Chapters Financial has always taken great care over the data that we hold for the clients and contacts that we work with. Because the provision and application of financial services advice and implementation is based on the information (usually personal information) with which we are provided we have always maintained strict practices in the way we hold and use this data.

The new regulations being introduced in May 2018, the General Data Protection Regulation (or GDPR), require us to update our policy to take account of these new regulations and we are pleased to have achieved this below.

Financial Services Regulation

Through financial services regulation, we have been required by our regulator to maintain full records of our interactions with clients, with the specified minimum time frame for maintaining full records varying from 3-5 years for some interactions (Example: Life Assurance) to an indefinite period for others (example; Pension transfers). More can be found on the Financial Conduct Authority's website here: https://www.handbook.fca.org.uk/handbook/COBS/9/5.html

To provide a fully continuous service to our clients, and for regulatory purposes and mutual future protection, we have continued a policy of keeping all records indefinitely and we plan to maintain this practice. We believe this to be a good business practice for our ongoing service provision.


Chapters Financial Limited

Privacy Policy

Our Privacy Policy - your information, your rights and how we use it

Chapters Financial Limited is committed to protecting your personal information.

Our Privacy Policy was last updated on 06 April 2018.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy. More detail can be found on our website, which may be updated over time. If there are important changes such as changes to where your personal data will be processed, we will contact you to let you know.

If you require access to the data we hold on you, we may require additional information from you to confirm your identification before we release any data we hold.

Who we are

We are Chapters Financial Limited ("Chapters Financial Limited").

This Privacy Policy applies to Chapters Financial Limited, Guildford, Surrey.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact:

FAO Data Protection Officer

Chapters Financial Limited

Hadleigh House, 232 High Street, Guildford, Surrey, GU1 3JF

Email: info@chaptersfinancial.com

Information we collect and use

Information about you that we collect and use includes:

  • Information about who you are e.g. your name, date of birth and contact details
  • Information about your contact with us e.g. meetings, emails / letters and phone calls
  • Information connected to your product or service with us e.g. your bank account details,
  • Information about your employment, company benefits, your sources of income, your liabilities, to ensure suitability of the products recommended
  • Information that is automatically collected e.g. via cookies when you visit one of our websites
  • Information you may provide us about other people e.g. joint applicants, dependants or beneficiaries for products you have with us. You must obtain consent from the individual(s) concerned to provide information on other people and we will rely on the understanding that this has been achieved. We may send the individual(s) concerned a privacy notice.
  • With your consent, information classified as 'sensitive' personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it is needed to provide the product or service you have requested or to comply with our legal obligations
  • Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
  • Other information required to complete our contract and legal obligations for providing advice: national insurance number, residency for tax purposes, identification documentation
  • Professional contacts, for liaison purposes if required
  • Your "Goals" and what you want to achieve now and in the future, your attitude and tolerance to risk

What are cookies?

A cookie is a small file – it is saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example - they will remember that you have visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don't have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and market our products and services.

  • Persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)
  • Session cookies - these expire when you close your web browser

Our website contains links to other websites, including social media sites and widgets/apps. We are not responsible for the content or privacy practices (including the delivery of any cookies) of these websites. We strongly encourage you to read the privacy policies of those websites before providing those third parties with your information.

Chapters Financial Limited operates from one website and have one standard cookie policy for our site and as such you can find more detail on our Chapters Financial Cookie Policy here.

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • an application form for a product or service
  • phone conversations with us
  • emails or letters you send to us
  • meetings with one of our financial advisers
  • registering for an event with us e.g. retirement events or webinars
  • participating in research surveys to help us understand you better and improve our products and services
  • our online services such as websites, social media and mobile device application ('Apps')

If you have an accountant / solicitor / or are a member of your employer's pension scheme, the information we collect and use may have been provided by them on your behalf.

We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

  • it is necessary to provide the product or service you have requested e.g. if you wish to invest in a pension or savings product, we will require some personal information including your name, address, date of birth, bank account details etc.
  • it is necessary for us to meet our contractual, legal or regulatory obligations e.g. to send you annual statements, newsletters, to tell you about changes to Terms and Conditions or for the detection and prevention of fraud.
  • it is in the legitimate interests of Chapters Financial Limited e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment; to provide continuing financial advice based on your circumstances, to meet our responsibilities in case of a complaint, to meet our regulatory reporting requirements.
  • where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services; where we use artificial intelligence or computer algorithms to improve the products and services offered to you
  • it is in the legitimate interests of a third party e.g. sharing information with your employer's adviser for the governance of a pension scheme of which you are a member
  • it is necessary for us to meet our legal or regulatory obligations e.g. to verify your identity
  • it is in the legitimate interests of Chapters Financial Limited e.g. to understand our user demographics and use of our website and online products
  • to send invoices or reminder notices or otherwise notify you of changes to our online products or services, and any other purpose related to or ancillary to any of the above.
  • you have given us your permission [consent] to send you information about products and services offered by other parts of Chapters Financial Limited.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

Who we may share your information with

We may share your information with third parties for the reasons outlined in 'What we collect and use your information for.'

These third parties include:

  • Chapters Financial Limited employees
  • Your adviser or employer
  • Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy, our compliance advisers or technology companies; or companies who can help us in our contact with you, for example an internet service provider
  • third parties, such as credit reference agencies for the purpose of processing your applications, our successors and to any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors or accountants
  • Our regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner's Office for the UK (the ICO)
  • Law enforcement, credit and identity check agencies for the prevention and detection of crime
  • HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance

Where we wish to share your personal information with third parties who are not listed above then we shall seek your consent before doing so, unless the data is anonymised (i.e. it does not identify individuals) – in which case we may share the information without first obtaining your consent.

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Where your information is processed by Chapters Financial Limited

All of the information provided to Chapters Financial Limited is processed by us in the UK. Each product provider(s) recommended / used will have their own Privacy Policy as to how they process any data provided to them during an application.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

Protection of Personal Data

Protection of all client information provided or received by us is of paramount importance to our company. Chapters Financial goes to great lengths to ensure that the information provided to us in the course of our business is kept secure at all times. Chapters Financial is a Data Controller under the GDPR, in line with the Data Protection Act 2018 (the 'Act') and any personal and financial information that we hold about you will be held on secure server/computer and/or in paper files and processed subject to the GDPR. This information will be used to administer your application, to deal with queries and to bring to your attention additional services and products that may be of benefit to you. If we are advised that the confidentiality of your information is breached, we will inform you as soon as possible if the breach is likely to result in a high risk of adversely affecting your rights and freedoms. We also have a duty to report certain types of personal data breach to the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. We will document all breaches regardless of whether or not reporting is required.

How long we keep your information

We intend to keep your personal information indefinitely to allow us to provide you with our products or services while you are a customer and to meet current and future regulatory requirements / reporting / mutual future protection, as noted at the beginning of this document.

The individual rights available to you

You have several rights in relation to how Chapters Financial Limited uses your information. They are:

Your right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request.

We reserve the right to charge a small administration fee for requests that are manifestly unfounded or excessive.

Your right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with, if at all.

Your right to request erasure

We shall, upon receipt of a written request from the Customer, return all Customer Personal Data at the end of the provision of the Services to which the Customer Personal Data relates. This will not apply to any Customer Personal Data that we must retain in accordance with any legal and regulatory requirements, and will be directed by any guidance that has been issued in relation to deletion or retention by a Supervisory Authority.

You can ask for your information to be deleted or removed if there is not a compelling reason for Chapters Financial Limited to continue to have it. However, legacy information may prove difficult to remove due to the nature of the backup medium used at that time.It should be noted that the information is stored in a secure safe and cannot be accessed using the systems at Chapters Financial and to remove this data a third party IT specialist would need to be involved.

We reserve the right to charge a small administration fee for requests that are manifestly unfounded or excessive.

Your right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

We reserve the right to charge a small administration fee for requests that are manifestly unfounded or excessive.

Your right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don't use it in the future for those reasons you have restricted.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please contact us directly and we will work to resolve any issues.

If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number

Fax: 01625 524 510