Following the introduction of the General Data Protection Regulation (GDPR) on the 25th May 2018 we are obliged to issue this document to outline how we will use any data we collect from you. The aim of the legislation is to make you aware of where your data is being stored and who has access to it. You will have more rights on how your data is managed. This legislation affects all firms in the UK that hold personal data.
Scope
All clients of Winchester Investment Solutions Ltd (WIS Ltd) whose data is being collected.
Responsibilities
We are responsible for ensuring that this notice is given to clients of ours where we are collecting your personal data.
All Employees of WIS Ltd who interact with our clients are responsible for ensuring that this notice is drawn to a client’s attention and their consent to the processing of their data is secured.
Fair Processing Notice
Any personal data we collect from you will be used for the following purposes:
MANAGEMENT AND ADVICE RELATING TO CLIENTS ASSETS
ADVICE ON PRODUCTS AND SERVICES WHERE REQUESTED FROM US
By consenting to this, you are giving us permission to perform those actions. You may withdraw consent at any time in writing.
What is Personal Data?
Under the EU’s General Data Protection Regulation, Personal Data is defined as
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Special Categories of Personal Data;
Certain data is classified under the Regulation as "special categories":
Racial
Ethnic origin
Political Opinions
Religious Beliefs
Trade-union membership
Genetic Data
Biometric Data
Health Data
Data concerning a natural person's sex life
Sexual orientation
Other
Consent is required for WIS Ltd to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
Why does WIS Ltd need to collect and store personal data?
As you will appreciate, the amount of data we need to collect from you to manage your investments is primarily your basic information such as name, address, email address, date of birth, telephone number, bank account number, passport details and your National Insurance number. It is unlikely we would collect any other data detailed within the “Special” category above.
In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy. We may pass your personal data on to the Third Party Platform provider who WIS Ltd have recommended in the course of dealing with you.
These Platforms are obliged to keep your details securely and use them only to fulfil the service requested. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with their firm’s procedures. If we wish to pass your sensitive personal data onto a third party, we will only do so once we have obtained your consent unless we are legally required to do so.
How WIS Limited uses your information
WIS Ltd will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR).
We will endeavor to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances, the law sets the length of time information has to be kept, but in most cases, we will use our discretion to ensure that we do not keep records outside of our normal business requirements.
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Using your personal data
We will only use the information you provide for the following purposes:
TO MANAGE CLIENTS INVESTMENTS OR PENSIONS AND PROVIDE ONGOING INDEPENDENT FINANCIAL ADVICE.
By completing the Contact page on our website, you are agreeing to our Privacy Policy and that we may contact you using the data provided.