This privacy information notice is about when and why PageRussell collects information about people who visit our website or seek our services, how we use it, when we might pass the information on to others and how we keep it secure.  If you are happy with what we’ve outlined below, no further action is necessary.

We collect your information in the following ways:

• From you over the telephone, in meetings, via our client portal or online questionnaires.
• We ask your permission to contact your financial plan providers or use a data aggregation service.
• We use a verification service to check your identity information and make sanctions checks.
• Our website uses cookies which collect anonymous information about visitors to our website.

To provide our service to you we may collect and use the following information about you:

• Contact information such as telephone numbers, post and email addresses.
• Financial information such as your assets and liabilities, income and expenditure.
• Employment details and, if self-employed or a business owner, information about your business.
• Your financial goals and lifestyle interests.
• Health information including whether you smoke and what medication you take.
• Any vulnerabilities you may have including loss of capacity to make decisions.
• Your financial products, such as pensions, investments and insurance plans.
• Your attitude to financial risk, capacity for loss and return required.
• Information about financial dependents or beneficiaries. If you provide information about other people we expect you to tell them and that they are happy for you to do so.  We recommend you share this privacy notice with them and ask them to contact us if they have any questions.
• Identity information such as passport or other identity document information. We may conduct electronic money laundering checks on you.  This will not leave a footprint which would impact your credit rating.
• Our website uses anonymised third-party cookies from Google Analytics which provide us with information about the location of visitors, what pages they look at and for how long.

The reasons we collect your information and who we might routinely share it with are:

Reason for using your information	Lawful basis	Other organisations we might share your information with
·       To provide you with our independent financial planning, investment and tax compliance services.	Performance of a contract	Product providers and fund managers; data base, call recording, email, research, risk profiling, cash-flow, tax compliance and accounting software providers; outsourced paraplanners.
·       To refer you to third party professional advisers to provide you with advice.	Consent	Solicitors, accountant, mortgage advisers.
·       To provide you with details of products and services from us and third parties that may be of interest to you electronically.	Consent	Data base and email software provider.
·       To keep records of any services or advice we provide you to defend potential legal claims or complaints.	Legitimate interest	Data storage supplier, professional indemnity insurance broker and insurer, compliance consultant.
·       To keep records of any services or advice we provide you to respond to a legitimate request by a regulator, court or tribunal.	Legal obligation	The Financial Conduct Authority or other regulator, court or tribunal.

We give other organisations only the information they need to complete their task.  We require our suppliers to keep your information secure and not use it for their own marketing to you.  We do not share, sell or rent your information to other organisations for their own marketing purposes.

Bombarding people with spam is a great way to upset them; so, we don’t.  However, the definition of electronic marketing is broad, so we ask for your permission first.  We may contact you to arrange a review (if we provide ongoing services), if we think you need to act (for example, after a tax change) or if we want to update you on economic, legal, regulatory or business changes that affect you.

Sensitive information (called special category data) includes information about your health or lifestyle.  To advise you on insurance or your retirement we need to collect and use this sensitive information.  We ask your permission to do this, but if you decline we may not be able to advise you.

If we need to share your information outside the EEA, we will comply with European data protection regulation.  You can ask us for more information about this.

Our employees may access our systems remotely when working abroad, which may be outside the EEA.  When they do so, they must follow our data protection procedures which comply with EEA data protection regulations.

We may hold your information for longer than you might expect because of a legitimate interest or legal obligation.  The periods for which we may keep your information depend on the type of service provided:

Service provided	How long we keep your information
·       Financial advice was given or a regulated product recommended.	Indefinitely
·       Tax advice or tax compliance services only were provided.	Seven years, unless we are notified by HMRC that a period is considered “open” in which case it will be until we are notified the period is “closed”.
·       An enquiry about our services, but no further information was gathered.	One year from last contact.
·       An enquiry about our services where further information was gathered but no advice was provided.	Three years from last contact.

We make our best efforts to ensure the security of your information on our systems.

Where you have a password for accessing our client portal, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.

Where we provide an ongoing service, we will update your information as appropriate during a regular review.  If between reviews you change your contact details please let us know. Where we provide a one-off service the information we keep about you will reflect your situation at that time and we will not normally update this.

To ensure we are dealing with the right person, we may ask you for proof of identity if you ask to exercise any of these rights.

We will not ask for a fee unless we think your request is unfounded, repetitive or excessive.  Where a fee is necessary, we will tell you before answering your request.

We aim to reply to valid requests within one month.  It may take us longer if the request is complicated or you have made several requests.  We will let you know if we think it will take us longer than one month.  To help us we may ask you for more detail about your request.

We may not be able to address your request in full.  For example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request differently.

• Access: You can ask for a copy of your information that we hold.
• Correct: You can ask that we correct (or rectify) any information about you that is incorrect. We will be happy to do so, but will need to check the accuracy of the information first.
• Erase: You can ask that we erase (or delete) your information if you think we no longer need it for the purpose we collected it. We may not be able to comply with your request. For example, where we need to keep your information to comply with our legal obligations or establish, exercise or defend legal claims.
• Restrict: You can ask us to stop processing your information. This means that we will keep it but no longer actively use it (in other words we will archive it).  We may not be able to comply with your request.  For example, where we need to use your information to comply with our legal obligations or establish, exercise or defend legal claims.
• Object: You can object to our use of your information if you think your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If we can demonstrate we have compelling legitimate interests to use the information we may continue to do so.
• Transfer: You can ask us to transfer your information to you or another organisation in an appropriate electronic format.
• Object to automated decisions: If we make a decision about you based solely by automated means (that is, with no human input), and our decision produces a legal effect concerning you or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision-making processes to protect your rights and freedoms.
• More information: You can contact us to ask us for more information about your information that we hold, what we use your information for, who we give your information to, whether we transfer it abroad, how we protect it, how long we keep it, what rights you have, how you can make a complaint, where we get your information from and whether we have carried out any automated decisions using your information.