Changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Associations

We confirm that this information will not be used or transferred by us to any other firm, company, entity or person with the exception of Sanlam Partnerships Limited and the product provider without your consent or as may be required by law. We may also provide information to the FCA upon request for regulatory reasons.

How we will use your information

• Perform the contract we are about to enter into or have entered into with you, for example to respond to a query or otherwise to manage our relationship with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, for example to update our records, to prevent fraud, or to respond to a query.
• Where we need to comply with a legal or regulatory obligation, for example to detect and prevent fraud or money laundering, to update your marketing communications preferences and correspond with you accordingly, or to verify your identity.

How is your personal  data collected?

The data

• Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
• Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
• Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
• Any pre-existing investments, mortgages, pensions and/or Insurance products and the terms and conditions relating to these
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not ask for any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Change of purpose

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

Third parties such as Her Majesty’s Revenue & Customs, our regulators, and law enforcement agencies based in the UK who may require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will never sell your personal data to a third party.

Data security

They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Where you have requested us to contact you we will communicate with you via email and/or telephone, depending on what you have specified. By doing so, you acknowledge that because of the nature of the internet the security of emails cannot be guaranteed.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data, see below for further information.

Marketing

Your legal rights

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  (a) if you want usto establish the data’s accuracy;
  (b) where our use of the data is unlawful but you do not want us to erase it;
  (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
  or
  (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to
  use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to utomated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.