Privacy Notice

Contact information 

Hulbert West Financial Planners is a trading name of HW Advisory Services Limited a company registered in England & Wales (Reg. 12659210).   

Our office address is: 8 St. Mary’s Court, Carleton Forehoe, Norwich, NR9 4AL.   

You can call us by telephone on 01603 759784 or email info@hwfp.co.uk.  Our website is www.hwfp.co.uk. 

Who is responsible for your personal data? 

Hulbert West Financial Planners (the firm) is responsible for your personal data and is the data controller for the purposes of the UK General Data Protection Regulations 2018 (UK GDPR). 

What type personal data do we collect? 

We collect a wide range of personal information relating to your personal circumstances and financial information about you including details of your assets, liabilities, financial contracts, habits, opinions, goals, and ambitions.   

We also collect information relating to usage of our website using cookies.  These are text files placed on your computer to collect standard internet log information and visitor behaviour information.   

Special categories of personal data 

There are certain categories of personal data that are sensitive by nature.  The categories include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health.   

Depending on the nature of the products and services that you require, we may need to obtain your sensitive personal data.  For example, we may need to ask for detailed health information in relation to an insurance application, or when assessing your preferences for ethical investments we may record your philosophical beliefs.   

We will ask for your specific consent to collect and process special category personal data.  

Dependents and relations 

If you have children under eighteen or responsibility for others without mental capacity, it is likely that we will record information that relates to those individuals.  

We may collect information about your dependants, spouse, beneficiaries or next of kin.  Before providing us with this information, you should provide a copy of this privacy notice to those individuals and have their agreement for the information to be shared with us. 

How we gather your personal information 

We obtain personal information: 

• Directly from you, usually in a face-to-face meeting but potentially also by telephone, email, video call or other means. 
• From other organisations such as investment/pension/insurance providers, where you have provided authority for them to share information relating to your existing financial products. 
• From your professional advisers, where you have provided authority for them to share information. 
• We may also obtain personal information from recording calls or meetings or by making contemporaneous notes of calls or meetings. 

How we use your data 

It is necessary to understand your personal and financial circumstances to provide financial planning, financial advice, and related services.  The personal data we collect is primarily used for providing our services to you.  In addition, we have certain legal obligations and legitimate interests we must also consider.   

We use information collected from our website to improve the website and personalise your repeat visits.   

Under the UK GDPR, the lawful bases we rely on for processing this information are: 

Provision of our contracted services with you 

The main legal basis on which we use your personal data is in the provision of our contracted services with you.   

When you engage with the firm regarding financial services you are entering into a contract for the supply of services.  To perform this contract, we must collect and process your personal data.  

To comply with a legal obligation 

As a regulated financial services company, we have legal obligations we must meet.  We may be required to use your personal data to meet our responsibilities to a regulator, or other legal authority.  For example, we must undertake certain checks to prevent crime and fraud.

Where it is necessary for our legitimate interests 

Throughout our business relationship or after it has ended, we retain your personal data to process it where it is in our legitimate business interest to do so.  For example, we may need to: 

• Respond to complaints. 
• Exercise or defend our legal rights, in the event of any legal claim or to pursue legal claims. 
• To manage our financial position and business capability for regulatory and insurance purposes. 

Sharing and transferring personal data  

We will not share your information with third parties for marketing purposes.  We will not share your information with any other party except as indicated in this Privacy Notice or where required to do so by any statutory, governmental, or regulatory body for legitimate purposes.   

Where necessary to the provision of our service, we may share your personal information with third parties.  The categories of third party are:  

• Financial product providers:  Insurance companies, pension schemes, investment platforms & investment managers. 
• Professional support services:  Compliance consultants, accountancy services and legal advisers. 
• Third party software providers:  Back-office software providers, financial planning tools and anti-money laundering services. 

The organisations to whom we may pass your details also have their own obligations to protect your personal data. 

Where necessary to implement the service that you require, your personal information might be transferred to other countries outside the UK, but only to jurisdictions where suitable protection is in place. 

How we store your personal data 

We will securely retain personal data for the period we are contracted to provide services to you.   

When this period ends, we remain subject to regulatory requirements to retain your data for specified periods dependent on the nature of the service provided.  The minimum periods range from 3 years to indefinitely.   

We will retain data for longer where we believe it is necessary to meet legal obligations and in our legitimate interests to do so.  

Your rights 

Under data protection law, you have rights including: 

• Your right of access – You have the right to ask us for copies of your personal information.  
• Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate.  You also have the right to ask us to complete information you think is incomplete.  
• Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.  
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.  
• Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances. 
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. 
• Your right to complain – If you have any concerns about our use of your personal information, you can make a complaint to us by writing to the Data Protection Officer at our postal address or by email to info@hwfp.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data. 

The ICO’s address:  Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Helpline number: 0303 1231113  –  ICO website: www.ico.org.uk  

You are not required to pay any charge for exercising your rights.  If you make a request, we have one month to respond to you. 

Cookies Policy

For information about how we use information collected by cookies and other tracking technologies, please refer to our Cookies Policy.