As Partners within the St. James’s Place Wealth Management Partnership, we provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that we provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services we provide.
This Privacy Policy explains when and why we collect your personal information as part of our provision of wealth management services, and also explains how we use your information. If requested, we will provide you with a copy of this Privacy Policy for your records.
“We”, “Us” “Our” refers to the Partner named on this website.
Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by St. James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found https://www.sjp.co.uk/site-services/privacy
In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a “data controller”.
The Partner named on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management.
As Partners within the St. James’s Place Wealth Management Partnership, I provide personal, face to face wealth management advisory services to St. James’s Place clients. St. James’s Place acts as principal to the Partnership, and ensures that any wealth management services that I provide to you are delivered in accordance with the applicable regulatory requirements. St. James Place is also responsible for managing any complaints made by you in respect of the services I provide.
This Privacy Policy explains when and why I collect your personal information as part of my provision of wealth management services, and also explains how I use your information. If requested, I will provide you with a copy of this Privacy Policy for your records.
“I”, “me” “my” refers to the Partner named on this website.
Where St. James’s Place uses your personal data, for example by conducting audits of Partners and dealing with any complaints that you may have, this will be governed by the St. James’s Place Privacy Policy. The St. James’s Place Privacy Policy can be found here.
In order for us to deliver such financial services and deal with any correspondence that may arise, we need to collect and process personal information. This makes us a “data controller”.
The Partner named on this website will be acting as data controller of your personal information, jointly with St. James’s Place Wealth Management.
Depending on our relationship with you (whether you are a prospective or existing client or a business partner), we will collect and use different personal information about you for different reasons.
Sometimes we will request or receive “special categories of personal information” (which is information relating to your health, genetic or biometric data, criminal convictions, sex life, sexual orientation, racial or ethnic origin, political opinions, religious or philosophical beliefs, and trade union membership). For example in order to better understand your current and potential future circumstances and recommend appropriate financial investments, we may need access to information about your health. Details about your health might also be needed for us to make reasonable adjustments when providing our services to you.
We also use details of any unspent criminal convictions for fraud prevention purposes.
Where you provide personal information to us about other individuals (for example, members of your family or other dependents) we will also be data controller of their personal information and responsible for protecting their personal information and using it appropriately. This notice will therefore apply to those individuals and you should refer them to this notice.
In order to make this notice as user friendly as possible, we have split it into different sections. Please refer to the section that best describes your relationship with us.
This section will apply if you are a prospective client and we will need certain information about you to carry out pre-client identification and compliance checks and to set you up as a client on the St. James’s Place client relationship management system.
What personal information may we collect?
What special categories of personal information may we collect?
How will we collect your personal information?
We will collect information directly from you when:
What will we use your personal information for?
There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.
We will rely on the following “Lawful Basis” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following lawful basiss in these circumstances:
Purpose for processing
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:
Third parties including self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
This section will apply if you currently receive wealth management services from us. This section will set out how we use your information.
What personal information may we collect?
What special categories of information will we collect?
How will we collect your personal information?
We will collect information directly from you when:
We will also collect your personal information from:
What will we use your personal information for?
There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.
We will rely on the following “Lawful Basis” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:
Purpose for processing
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:
The police, HMRC and other crime prevention and detection agencies. Third parties and self-employed contractors who we have entered into contractual arrangements with to provide services we need to carry out our everyday business activities such as business administration, partner support specialists who assist us with day to day business operations, document management providers, back office system providers, secure login and email providers, storage warehouses, IT suppliers, actuaries, auditors, lawyers, outsourced business process management providers, our subcontractors and tax advisers.
This section will apply if your personal information has been provided to us by a client to explain their lifestyle and approach to investments and wealth management (for example if you are a spouse or partner, dependant mentioned in a will or trust document, another beneficiary a business partner) and will set out how we use your information.
What personal information may we collect?
What special categories of personal information may we collect?
How will we collect your personal information?
What will we use your personal information for?
There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.
We will rely on the following “Lawful Basis” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
When we use your “special categories of personal information”, we must have an additional “lawful basis” and we will rely on the following Lawful Basis in these circumstances:
Purpose for processing
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to the following parties:
If you are a business partner such as a products provider, portfolio or fund manager or contractor who carries out business functions on our behalf, this section will be relevant to you and sets out our uses of your personal information.
What personal information may we collect?
How will we collect your information?
What will we use your personal information for?
There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.
We will rely on the following “Lawful Basis” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
Purpose for processing
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid reason as set out above and we will only disclose it to the following parties:
If you use our website, this section will be relevant to you and sets out our uses of your personal information.
What personal information may we collect?
How will we collect your personal information?
We will collect your information directly from our website.
What will we use your personal information for?
There are a number of reasons we use your personal information and for each use we need to have a “lawful basis” to do so.
We will rely on the following “lawful basis” when we process your “personal information”:
In each case we assess our need to use this personal information for these purposes against your rights to privacy to ensure we are protecting your rights.
Purpose for processing
Who will we share your personal information with?
We will not sell or transfer your personal information to anyone unless we have a valid purpose as set out above and we will only disclose it to:
We carry out the following marketing activities depending on the relationship that we have with you:
Where you are a prospective client
We will obtain your personal information from LinkedIn searches and use this information to send you letters providing information about our wealth management services that we offer which you might be interested in.
In these letters, we inform you that we will contact you via telephone to discuss our service offerings unless you notify us that you do not wish to receive such a call.
As part of our follow-up telephone call we will discuss the wealth management services we offer which you might be interested in and we will answer any questions that you may have.
Where we have obtained your personal information from a marketing list from a third party, we will have undertaken rigorous checks to verify that those third parties have obtained appropriate consent for us to market to you.
We will use also your personal information to provide you with information about our wealth management services and any newsletters and event invites where you have provided your consent for us to do so.
We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have indicated that you would like to receive this.
Where you are an existing client
We will use your personal information to provide you with information about our wealth management services and any newsletters and event invites where it is part of the ongoing wealth management services we offer or where you have provided your consent for us to do so.
We will also provide you with information of St. James’s Place wealth management products and other third party products which we think may interest you where you have consented to receive this.
General marketing practices
If you wish to opt out of marketing, you may do so by clicking on any “unsubscribe” link or responding to any marketing email communication confirming you would like to opt out or telling us when we call you. Otherwise you can always contact us using the details set out in section 7 to update your contact preferences.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications in connection with the services we offer you.
We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out in section 3 above, to comply with our legal and regulatory obligations or for as long as necessary to respond to concerns you raise with the advice you received. As a financial service firm, we are regulated by the Financial Conduct Authority (the FCA) who imposes certain record-keeping rules which we must adhere to.
If you would like further information regarding the periods for which your personal information will be stored, please contact us using the details set out in section 7.
There are a small number of instances where your personal information is transferred to countries outside of the European Economic Area (“EEA“) such as when we transfer information to our other companies in the SJP group or to third party suppliers who are based outside the EEA or when third parties who act on our behalf transfer your personal information to countries outside the EEA. Where such a transfer takes place, we will take the appropriate safeguarding measures to ensure that your personal information is adequately protected. We will do so in a number of ways including:
We are also entitled under European data protection laws to transfer your personal information to countries outside the EEA where it is necessary for the performance of the contract we have with you.
Depending on our relationship and your particular circumstances, we might transfer personal information anywhere in the world. An example of our regular data transfers outside the EEA is set out below:
If you would like further information regarding our data transfers and the steps we take to safeguard your personal information, please contact us using the details set out in section 7.
You have several rights which you can exercise at any time relating to the personal information that we hold about you and use in the ways set out in this notice. Please contact us at any time using the details set out in section 7 if you wish to exercise these rights; we will not usually charge you.
We respect your rights and will always consider and assess them but please be aware that there may be some instances where we cannot comply with a request that you make as the consequence might be that:
We will of course inform you if any of the above situations arise and if we are unable to comply with your request.
You are entitled to a copy of the personal information we hold about you and certain details of how we use it.
We are happy to provide you with such details but in the interests of confidentiality, we follow strict disclosure procedures which may mean that we will require proof of identify from you prior to disclosing such information.
We will usually provide your personal information to you in writing unless you request otherwise. Where your request has been made electronically (e.g. by email), a copy of your personal information will be provided to you by electronic means where possible.
It would be helpful if could please complete the Data Subject Request Form, available from your partner, to request a copy of the information we hold so that we can ensure we have all the relevant information we need to appropriately respond to your request.
Please help us to keep your personal information accurate and up to date so if you believe that there are any inaccuracies, discrepancies or gaps in the information we hold about you, please contact us and ask us to update or amend it.
In certain circumstances, you have the right to ask us to stop using your personal information, for example where you think that the personal information we hold about you may be inaccurate or where you think that we no longer need to use your personal information.
Where we rely on your consent to process your personal information, you have the right to withdraw such consent to further use of your personal information.
You are entitled to request your personal information to be deleted in certain circumstances such as where we no longer need your personal information for the purpose we originally collected it. When you exercise this right, we need to consider other factors such as our own regulatory obligation, to assess whether we can comply with your request.
You have a choice about whether or not you wish to receive marketing information from us and you have the right to request that we stop sending you marketing messages at any time. You can do this either by clicking on the “unsubscribe” button in any email that we send to you or by contacting us using the details set out in section 8.
Please note that, even if you opt out of receiving marketing messages, we may still send you communications which are relevant to the nature of services we offer you.
In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data.
In certain circumstances, you can request that we transfer personal information that you have provided to us to a third party.
When you exercise this right, we need to consider other factors such as our own regulatory obligations, to assess whether we can comply with your request
We do not carry out any automated decision making to provide products and services to you.
If you believe that we have breached data protection laws when using your personal information, you have a right to complain to the Information Commissioner’s Office (ICO).
You can visit the ICO’s website at https://ico.org.uk/ for more information. Please note that lodging a complaint will not affect any other legal rights or remedies that you have.
If you would like any further information about any of the matters in this notice or if you have any other questions about how we collect, store or use your personal information, you may contact our St. James’s Place Data Protection Officer at St. James’s Place plc, St. James’s Place House, 1 Tetbury Road, Cirencester, Gloucestershire, GL7 1FP, United Kingdom, [email protected] and 01285718453.
From time to time we may need to make changes to this notice, for example, as the result of changes to law, technologies, or other developments. We will provide you with the most up to date notice.
This notice was last updated on 22nd August 2018.
Copyright © Toby Thomson Wealth Management Limited.
All rights reserved.
SJP APPROVED xx/xx/xxxx
The Partner Practice is an Appointed Representative of and represents only St. James’s Place Wealth Management plc (which is authorised and regulated by the Financial Conduct Authority) for the purpose of advising solely on the group’s wealth management products and services, more details of which are set out on the group’s website www.sjp.co.uk/products. The ‘St. James’s Place Partnership’ and the title ‘Partner Practice’ are marketing terms used to describe St. James’s Place representatives.
Thomson Private Wealth is a trading name of Toby Thomson Wealth Management Limited.
Toby Thomson Wealth Management Limited, Registered Office: 116 Brompton Road, Knightsbridge, London, SW3 1JJ. Registered in England and Wales, Company No. 11163429