Privacy Policy

Sterling Financial Planning Limited is an appointed representative of New Leaf Distribution Limited, which is an FCA Regulated Firm and this privacy notice explains how we use any personal information we collect about you.

Sterling Financial Planning Limited provide financial planning solutions and advice through experienced and qualified advisers based in the UK.

Currently, Sterling Financial Planning Limited and New Leaf Distribution jointly determine the purposes and means of processing personal client data relating to giving advice.  This means we are joint data controllers for these core advice giving activities and therefore responsible for managing this client data and ensuring compliance.

However, Sterling Financial Planning Limited is solely responsible for some activities, for example any direct marketing that we undertake.

What is this privacy statement about?

To supply our customers with our services we need to use information about you, and some of that may be personal or private. For example, we may need to know your name and address, details of how you would like to be contacted (e.g. your mobile phone number), or how you would like to pay for the services we provide you.

As we do this, we’d like you to take some time to read this privacy statement. It will explain what information we might collect about you, why we collect it, what we may use it for, and who we may give it to. We’ll also explain your rights towards your information and how we look after it while we have it.

What information do we collect about you?

We collect information about you when you engage us for financial planning and advice as well as protection advice. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete client surveys or provide feedback to us.

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.

Why do we need to collect and use your personal data?

To supply our customers with our services we need to use information about you, and some of that may be personal or private. For example we may need to know your name and address, details of how you would like to be contacted (e.g. your mobile phone number), or how you would like to pay for the services we provide you.

As we do this, we’d like you to take some time to read this privacy statement. It will explain what information we might collect about you, why we collect it, what we may use it for, and who we may give it to. We’ll also explain your rights towards your information and how we look after it while we have it.

What information do we collect about you?

The information we collect about you may vary based on what service we provide to you. Typically, we need details like:

  • Your name and address so we know who you are and what services you need from us
  • Your contact details like phone number or email so that we can keep in touch with you about our services.
  • Your bank account or other financial details so we can manage your payment for our services.

If you are receiving some financial services advice, we will need to know more information about your current position. This might include information regarding:

  • Your employment information
  • Your assets and liabilities

Some financial services products may require us to collect information about your health and lifestyle.

We only collect information about you that we need to make sure you get the best service from us. We respect your privacy and we try to minimise what we do collect.

How do we collect information about you?

We prefer to collect the information we need directly from you. That way, you know what we have, and we can be sure you’ve provided us with the most accurate and up to date information.

We will usually do this:

  • When you complete our fact find and discussion document.
  • When you contact us for any reason.
  • If you complete an online form.
  • If you interact with us through the client portal.
  • If you complete a survey.
  • When completing application forms.

What do we do with the information we collect about you?

We use your information in various ways, such as to:

  • Meet the purposes that you provided your information for
  • Provide you with the services you want
  • Let you know about goods or services we feel would be beneficial to you.
  • Prevent fraud, money laundering and financial crime
  • To confirm your identity.
  • Credit scoring and assessment, and credit management (where applicable).
  • Keep our records accurate and up to date.
  • Comply with any legal or regulatory obligations we may have.

Who might we share your information with?

We appreciate that you have provided your information to us and may not want us to share it with other people or organisations, however sometimes it is necessary for us to do so.

We only share your information where we are permitted or required to by law, or where you have requested us to do so. We may share your information with, for example:

  • Any of your family, associates, or someone who represents you, where you have asked us to do so.
  • Our employees who provide you with our services.
  • Carefully selected organisations and specialists to help us provide you with our services.
  • Credit reference and fraud prevention agencies in order to help prevent and detect fraud as part of our due diligence process.
  • Any person, organisation or regulator where we are required to because of a court order, regulatory responsibility, legal duty or statutory obligation.

We are careful to minimise such sharing.

Although we are a UK company, we may sometimes share your information with an organisation who is outside the UK. Such companies may also be outside of Europe. We may do this, but we will only do so where we are permitted to by law.

Whenever we share your information we do everything we can to make sure it is protected from misuse or loss.

How do we look after and secure your information?

When we use information about you we take all reasonable efforts to do so fairly and lawfully.

We think it likely that our customers know we use information about them, and we provide notices of such wherever we can.

We never use information about you unless it is lawful for us to do so and we have a clearly defined need or purpose.

When we collect information about you we ensure that we minimise what we collect. We try not to keep your information for longer than we need it and we ensure that the records we have about you are managed properly and deleted promptly and securely when we no longer need them.

We make every effort to ensure your rights towards your information, which we detail below.

We take appropriate care to secure the information we hold about you. We have robust technical security such as passwords and information encryption. We also have policies and procedures to ensure your information is only available to our employees who need to see it to do their job, and we train those employees appropriately.

Also, we establish robust procedures and contracts to extend these protections to any other person or organisation we may need to give your information to.

In everything we do with your information we try to be fair, lawful, and open, and we take seriously our obligations towards your privacy and the protection of information we may hold about you.

How long do we keep hold of your information?

In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. However, we’re subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than five years from the end of our regulatory obligations to retain the data.

You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Marketing

We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post

What are ‘Cookies’ and how does Sterling Financial Planning use them?

A cookie is a piece of information that is stored on your computer’s hard drive by your Web browser. On visiting the Web Site, your computer server will use the cookie to guarantee a secure connection. Most browsers accept cookies automatically, but usually, you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you may not be able to use certain features of this Web Site.

Forces Family Finance may conduct analyses of user traffic. These analyses will be performed through the use of IP addresses and cookies which are required to ensure a secure server connection. Sterling Financial Planning Limited does not use cookies to store any personal data or browsing habits.

Third parties such as advertising agencies and content providers may use cookies on this Web Site to collect personal information about you. Sterling Financial Planning Limited recommends that you read the privacy statement of any third party before using their web site. Sterling Financial Planning Limited is not responsible for the use of such cookies or any other ways in which your personal data may be collected or used by such third parties.

What can you do if you are unhappy with how your personal data is processed?

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 (local rate)

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll place any updates on our web page (and/or) inform you of any changes when they occur.  This privacy policy was last updated on 16/03/2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you: by email at:

Or write to the Privacy Officer, New Leaf Distribution Limited, 1 High Street, Southend on Sea, Essex, SS1 1JE