In accordance with the UK General Data Protection Regulation (GDPR), this Privacy Notice is intended to provide you with transparent information regarding our Data Protection Policy and how we process your personal data. In doing so, it will explain:

– Who we are;
– What information we collect from you and why;
– Who we share your information with and why;
– What we do with your information and how long we keep it for;
– Your rights in relation to your information.

ABOUT US

We are PPM Wealth Limited and our office address is 177 West George Street, Glasgow, G2 2LB. If you have any questions regarding this Privacy Notice, you can write to our Named Privacy Person (Mr Alan Steven) at this address, email him at alan@ppmltd.co.uk or call him on 0141 435 3300.

Our Data Controller is PPM Wealth Limited, 177 West George Street, Glasgow, G2 2LB. We are registered with the Information Commissioner’s Office (ICO) and our registration number is Z8294763. You can check our registration details on their website which is www.ico.org.uk.

YOUR PERSONAL DATA

Your personal data consists of many different things where one or more of these can identify you. In relation to our services, this will include your personal details, your financial details and your personal circumstances. It may also include personal information which is regarded as more sensitive and is described as ‘Special Category Data’ under the GDPR. This can include information about your ethnic origin, politics, religion, genetics, biometrics, health or sexuality. We will only process Special Category Data where it is required for one or more purposes specified by you and where you have given us additional explicit consent. We will also confirm to you when your data is specified as such. For the purposes of this Privacy Notice, we also use the term ‘information’ to mean ‘personal data’.

CHANGES TO OUR DATA PROTECTION POLICY

Our Data Protection Policy and related procedures have been designed to comply with the GDPR. If, however, we need to make changes to this Policy or the way that we process your personal data, we will write to inform you of the changes and how those may affect you, and to provide you with an updated Privacy Notice.

LAWFUL BASIS FOR PROCESSING 

In accordance with the UK General Data Protection Regulation (GDPR), we confirm that our lawful basis for processing your personal data is because it is necessary in relation to an agreed contract with us for the provision of our services, or because you have asked us to take specific steps before entering into a contract with us.

INTENDED PURPOSES FOR PROCESSING

We collect your personal data in order that we can provide you with our Investment Management Services, which will also include the provision of associated financial advice, administration services and valuation reporting.

KNOW YOUR RIGHTS

GDPR gives you various rights in relation to the processing of your personal data, as follows:

RIGHT TO BE INFORMED- You have the right to receive clear and transparent information regarding why we require your personal data and what we are doing with it, which includes fair processing information as provided by this Privacy Notice.

RIGHT OF ACCESS- Your personal data includes information which can directly or indirectly identify you, and you are legally entitled to access that information should you wish to do so. This access is called a Data Subject Access Request (DSAR).

RIGHT TO RECTIFICATION- You are entitled to have your personal data rectified if it is inaccurate or incomplete.

RIGHT TO ERASURE- In certain circumstances, you have the right to request the deletion or removal of your personal data where there is no compelling reason for its continued processing.

RIGHT TO RESTRICT PROCESSING- You have the right to block or suppress the processing of your personal data where you contest its accuracy.

RIGHT TO DATA PORTABILITY- In certain circumstances, you are entitled to obtain and reuse your personal data for your own purposes across different services, and this right allows you to move, copy or transfer your personal data easily from one IT environment to another in a safe and secure way without hindrance to your usability.

RIGHT TO OBJECT- You also have the right to object to the processing of your personal data.

RIGHTS IN RELATION TO AUTOMATED DECISION MAKING & PROFILING- If we use an automated decision making or profiling process, we will be required to give you information about the processing. You will also have the right to request human intervention or challenge a decision.

If you want to exercise any of these rights, please write to our Data Protection Officer.

WHAT INFORMATION DO WE COLLECT FROM YOU?

We will only collect relevant and sufficient data from you as required in accordance with our lawful basis for processing. Your personal data will include your personal details, financial details and other information including your personal circumstances, financial needs, priorities and objectives. You should inform us of any changes to your personal information which you consider to be relevant to the services we are providing to you.

We will collect your personal data from a variety of sources including:

– Meetings with you- where we will gather and update information about you as appropriate to the services we are providing to you
– Telephone conversations with us- our telephone calls are recorded for regulatory purposes, and when you call us there is a message to inform you of that
– Emails or letters you send to us
– Our Discretionary Management Agreement or Advisory Agreement, which we require you to sign to agree to the Terms and Conditions of our services and which includes this Privacy Notice
– From Application Forms which we pass on to third parties such as Investment Platforms
– From information you provide to us to carry out Anti-Money Laundering checks, which may include details of your passport, driving licence and utility bills
– From our Fact Find document, which we use to gather information from you prior to undertaking services on your behalf

WHY DO WE COLLECT THIS INFORMATION FROM YOU?

We collect this information because we have entered into a contract with you to provide our services to you, or because you have asked us to look at some financial matters for you which may lead to us entering into a contract with you.

CONSEQUENCES OF NOT PROVIDING YOUR RELEVANT INFORMATION

Failure to provide relevant information about yourself may impair our ability to provide our services to you.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Your personal data may be shared with third parties, including:

– Where disclosure is to any person who provides a service to, or performs a function for, us provided that where we disclose information to any such person we shall ensure that such person uses such information for the same purposes as it was originally supplied to us and/or used by us; or
– Where it is required to comply with any applicable law or order of a governmental or law enforcement body; or
– Disclosure is required to investigate, prevent or take action against suspected illegal activities; or
– Disclosure is required to establish or exercise our legal rights or defend against legal claims.

WHAT DO WE DO WITH YOUR PERSONAL INFORMATION?

We process your personal information so that we can provide our services to you and to meet our contractual, legal and regulatory obligations. The privacy of your personal information is very important to us, and our Data Protection Policy and procedures have been developed to ensure this is always maintained.

HOW LONG DO WE KEEP YOUR INFORMATION FOR?

This will depend upon the nature of the services which we provide to you, and as required to meet contractual, legal and regulatory requirements.

If you have entered into a contract with us, your information will be retained for the duration of your contract, or longer where there is a legal or regulatory requirement to keep it, which protects you and us.

If you have made enquiries regarding our services and about entering into a contract with us and do not proceed, we will securely destroy any personal data that you may have provided to us or have asked us to obtain. This information will be destroyed if we have not had any contact from you after six months following our last meeting. Alternatively, you can instruct us in writing if you wish us to destroy this information sooner than six months.

HOW TO REPORT A CONCERN OR MAKE A COMPLAINT ABOUT HOW WE PROCESS YOUR PERSONAL INFORMATION

Protecting the privacy of your personal data is very important to us. However, if you are concerned in any way or wish to make a complaint regarding how we process it, then you should write to our Named Privacy Person. If you are still not satisfied with his response, you can raise your concerns with the Information Commissioner’s Office (ICO), who are our Supervisory Authority in relation to Data Protection. Details of how to contact our Named Privacy Person or the ICO are set out earlier within this Privacy Policy. This does not affect your rights for your complaint to be handled under FCA Rules. Details of our FCA Complaints handling procedures can be provided on request.

FURTHER HELP AND ASSISTANCE

We will be happy to help you with any further questions that you may have in relation to this Privacy Notice and how it affects you. Our contact details are confirmed within this Privacy Notice.