This privacy notice sets out how Clarkson Wayman Ball Limited (CWB) and CWB Group Services, use any personal information we collect about you. CWB also use the following trading styles:
- Corporate Workplace Benefits
- CWB Caledonia
- Professional Practice Services (PPS)
- PPS Caledonia
- ReSource Mortgages
What information do we collect about you?
We collect information about you when you engage us for financial advice, our advice will cover a wide range of financial strategies and products. 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. Please note we may record calls for training, monitoring and regulatory purposes.
Examples of the types of information we collect are set out below:
- Personal identifiers (e.g. name, title, address, business and/or personal telephone numbers and email addresses)
- Verification information (e.g. passport, driver’s licence, utility bill, bank statement, country of residence, nationality, date of birth, and occupation),
- Finance-related information (e.g. salary and other income, details of accounts held with other providers, loans, mortgage and other debt),
- Education and employment details/employment status.
In order to provide you with services and with your express consent, we may also collect personal information about you from third parties, such as insurance companies, investment platforms, investment managers, pensions providers, pension administrators, mortgage lenders, credit information agencies, your accountant or legal adviser. The information we gather may include details about the products or investments you hold, values, premiums, payments, and information about your tax or legal affairs. If we do not receive the information we request from you, we may not be able to provide you with the requested services due to our legal and/or contractual obligations.
We may also collect information when you voluntarily complete client surveys or provide feedback to us, however, this will be conducted by CWB and is not conducted by a third party.
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 may use your information collected from the website to personalise your repeat visits to the site. For further information visit http://www.allaboutcookies.org/.
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.
We use two types of cookie; essential cookies, which are required to allow you to use our website, and experience & insight cookies.
How long a cookie stays on your computer will depend on whether it is a session cookie or a persistent cookie. Session cookies delete themselves once you close your browser after visiting a website. Session cookies can help with security, and also remember what you’ve done on previous web pages so you don’t have to re-enter information. Persistent cookies stay on your device after you close your browser and for example record your cookie preference, so you don’t need to tell us every time you visit our website. The persistent cookies from our website delete themselves after one month. You can delete them at any time manually if you wish – please refer to the link above for details.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. You should provide a copy of this privacy notice to them before passing personal information to us.
Why do we need to collect and use your personal data?
The primary legal basis that we use for the processing of your data is for the performance of our contract with you or to take steps at your request prior to entering into an agreement with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. We may also process your personal information where it is required by law or where it is necessary for the purposes of our legitimate interests that are not overridden by your interests or fundamental rights and freedoms. Without collecting your personal data we would also be unable to fulfil our contractual, legal and regulatory obligations.
Where special category data is required, we will obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us, to complete verification checks, and communicate and/or market to you.
If you agree, we may email you about other products or services that we think may be of interest to you. We would like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you have agreed to receive marketing information, you may opt out at a later date. If you no longer wish to be contacted for marketing purposes, please contact us by email or post, or by clicking here. [Insert link if applicable for online].
Who might we share your information with?
We will not share your information for marketing purposes with other companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers such as insurance companies, investment platforms, investment managers, pensions providers, pension administrators, mortgage lenders, regulators, auditors, electronic verification agencies, government authorities that we use to arrange financial products for you.
Where third parties are involved in processing your data we will have a contract in place with them that is compliance with applicable laws to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit.
- We encrypt many of our services.
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
- We restrict access to personal information to CWB employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined, or their contract terminated if they fail to meet these obligations.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
In circumstance where we arrange an offshore product for you, your data may be passed to a product provider who operates outside the UK or EEA. If this is a product provider operating in the EEA they will be required to follow the same rules as currently apply in the UK and your data will be handled and protected in the same way. If this is a product provider who operates outside the EAA, we will check that the EU Commission has made an adequacy decision which allows us to transfer data without further action, alternatively we will ensure appropriate safeguards are in place to protect your data.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-out business
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it is in our legitimate interests to do so. In any case, we will not keep your personal data for longer than 7 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We will 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 would 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.
In addition, where certain conditions are met, you have the right to:
- Object to us processing personal information about you;
- Withdraw your consent at any time (where relevant); and
- Have personal information about you erased or to restrict processing in certain limited situations;.
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
How to contact us
20 The Point
Whether it is to request more information or send us some feedback, please do get in touch either by completing our Enquiry Form or contacting us on the details below.