Basis for Holding Personal Information

This notice explains the terms under which personal data is obtained and stored by Dentons Wealth under the General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018. ‘Personal data’ is defined as any information that relates to an identified (or identifiable) person.

Dentons Wealth collects sufficient personal information from its clients in order to provide suitable advice recommendations.  It is also used to comply with anti-money laundering regulations and legislation, such as the FCA’s ‘Know Your Client’ guidelines. This information includes basic facts such as clients’ name, address, dependants and contact details as well as more subjective information such as their attitude to risk. It may also include health information that is categorised as sensitive personal data, for which we will require clients to provide their explicit consent to process this information. 

The primary lawful basis of the data processing is that the data subject is giving their consent that collection of the data is necessary for the performance of a contract with Dentons Wealth in respect of the products and services provided in accordance with our terms of business.  Other bases include where the processing is necessary in relation to the fulfilment of any contract, or where the processing is necessary to pursue our legitimate interest in the operation of Dentons’ business.

Where relevant, clients have the right to withdraw their general and explicit consent at any time, however, without their consent, we will not be able to process the data they have provided. 

Information to and from other sources

We may share client information, including by electronic transfer e.g. email, with other product providers we use.  This may include insurers, intermediaries, product providers and other third party service providers which are used in the delivery of our ongoing service.  This includes IT systems or the operators of services which verify information for the purposes of anti-money laundering and the prevention of fraud.

We also have a legal obligation to provide information to government departments and our regulatory bodies on request, the Financial Conduct Authority (FCA), The Pensions Regulator (TPR), His Majesty’s Revenue & Customs (HMRC), appropriate Ombudsmen and the Information Commissioner’s Office (ICO). We may also use third party companies to administer and communicate information in respect of our legal and regulatory obligations.

Dentons Wealth is a controller and processor of the personal data provided to us. Our registered office is Sutton House, Weyside Business Park, Catteshall Lane, Godalming, Surrey, GU7 1XE.

How we hold client personal data

All the personal data we use is controlled by Dentons Wealth in the United Kingdom. No third parties have access to client personal data unless the law allows them to do so. We have a data protection regime in place to oversee the effective and secure processing of personal data.

All information at Dentons is stored on secure servers. All our data transfers to and from authorised third party recipients have built in security features, including encryption, to best protect personal data. Email communications cannot be secured in such a robust manner, although we do endeavour to supply confidential information in password protected files wherever possible.

Client basic personal data will be kept for a maximum of 6 years, or for as long as is required by the FCA (our regulator), following the end of their business relationship with Dentons Wealth, after which time it will be destroyed.

Data Subject Rights

Data subjects have rights relating to how their data is held.  This includes being able to request that Dentons:

•    Provides copies of personal information held
•    Corrects incorrect  or incomplete personal information
•    Restricts its processing of their personal data
•    Stops processing personal data
•    Does not use fully automated processing for decision making

Clients may also request that their data be transferred to another data controller in a machine-readable format.

Dentons Wealth will respond to all requests relating to data subjects’ individual rights, however there may be reasons that requests are not able to be carried out, such as if this would prevent the fulfilment of legal or regulatory obligations.

If a data subject wishes to raise a complaint on the handling of their personal data, they can contact the Managing Director of Dentons Wealth, Sue Stevens, at the above address, who will investigate the matter. 

If they are not satisfied with our response or believe we are not processing their data in accordance with the law they can complain to the Information Commissioners Office (https://ico.org.uk/).