Data protection policy - Go IFA

DATA PROTECTION POLICY

Welcome to the Go IFA Ltd's privacy policy.

Go IFA Ltd respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and when you are a customer of Go IFA Ltd.  It tells you about your privacy rights and how the law protects you.  Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.   IMPORTANT INFORMATION AND WHO WE ARE
1.1 Purpose of this privacy policy
This privacy policy aims to give you information on how Go IFA Ltd collects and processes your personal data through your use of this website (including any data you may provide through this website) when you sign up to our newsletter or purchase a service from us as a customer.  
This policy applies to all our customers (“you”), whether you are an individual contacting us directly or a member of a group scheme set up by your employer.  
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy replaces the original policy communicated to you and supplements other notices and privacy policies, such as those provided by third parties who we may share your data with.
1.2 Controller
Go IFA Ltd is the controller and responsible for your personal data (collectively referred to as "Go IFA", "we", "us" or "our" in this privacy policy).  We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
1.3 Contact details
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager:
Email address: office@go-group.co.uk
Postal address: 1 Dunstall Court, Astwood Lane, Feckenham, Redditch, B96 6QH
Telephone number: 0300 012 5860
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
1.4 Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5 Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.   THE DATA WE COLLECT ABOUT YOU
2.1 Personal data types collected
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data: title, first name, last name, username or similar identifier, date of birth, gender, nationality, civil or marital status, policy number, passport number or driving licence number
  

• Contact Data: email address, telephone numbers, phone number and address
  

• Financial Data: bank account and payment card details, tax information, loans and credit commitments, personal credit history (including credit reports), sources of income and expenditure
  

• Employment Data: employment and remuneration information, (including salary, bonus schemes, overtime, sick pay and other benefits) and employment history
  

• Health Data: health status and history, details of treatment and prognosis, medical reports (further details are given below specifically about the processing we may undertake in relation to this type of information)
  

• Criminal Data: historic or current criminal convictions or offences
  

• Family Data: first and last name of dependants, date of birth of dependants, health status and history of dependants
  

• Transaction Data: details about payments to and from you and other details of services you have purchased from us, including pre-existing financial products and the terms and conditions relating to these
  

• Technical Data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
  

• Profile Data: your username and password, purchases for our services made by you, your interests, preferences, feedback and survey responses
  

• Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences.
  

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any information about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership or biometric data.  We do collect Health Data and Criminal Data to arrange certain types of insurance and related activities such as underwriting, claims and fraud management.  These categories are classified as special category data.  
2.2 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?
3.1 Data collection methods
We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Financial, Employment, Health, Criminal, Family and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, meetings or otherwise. This includes personal data you provide when you:
  

     •    apply for our services;
     •    use of one our advice tools that enable us to deliver our advice to you;
     •    create an account with us;
     •    subscribe to publications;
     •    request marketing to be sent to you; or
     •    give us feedback or contact us.

• Interactions with our independent financial advisors.  You may give your Identity, Contact, Financial, Employment, Health, Criminal, Family and Marketing and Communications Data to our independent financial advisors by filling in forms or by corresponding by post, phone, email, meetings or otherwise. This includes personal data you provide when you:
  

     •    apply for services;
     •    create an account;
     •    subscribe to publications;
     •    request marketing to be sent to you; or
     •    provide feedback.

• Data capture systems. Sometimes we will use online data capture systems to help us record your data. We will send a link to you via email, but this link will be secure and will not contain any personal data until it is completed by you. We use these tools to help us with our work. We also use such tools to assist our team with profiling you against a risk scale so we can assess your suitability for certain investment solutions during the advice process.  Our final decisions are always made by a member of our team.  In all cases, paper capture forms are available for completion.
  

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our cookie policy for further details: http://www.go-ifa.co.uk/cookies.html.
  

• Third parties or publicly available sources. We may also obtain some information from third parties, for example, for credit checks, fraud prevention agencies, information from your employer, and searches of information in the public domain such as the voters roll.  Sometimes we may have to use technology solutions to assist in the collection of your personal data for example software that is able to verify your credit status.
  

  
4.   HOW WE USE YOUR PERSONAL DATA
4.1 Use of personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
  

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  

• Where we need to comply with a legal obligation.
  

See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message and before collecting and processing your Health and Criminal Data for the purpose of delivering our services. You have the right to withdraw consent to marketing or Health and Criminal Data at any time by contacting us.
4.2 Purposes for use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

4.3 Promotions from us
We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.  You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.  We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
4.4 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
4.5 Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see: http://www.go-ifa.co.uk/cookies.html.
4.6 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.   DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above:

• External Third Parties as set out in the Glossary
  

• Specific third parties listed in the table
  

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.   INTERNATIONAL TRANSFERS
6.1 EEA
Except as set out below in section 6.2, we do not envisage that the performance by us of our service will involve your personal data being transferred outside of the United Kingdom or the European Economic Area (EEA). If for any reason this changes we will notify you before it happens.
6.2 Overseas transfer
Where our services involve investment in financial products based outside the EEA or UK, it may be necessary to transfer your name, data of birth and policy number outside the EEA or UK.  Whenever it is necessary to undertake such a transfer of your personal data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.   DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We operate a clear desk policy at all our offices and any of our staff who operate on a remote basis will be required to ensure any data is secure at all time.

8.   DATA RETENTION
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.   YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
i.    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.
ii. 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.
iii.  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.
iv. 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 or using profiling techniques as part of our decision making process. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
v.   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:
     •    If you want us to establish the data's accuracy.
     •    Where our use of the data is unlawful but you do not want us to erase it.
     •    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.
     •    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
vi.  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.
vii. 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 for Health or Criminal Data, 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 wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.  GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
External Third Parties

• Service providers acting as processors who provide IT and system administration services, investment providers, mortgage lenders, finance lenders and insurance providers.
  

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  

• Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
  

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.