Changes to UK data privacy law on 25 May 2018 under the General Data Protection Regulation (GDPR), gives individuals additional rights about the way their personal information is collected and used.
It is one of our fundamental responsibilities as a financial planning business to ensure that we protect the information provided to us by our clients, prospective clients and our website visitors.
This privacy notice explains how O’Sullivan Financial Planning Ltd (“we“, “our“, “us“) collects, uses and shares your personal data, and your rights in relation to the personal data we hold. This privacy notice concerns our processing of personal data for past, prospective and present clients of O’Sullivan Financial Planning Ltd (“you“, “your“).
O’Sullivan Financial Planning Ltd (a UK registered company, registered in England with company number 11095517) is the data controller of your personal data and is subject to the Data Protection Act 1998 (“DPA“) and the General Data Protection Regulation (the “GDPR“).
O’Sullivan Financial Planning Ltd is an Authorised Representative of Vision Independent Financial Planning Ltd.
We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 23rd May 2018.
How do we gather and use your personal information?
We collect your personal information in a number of ways. This begins with any interactions we have with you for example:
How do we share and store your personal data?
We collect the following types of personal data about you:
We may also collect special categories of personal data, including more sensitive personal data, such as information concerning your health and medical conditions (“sensitive personal data“).
When you visit our website, the server collects IP addresses to provide security and prevent brute force or malicious attacks. These IP addresses are not linked to any other personal data. The address for our UK data centre is: Reynolds House, 4 Archway, Manchester M15 5RN
Use of “Cookies”
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites which we believe may be of interest to you. However, once you have used these links to leave our site, you should note that we do not have any control over those other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
How we use your information and our basis for processing that information
We may process your personal data because it is necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Under these circumstances, we use your personal data for the following:
We may also process your personal data because it is necessary for our or a third party’s (this is a person or organisation external to O’Sullivan Financial Planning Ltd) legitimate interests. Our “legitimate interests” include our commercial interests in operating our business (and the business of Vision Independent Financial Planning Ltd more generally) in a client focused, efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements. In this respect, we may use your personal data for the following:
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data for the following:
We may also process your personal data where:
Monitoring of communications
As a matter of course, we monitor the use of company communications equipment by its employees and other staff. This means that when you speak to us by telephone, your calls may be monitored. In the same way, the content of email communications may be monitored for the following purposes:
Disclosure of your information (when it may be shared with others)
In addition to sharing your personal data with Vision Independent Financial Planning Ltd, we may also disclose your personal data:
Transferring your information outside of Europe
We do not operate globally, and therefore your personal data will not be transmitted to and processed outside of the UK in countries that do not provide the same level of data protection as the UK.
How long your information is kept
We will retain your personal data for as long as we are providing you with the services referred to in any relevant Client Agreement, Terms of Business or any other contractual document, and for as long as permitted or required for legal, regulatory, fraud prevention and our legitimate business purposes after the closure of your account, if the relationship between you and us has terminated, or if your application for a particular service or services is declined or abandoned.
You have the following rights:
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
If you have given your consent and you wish to withdraw it, please contact our Data Protection Officer using the contact details set out below. Please note that where our processing of your personal data relies on your consent and where you then withdraw that consent, we may not be able to provide all or some aspects of our services to you and/or it may affect the provision of those services.
If you are not satisfied with how we are processing your personal data, you can raise a concern with the Information Commissioner. You can also find out more about your rights under data protection legislation from the Information Commissioner’s Office website available at: www.ico.org.uk.
If you have any questions you would like to raise about how we process your Personal Data, you can contact our Data Protection Officer by writing to our registered office: Data Protection Officer, O’Sullivan Financial Planning Ltd, 12 Symonds Way, Mawsley, Northants, NN14 1GW.