if we did you would have the right to restrict our use of your data for this purpose.
How to make a complaint
Or alternatively, you can find us at:
24 Sand Street
If you are still unhappy you may make a complaint to our Supervisory Authority. Their details are:
Telephone: +44 (0)1534 716530
Office of the Information Commissioner