Data Protection – Privacy Notice
At Edgewater Associates Limited (“Edgewater”), we are aware of the trust you place in us and our responsibility to protect your privacy and keep your personal data secure in accordance with Data Protection legislation.
This privacy notice covers:
- How and why we process your personal information;
- The sources of information about you;
- The parties we may disclose it to;
- How long we will retain your information;
- What rights you have in respect of your personal data; and
- How you can contact us with any further queries or concerns.
Below are two definitions to help you understand this privacy notice:-
‘Independent Financial Adviser’ ‘(IFA)’ means a Qualified Financial Adviser employed by Edgewater.
‘Provider’ means any third party company we work with on your behalf that offer financial products or services such as pensions, annuities, life insurance, critical illness cover, income protection, private medical insurance, general insurance, and mortgages.
The Data Controller:
Edgewater Associates Limited is the Data Controller for the purposes of the Data Protection Act 2018 and in relation to all the personal data provided to us. The primary legal basis for which we process this personal data is for the performance of service contracts we enter into (or may enter) into with you through our Terms of Business;
Why do we collect personal information?
We collect your personal information for any of the following purposes:
- It is necessary to review your financial requirements to allow us to consider whether we can offer you our services;
- For the preparation of the entering into a customer relationship for financial advice or insurance brokering services with you;
- It is necessary to provide existing customers with our services, to perform obligations under our Terms of Business, and to generally maintain relationships with our customers;
- To manage any 3rd party arrangements required by Edgewater in order to run the business and provide you with our services;
- To consider any applications for employment or sponsorship; and
- To comply with our legal and regulatory obligations as a regulated financial services provider.
Your personal information is only collected and used for the purpose(s) it was provided for, and of which you were aware at the time your information was supplied to us. We will limit the collection of your personal information to only that which is needed in order to satisfy the intended purpose.
It is ultimately your choice as to whether to provide us with your personal data, but please note that if you fail to do so, or you fail to provide us with accurate data, we may not be able to properly provide you with our services.
What information do we collect and how do we collect it?
In order to fulfil the purposes above, we will need to collect your personal information. We collect it from you when you initially provide it to us, every time you contact us during the administration of our relationship with you, and from additional sources such as background checks and/or references. Information is collected when you meet with us, complete forms, correspond with us, telephone us, or send us an email. We may also get your personal information from Providers during the management of any financial products you take out, such as for example, a pension Provider in the case of crystallisation of a pension, or an insurance company in the case of an insurance claim.
This information can include all, or a combination of any of the items listed below depending on the nature of your relationship with us:
- General personal details including your name, date of birth, place of birth, nationality, gender, marital status and National Insurance Number;
- Your contact details (address, telephone numbers, e-mail);
- Additional information about your lifestyle and/or insurance requirements, such as details of your car, your home, your household, your health, or your travel arrangements;
- Information about your other policies, such as claims data and history, quotes history, additional pensions held, or your payment history;
- Pension information including pension scheme names, pension scheme numbers, fund/investment details, tax information, NI Number, salary, occupation and information on other savings;
- Information about your home from you and from publicly available sources, third parties and from information already held by Edgewater about your home;
- Employment details such as employment status, employer contact details, and salary information;
- Financial details such as bank account details, savings, investments, tax information and/or reference checks you may provide to us;
- Health data (please refer to Sensitive Information, below);
- Character references if you are applying for a job with us;
- Publically available information (generally obtained through internet searches) such as news articles or public register information which is obtained from background searches or reference checks; and
- Criminal convictions or bankruptcy information for certain general insurance products such as motor insurance
Personal information about others:
We may collect information about other members of your household or family e.g. family members who may drive your car or who may be included on a travel or health insurance policy or on whose life you take out a life insurance policy.
If you give us information about another person it is your responsibility to ensure and confirm that:
- You have told the individual who Edgewater is and how we use their personal information, as set out in this Privacy Notice; and
- You have permission from the individual to provide that personal information (including any sensitive personal data) to us and for us to process it, as set out in this Privacy Notice.
Certain types of personal information are classed as “sensitive” under the Data Protection legislation, or otherwise referred to as “special categories” of data. This includes information about your health, race, ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership and genetic and biometric data.
In order to offer advice or find suitable products and/or services, Edgewater needs to collect special categories of data (such as health data for health insurance advice) during the normal course of our business. We must get your separate explicit consent to process and disclose any special categories of data.
Sometimes we may indirectly come across sensitive information. In the event we are likely to (or do) come into possession of your sensitive personal data, we will contact you separately to seek your consent for its processing.
How do we use your personal information?
We store and process the personal information that you (or third parties) have provided to us in any or all of the following ways:
- To assess your application for a product, service or quote;
- To Request or obtain quotes for the products you are seeking;
- Arranging a product from your chosen Provider;
- To conduct background checks for financial products, insurance or other related services;
- To perform our obligations under any contract, or terms of business, or employment contract you have entered into with us;
- To supply you with the information and product(s) and/or service(s) that either you have requested from us, or wish to provide to us;
- To manage our relationship with you;
- To reconnect with you if you move house or change employer;
- To handle claims;
- To consider any application for employment you may have submitted;
- For general business purposes, to prepare management and accounting information necessary for the conduct of our business, including audit;
- For the prevention and detection of crime, including AML purposes, fraud detection and debt collection; and
- To comply with any and all statutory responsibilities.
Information you submit through our website may be held and processed by our Internet Service Provider, but it is only held and processed on our behalf and under our strict instruction.
Disclosure of Personal Information:
During the term of your relationship with us we may disclose your personal information to any of the following parties to allow us to properly manage our relationship with you:
- To the Providers of your financial products to allow them to supply your chosen policies/insurance/cover;
- To persons acting as our agents or on our behalf under a strict code of confidentiality where we outsource functions relating to our services (for example, our IT system providers, document storage and archiving companies etc.);
- To credit reference agencies and fraud prevention agencies to conduct background and credit checks on our behalf; (for further information see below)
- To anyone we transfer or may transfer our rights and duties under your Customer Terms of Business;
- Back to you during the course of your relationship with us and we will be in periodic communication with you;
- If you are a current or former employee; to future employers who seek references about you (who will require your consent to do this); or
- To legal or regulatory bodies (such as the Isle of Man Financial Services Authority) as required by law or regulation.
Otherwise we will keep all of your personal information confidential unless you give us consent to transfer it to a third party.
It is not normally necessary during the usual course of business to transfer your personal data outside of the Isle of Man or the UK, however, in the event it is necessary, it will be done so in accordance with the requirements of Data Protection legislation. These requirements include the provision that the recipient of your personal data must have the same level of protections in place as you are entitled to on the Isle of Man or in the UK. We will advise you in the event that your personal data is to be transferred in this manner.
The exception to this is, if you as a customer live outside the Isle of Man, UK or the EEA and we are sending your personal information back to you, this will be necessary in order to communicate with you and for providing you with our services. Our e-mails to you are subject to encryption and any sensitive documentation will be sent via registered mail.
Credit Reference Agencies:
In considering whether to enter into any agreement with you, we (or your Provider) may search your record and that of any joint applicant or any guarantor, using standard public searches and credit reference agencies. This may include a quotation search from a credit reference agency which will appear on your credit report and will be visible to credit providers. It will be clear that this is a quotation rather than a credit application by you.
Where you agree to pay periodically under a provider’s agreement, the status of your quotation search from the credit reference agencies may be updated to reflect your credit application and this will be visible to credit providers. Credit reference agencies may keep a record of the search. Providers may also pass to credit reference agencies information they hold about you and your payment record. The information will be used by other credit lenders for making credit decisions about you, and people with whom you are financially associated, for fraud prevention, money laundering prevention.
This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and other members of your household.
We currently use the following 3 credit reference agencies. For further information regarding how they will process your information, please refer to the links provided:
Fraud Prevention Agencies:
We may share your personal information with fraud prevention agencies if we feel fraud has been or might be committed. These agencies collect, maintain and share data on known and suspected fraudulent activity for the purposes of fraud prevention. These records may be searched and shared with other organisations by the fraud prevention agencies.
We have a legal obligation to report suspected fraud to law enforcement agencies.
The fraud prevention and law enforcement agencies we share data with are:
- Isle of Man Financial Intelligence Unit;
Please telephone or write to us at the address stated below if you would like further details of the fraud prevention agencies.
How long do we retain your personal information?
We are permitted by law to retain your information for as long as is necessary in relation to the purposes for which the information was originally provided. This includes our legal requirement to hold information for at least 6 years following the termination of a customer relationship or transaction.
We will therefore hold your personal information, accounting records, client due diligence (CDD) and transaction records for a minimum of six years following the termination of our relationship with you, except in the following circumstances:
- Where records are required for investigation by law enforcement, where they will be retained for as long as required by the Constable or competent authority; or
- Pension information including pension transfers, pension opt-outs or free standing additional voluntary contributions which will be kept for a much longer period. Pensions by nature last for a lifetime or longer (in the cases of pension transfer exercises) and therefore, to enable Edgewater to respond to queries, records will be retained for lifetime of the pension plus six years.
If you have been unsuccessful in applying for a job with us, we will retain your information for a maximum of 6 months unless you give us permission to retain it for longer.
Once your information is no longer necessary, it shall be destroyed in accordance with Data Protection legislation.
Under Data Protection legislation you have the following rights free of charge. To exercise these rights, please contact us using any of the methods detailed below.
- Access to Personal Data
Subject to exceptions detailed in Data Protection legislation, you have a right of access to all personal data we hold about you. If you wish to exercise this right, or you have any questions regarding your personal data, please write to the Data Protection Officer at the address overleaf. We will respond within one month from receipt of a valid request, and in any event, without undue delay.
- Automated Decision Making:
Edgewater does not use any kind of automated decision making technology.
You have the right to the rectification of inaccurate data, and to obtain completion of incomplete personal data. To correct or amend your personal data, please contact the Data Protection Officer at the address below with the details. We will make the required changes as soon as possible.
In certain situations you have the right to request that your personal data is erased, however, there are limitations to this right.
Examples of grounds for exercising your right to erasure include:
- Your Personal data is no longer necessary for the purpose of the performance of a contract between us and you;
- Where data has been unlawfully processed by us;
- Where data has to be erased to comply with a legal obligation;
- Where a right to object to direct marketing or the right to object to processing has been exercised.
Examples of limitations to your right of erasure include:
- It is still necessary for the performance of a contract between us and you;
- Our compliance with legal obligations to retain client records for certain periods of time (as detailed above); and
- Our establishment, defence or exercise of legal claims.
- Restriction of Processing
You have the right to restrict our processing of your personal data in the following circumstances:
- If you contest the accuracy of personal data processed by us, (we may restrict processing for a limited period to enable us to verify the accuracy and amend the data as necessary);
- We no longer require your information for the purposes we originally obtained it;
- We have no legitimate grounds for processing your information or your information has been processed unlawfully.
If you wish to exercise this right please contact the Data Protection Officer at the address overleaf with the full details.
- Data Portability
You have a right to receive your personal information that you have provided to us, in a structured, commonly used and machine readable format. You also have a right to have this personal data transmitted to another data controller (i.e. another business), where technically feasible.
- Right to Object
You have the right to object to us processing your personal data in the following circumstances:
- For direct marketing purposes;
- Profiling in relation to direct marketing.
- Right to Lodge a Complaint
If you have a complaint regarding the way we are processing your personal data, please address it with us in the first instance in the hopes that we will be able to resolve the matter with you. However, if you do not want to address your concerns to us, or we have failed to satisfactorily respond to your complaint, you have the right to complain to the Data Protection Supervisor. The contact details are below:
First Floor, Prospect House
Isle of Man
Tel: +44(0) 1624 693260
If you wish to receive information about our products or services please let us know by any of the contact options provided below.
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The Data Protection Officer and Contact Details:
If you have any questions or concerns regarding this notice or you wish to exercise your rights, please contact us, addressing your query to the Data Protection Officer using any of the following methods:
Writing: Edgewater Associates Limited, 1st Floor, Clarendon House, Victoria Street, Douglas, Isle of Man, IM1 2LN
Telephone: +44 (0)1624 654000