Privacy notice

WHO WILL PROCESS YOUR PERSONAL INFORMATION?

Your personal information will be initially processed by:
    In Partnership Financial Advisers Limited,
    On-Line House,
    50-56 North Street,
    Horsham,
    West Sussex,
    RH12 1RD

Your personal data will be further processed by:
    On-Line Partnership Group Limited,
    On-Line House,
    50-56 North Street,
    Horsham,
    West Sussex,
    RH12 1RD

on behalf of its subsidiary company The On-Line Partnership Limited who acts as our Principal for regulatory purposes. All parties will process your personal data in accordance with this privacy notice.


WHY IS YOUR PERSONAL INFORMATION REQUIRED?

Your personal information may be required to
  • reply to your enquiry
  • enable us to take necessary steps at your request prior to entering into a contract for financial services and to perform such a contract.
  • enable us to take necessary steps at your request prior to entering into a contract of employment when applying for a job vacancy and to perform such a contract.
This may include identity and age verification checks, credit checks, preventing and detecting fraud, money laundering or other crimes and any other requirements in accordance with rules set by the Financial Conduct Authority (FCA) or other employment legislation.


WHAT HAPPENS IF WE WANT TO PROCESS YOUR INFORMATION FOR OTHER REASONS?

Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about we will notify you.


WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION?

Your personal data is essential to enable us to answer your enquiry or to take steps at your request prior to entering into a contract or to perform a contract to which you are a party. Without this information we will not be able to proceed any further.


WHAT MAKES THE PROCESSING LAWFUL?

Because the processing is necessary:
  • For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
  • for compliance with a legal obligation to which we are subject;
  • for the performance of a task carried out in the public interest;
  • for the purposes of the legitimate interests pursued by us.



KEEPING YOUR INFORMATION UP TO DATE

We will record your information exactly as you provide it. You may ask us to update it at any time and we will action your request promptly and where possible notify relevant third parties of any changes.


WHAT ABOUT SENSITIVE PERSONAL DATA?

We only process sensitive personal data
  • because it is necessary for reasons of substantial public interest;
  • to carry out obligations in the field of employment;
  • to protect your vital interests eg. we may pass on an employees information about medical conditions to paramedics if they are unable to give consent due to illness.
Sensitive personal data may include data revealing racial or ethnic origin, data concerning health or data relating to criminal convictions or offences.


HOW WILL WE FURTHER USE YOUR PERSONAL INFORMATION (OUR LEGITIMATE INTERESTS)?

  • To contact you to ensure that our records of your personal information are correct;
  • To respond to questions or grievances you have about employment;
  • For analysis of our website to understand visitor preferences, visitor numbers and which areas of the site are visited most;
  • To review, improve and develop employment conditions or handle complaints;
  • To pursue debts;
  • To evidence company practices;
  • To evidence the standards and processes carried out conform to the company's ethical standards and expectations;
  • To protect the business from risks which might be introduced by an individual;
  • To raise awareness about other opportunities within the company;
  • To provide references to prospective employers when you have named us as a referee.
You have the right to object to processing for these purposes and we shall cease unless we can show we have compelling legitimate grounds to continue.


PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST*

We will use the information provided to protect members of the public against dishonesty, money laundering or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group Plc or Creditsafe Business Solutions Ltd.


WHAT INFORMATION IS REQUIRED?

We only collect information that is necessary to carry out the purposes listed above. This includes information you supply and data we receive from reference agencies. Where practical and lawful we will inform you about any personal data we receive about you from third parties that you may be unaware of.


HOW SECURE WILL YOUR DATA BE?

We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security measures will be in place to prevent unauthorised access, alteration, disclosure, loss, damage or destruction of your information. If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding appropriate security measures in place and only process your information in the way we’ve authorised them to. These organisations won’t be entitled to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we’ve set. Please contact our Data Protection Officer below if you would like further information.


WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?

We may share your information with:
  • Appropriate staff such as those who carry out financial or compliance functions.
  • Organisations that need your information because we are required to provide it by law (eg. The FCA, HMRC, The Information Commissioner etc).
  • Organisations that carry out credit references or identity checks such as GB Group Plc or CreditSafe Business Solutions Ltd. These organisations may keep a record of the information and may disclose the fact that a search of its records was made to its other customers for the purposes of assessing the risk of giving credit, to prevent fraud and to trace debtors.
  • Sometimes other authorised firms with specialist advisers, such as pension specialists, who assist us in providing pension schemes. You will be provided with their details if this applies.
  • Law enforcement agencies, courts or other public authorities if we have to, or are authorised to by law.
  • If you are an employee, our parent company to administer various benefits such as life insurance, our bank to enable payment of salaries and benefits and our group pension provider, Standard Life Assurance Limited.
  • Where we go through a business transaction, such as a merger, being acquired by another company or selling a portion of its assets, your information will, in most instances, be part of the assets transferred.
  • Companies or organisations requesting a reference where you have named us as a referee.
We do not sell your personal information to third parties.


TRANSFERRING DATA OUTSIDE THE EUROPEAN UNION

We do not usually transfer any of your personal data outside of the EU except when we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies, like Creditsafe Business Solutions Ltd, may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases Creditsafe encrypts any data it sends to other selected agencies and only transfers information necessary to carry out checks.


WHAT ABOUT DIRECT MARKETING?

We may use the information provided now and in the future to carry out direct marketing activities as these are legitimate interests pursued by us. Sometimes this includes, with your consent, sharing data with product providers for their marketing activities. You can choose which method you’d prefer us to use to contact you (by email, telephone, SMS or post) and you have the right to object at any time to the use of your personal data for this purpose and we will cease marketing activity.


VISITORS TO OUR WEBSITE

When someone visits www.inpartnership.net we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be clear about this and explain what we intend to do with it.


WHAT ABOUT COOKIES?

You can read more about cookies on our cookie use page.


TYPES OF INFORMATION WE PROCESS

Information about you that we collect and use includes:
  • Information about a person’s identity such as their name, date of birth and contact details
  • Information connected to a product or service with
  • Information about your contact with us e.g. meetings, phone calls, emails / letters
  • Information that is automatically collected e.g. via cookies when you visit one of our websites
  • Information if you visit our office e.g. visual images collected via closed circuit television (CCTV)
  • Information classified as ‘sensitive’ personal information e.g. relating to your health. This information will only be collected and used where it’s needed to provide a product or service you have requested or to comply with our legal obligations in matters of employment.
  • Information you may provide us about other people e.g. joint applicants or beneficiaries for products
  • Information on children e.g. where a child is named as a beneficiary on the application for a policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)



HOW DO WE COLLECT YOUR INFORMATION?

We may collect your personal information from a variety of ways, including:
  • a telephone conversations with us
  • emails or letters you send to us
  • an application form for a product or service
  • meetings with us
  • registering for one of our events
  • our websites or via our social media pages



HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

The Financial Conduct Authority lays down rules relating to how long information should be held for and we will keep your information to meet these requirements. We will not keep your information for longer than is necessary.


REQUESTING A COPY OF THE INFORMATION WE HOLD

You may at any time ask for a copy of the information we hold about you – it is your legal right. We will provide you with a copy of any non-exempt personal information within one month unless we ask you for an extension of time. To protect your personal data, we will ask you to verify your identity before we release any information. We may refuse your request if we are unable to confirm your identity.


IMPORTANT RIGHTS

You have the right, on grounds relating to your situation, at any time to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. We will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defence of legal claims.

You have the right to object at any time to processing your personal data for marketing activities. In such a case we must stop processing for this purpose.


WHAT ARE YOUR OTHER LEGAL RIGHTS?

In addition to the rights above the additional following rights:
  • You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning your data;
  • You have the right to receive data you have provided to us in a structured, commonly used and machine readable format (data portability);
  • You have the right to lodge a complaint with the regulator (see below).

To exercise any of these rights please contact our Data Protection Officer.


HOW TO CONTACT OUR DATA PROTECTION OFFICER

You can contact our data protection officer about any data protection issues by:
  • Writing to:
        The Data Protection Officer,
        In Partnership Financial Advisers Limited,
        On-Line House, 50-56 North Street,
        Horsham, West Sussex, RH12 1RD
  • Telephoning: 01403 214200
  • Emailing: dpo@inpartnership.net



HOW DO YOU MAKE A COMPLAINT TO THE REGULATOR?

  • By writing to:
        Information Commissioner's Office,
        Wycliffe House,
        Water Lane,
        Wilmslow,
        Cheshire,
        SK9 5AF
  • By telephoning: 0303 123 1113
  • By emailing: casework@ico.org.uk
  • By using their website:
        https://ico.org.uk/for-organisations/report-a-breach/


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© In Partnership 2016-17. All rights reserved.    Privacy Notice

In Partnership Financial Advisers Limited trading as In Partnership is an appointed representative of The On-Line Partnership Limited which is authorised and regulated by the Financial Conduct Authority Registered No. 5869204. Registered in England & Wales.

This website is aimed at UK residents.