If you wish to register a complaint, please contact us by any of the following methods:
In writing to Complaints, Wren Sterling, 13-19 Derby Road, Nottingham NG1 5AA.
Telephone: 03701 432100.
Email: complaints@wrensterling.com
If we cannot agree settlement of your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this web page.
Wren Sterling Financial Planning Limited collect, uses, and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulations, and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “Wren Sterling”, “we”, “us” or “our” we are referring to Wren Sterling Financial Planning Limited.
While providing our service to you, we may collect the following personal data when you provide it to us.
We also obtain personal data from other sources while providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
The personal data we obtain from other sources may include the following:
The below table sets out.
|
Rationale/Reason for Processing |
Lawful Basis for Processing |
Third party recipients linked to that activity |
| To provide you with intermediary services | Performance of a contract | Bankhall Support Services |
| To assess your risk profile as part of our advice process | Consent and Performance of a contract | FinaMetrica |
| To verify your identity | Compliance with a legal obligation | Equifax
GB Group |
| To apply for products on your behalf | Performance of a contract | Product providers |
| To refer you to third party advisers to provide you with advice in relation to; | ||
|
Consent | Accord Legal Services |
|
Consent | |
|
Consent | Accord Legal Services |
|
Consent | Key Equity Release |
| To retain records of any services or advice provided to you by us to defend potential legal claims or complaints | Legitimate interests | Intelliflo |
| To provide you with details of products and services from us and third parties that may be of interest to you in accordance with your preferences. For more information see ‘Marketing’ below | Consent | |
| To allow us to audit our provision and company processes to meet our legal, regulatory, and statutory responsibilities | Compliance with a legal obligation | Auditors |
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data, and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process:
Some providers may ask for this information during your application for their products or services. We will never ask for this information for our own purposes.
In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance contract or (ii) for the establishment, exercise, or defence of legal claims.
During our activities relating to the prevention, detection, and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information set out in the above table, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty. We shall not be obliged to give you any further notice of this.
We may use personal data we hold about you to help us identify, tailor, and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then will do so in accordance with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.
You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us:
By phone: 0370 1432 100
By email: marketing@wrensterling.com
By post: The Marketing Team, Wren Sterling 13-19 Derby Road, Nottingham NG1 5AA.
In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of every email.
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data for us to provide you with intermediary services.
When we provide you with intermediary services, we will keep your personal data indefinitely.
We may transfer your personal data to the following which are located outside the European Economic Area (EEA) as follows:
Australia to assess your risk profile as part of our advice process.
Such countries do not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission has not given a formal decision that Australia provides an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a contractual transfer contract that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data. To obtain a copy of such safeguards please refer to Morningstar’s Privacy Policy, available at https://www.morningstar.com/company/privacy-policy/emea.
You have a right to ask us for more information about the safeguards we have put in place as mentioned above. To learn more, please see ‘Your rights’ below.
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings.
To find out more about how we use personal data:
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.
You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information) or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
You can ask that we restrict our use of your personal data in certain circumstances, for example:
We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
You can object to any use of your personal data which we have justified on the basis of our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g., another company).
You may only exercise this right where we use your personal data to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
If we made a decision about you based solely by automated means (i.e., with no human intervention), and the decision made by us 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.
You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the European Economic Area. We are not required to share details of these safeguards where sharing such details would affect our commercial position or create a security risk.
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.
If you would like to exercise any of the above rights, please.
We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before contacting the ICO.
Please contact our Data Protection Officer if you have any questions about this privacy notice or the information, we hold about you.
If you wish to contact our Data Protection Officer, please send an email to
dataprotection@wrensterling.com or write to Wren Sterling, 13-19 Derby Road, Nottingham, NG1 5AA.
| we, us or our | Wren Sterling Financial Planning Limited
a company registered in England and Wales (company number 09157918) and having its registered office at 13-19 Derby Road, Nottingham, NG1 5AA |
| contact information | these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode, or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address |
| data controller | means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used during us providing you with intermediary services |
| data protection regulation | applicable data privacy and protection laws |
| employment status | this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance |
| FCA | the Financial Conduct Authority, being the independent watchdog that regulates financial services |
| financial information | this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60 |
| health information | this is information relating to your medical history, including symptoms, diagnoses, procedures, and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history |
| identity information | this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers’ licence, and national insurance number |
| intermediary services | these are the services we provide to you in relation to the products. |
| lenders | a mortgage lender (for a list of current lenders which we work with, please contact us – see How to contact us above) |
| lifestyle information | this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits |
| product | this is an investment, pension, and/or protection product in respect of which we provide intermediary services to you |
| product provider | a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above) |
| sanction check information | this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering |
| vulnerability | a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall into the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence) |