Featherstone Partners Limited (“Featherstone”) takes the privacy and security of your personal information very seriously. This notice sets out how we process the information we obtain from you or you provide to us so please read it carefully.
For the purposes of the General Data Protection Regulation 2016 and the Data Protection Bill 2018 (the “Legislation”), the data controller in respect of our services and our website www.featherstonepartners.co.uk (“our website”) is Featherstone Partners Limited (a company registered in England and Wales under the company number 11039522, whose registered office is at Old Brewhouse, The Yattendon Estate, Thatcham, RG18 0UE).
We have appointed a Data Protection Officer for the purposes of the Legislation. Details of how to contact them can be found below in the How to Contact Us section.
What information might we collect about you?
We collect information when you register with us or place an order for our products or services. You may give us this information by filling in forms on our website or by corresponding with us by phone, email, in writing or otherwise and it will likely include your name, address, email and other contact details. Additionally, we may collect personal information which might include, but not be limited to, earnings, tax details, information about your pensions and investments and details of other assets and liabilities.
We may also record your telephone calls to us, and those from our staff to you. We make those recordings so that we can review your instructions and our interactions with you, and to improve the service we offer to you and our other clients by training our team.
We do not generally collect or process special categories of data or criminal offence data. Where we do collect or process such data, we will do so with your consent or in order to comply with the legal and regulatory obligations imposed on us.
Cookies are text files placed on your computer which collect standard internet behaviour information. For further information visit www.aboutcookies.org or www.allaboutcookies.org where you will find guidance on how to prevent or remove cookies on your computer.
Why do we hold your personal data?
Featherstone uses the following lawful bases, as set out in the Legislation, for the processing of personal data:
Fulfilment of contract, to provide the services to you that you have purchased from us or contracted us to perform
Legal obligation, to comply with statutory and regulatory record keeping obligations and to assess your application for the risk of money laundering
Legitimate interest, for example when recording telephone calls for training and monitoring purposes or contacting you about services similar to those that you have previously purchased from us
Consent, for example for sending you our newsletter
How will we use the information about you?
We may use the information held about you to manage your account and provide any services you request from us. Such information is necessary for the fulfilment of contract.
In certain circumstance there is a legal obligation on us to hold or provide information for the purposes of the FCA, Financial Ombudsman or a court of law. It is also our duty to detect and prevent, as far as possible, crime including money laundering and financial crime. It is our e may use information held on you to assist us in this requirement.
We may use online information to understand the effectiveness of the content we provide on our website and to deliver to you relevant content, in which we consider you may have a legitimate interest. This might include targeted advertisements as your browse the internet. Furthermore, we may inform you by post, email or telephone about other products and services we think may of interest to you. These will be of a similar nature to those you have already engaged in or shown an interest in.
You have a right at any time to stop us from contacting you for marketing purposes. To ask us to stop please email email@example.com or follow the links in any of our communications.
Generally, we do not rely on consent except where we have specifically requested and received consent from you that we may do so.
Where we store your personal data and for how long?
We store personal data on secure servers and retain it for a reasonable period of time or for as long as the law requires. Your data may be transferred to, stored at and processed at a destination inside or outside the European Economic Area by our service providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. Some information may be held in original hard copy on site at our registered address. Where this does occur, we will take all reasonable steps to ensure its security.
Your rights over the information we hold
You have the following rights in respect of your personal data under the Legislation:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like to exercise any or all of your rights under the Legislation you may contact your advisor or the Data Protection Officer at Old Brewhouse, The Yattendon Estate, Thatcham, RG18 0UE or by telephone 02071 838636. We want to make sure your personal information is accurate and up to dateWe will action any such request within one month and will not charge a fee for doing so.
Changes to our privacy notice
We keep our privacy notice under review and will place any updates on this web page so please check it regularly. This notice was last updated on 20 April 2018.
How to contact to the ICO
You have a right to take any complaint about our information rights practices to the Information Commissioners Office (“ICO”) but we would be grateful for the opportunity to address your concerns in the first instance using the details below. However, if you have a concern about any organisation’s information rights practices including ours, you can contact the ICO on 0303 123 1113.
How to contact us
Please contact us if you have any questions about our privacy notice or information we hold about you:
Telephone – 02071 838636
Email – firstname.lastname@example.org
Post – The Data Protection Team, Featherstone Partners, Old Brewhouse, The Yattendon Estate, Thatcham, RG18 0UE