Privacy Policy

Hartsfield Financial Services Ltd (“HFS”, “us”, “we”, “our”) is part of the Hartsfield group of companies, which includes Hartsfield Trustee Services Ltd (HTS), White Horse Trustees Ltd (HTS) and Hartsfield Capital Management (HCM) which is a trading style of Hartsfield Financial Services Ltd.

Your right to privacy is important to us. HFS is the data controller responsible for the safe keeping of your personal information and we are committed to protecting your privacy.

This Privacy Policy describes the ways in which we collect your information, how we may use it; record and maintain it and with whom we share and obtain your details from. Your individual rights under the General Data Protection Regulations (2018) are also confirmed.

Why do we collect information on you?

To enable us to provide you with the most suitable financial advice and make a personalised recommendation, we require detailed information about you; your circumstances needs and objectives.

We will not be able to provide you with appropriate financial advice if you do not supply us with the necessary information, or if you do not give us your permission to process your information.

What information do we collect about you?

We collect information about you by completing a detailed ‘fact-finding’ document, which we will do at the beginning of our relationship before we provide you with advice. You will be asked to sign a Client Agreement to formally appoint HFS at this point.

Throughout our relationship we will maintain and update our records to ensure that we continue to provide you with our best advice. If your circumstances or objectives change, even if that is between agreed reviews, you should notify us as this may entail a change in our advice.

We may, from time to time, contact you with a view to obtaining your feedback and views on our services. Website usage information is also collected using cookies.

How will we use the information about you?

Our primary reason for collecting your data is to provide you with personalised recommendations; however, with your consent, we will pass your information to 3rd party organisations whose products and/or services complement those of our own. Examples of this would be insurance companies, investment providers, accountants and solicitors whom we have recommended to you as they fulfil a particular need we have identified and recommended to you.

HFS will not share your personal information for marketing purposes with any 3rd party organisation, unless there is specific consent from you to do so.

In processing your data, we may send your details to, and use information from credit reference agencies and fraud prevention agencies.

Confirming your identity

We are required by law to verify the identity of every individual who becomes a client (corporate or retail) of HFS. Where possible, we will try and do this electronically by using the services of specialist external agencies. If we are unable to validate your identity in this way, you will need to provide certain documents to confirm your identity.

If you are an existing customer, we may on occasions need you to re-confirm your identity, for example, if your circumstances have changed or where new advice services are requested.

Processing your personal information

In most, if not all circumstances, HFS will process your personal information under a lawful basis or bases (rather than simply rely on your specific consent) as described by the Information Commissioners Office (ICO) – typically, this will fall under the following lawful bases (although not limited to):

Lawfulness of processing conditions

6(1)(a) – Consent of the data subject

6(1)(b) – Processing is necessary for the performance of a contract with the data subject or to take steps to enter into a contract

6(1)(f) – Necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject

Access to your personal information and rectification

You have the right to request a copy of the information that we hold about you. If you would like a copy of some, or all of your personal information, please email our Compliance and Data Protection Officer – mark.futcher@hartsfield.co.uk , or write to Hartsfield Financial Services, Hartham Park, Corsham, Wiltshire SN13 0RP.

We will not make a charge for such a request and have a month within which we must respond to you. We do reserve the right to refuse or impose a reasonable fee for requests that are deemed excessive or repetitive.

If we refuse a request we will confirm the reasons why, given that you have the right to complain to the supervisory authority and to a judicial remedy. Any refusal will be given within one month of the original request being made.

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.

Personal information retention periods

Personal information that we record, hold and maintain will only be used for the purposes it was originally collected. Personal information will not be retained for longer periods than are necessary and data will be securely destroyed when data is no longer required.

HFS is proud to operate under the auspices of the UK Financial Services Regulator – the Financial Conduct Authority (FCA). As such, we are obliged to retain records for at least 6 years when we have provided a personal recommendation for a product and/or service to any retail client. Where we engage and provide a personal recommendation relating to pension transfer business, we are also obliged to keep records and information indefinitely. The rules and obligations set by the FCA will always take precedent over any other set of rules or regulations set by alternative regulatory bodies, industry-related or otherwise.

Your right to erasure

You may ask us to remove/delete/erase personal information that we hold about you and to prevent processing in specific circumstances, such as:

• When consent is withdrawn
• Where personal data is no longer necessary in relation to the purpose for which it was originally collected/processed
• You believe personal information was unlawfully processed
• Personal data has to be erased in order to comply with a legal obligation

There may be instances where HFS cannot erase your personal information – an example of this would be where FCA rules and regulatory obligations do not allow us to do so and in line with our retention policy. Where this situation occurs, we will explain the reasons why we may not be able to carry out such a request.

Portability of personal information

In certain circumstances, you may request that we move, copy or transfer personal information in order that you may reuse the data across different services and organisations.

Your right to ‘data portability’ applies:

• to personal data you have provided us
• where the processing is based on your specific consent or for the performance of a contract; and
• when processing is carried out by automated means

HFS will ensure (where feasibly possible) to provide data in a structured, commonly used and machine-readable format. HFS do not impose a charge for this service.

We are not required to adopt or maintain processing systems that are technically compatible with other organisations.

Fraud Prevention and Detection

We are required by Money Laundering Regulations to collect and record personal data to confirm a customer’s identity.

To protect us against any fraudulent or other criminal activity we may check your details against, and share information with, fraud prevention agencies who maintain and share information on known and suspected fraudulent activity, such as Action Fraud.

We are required by law to report any suspicious transactions to the National Crime Agency, the police and other law enforcement agencies for crime detection and prevention purposes.

Call monitoring and recording

Your telephone conversations with us may be recorded for security and fraud prevention purposes, and to meet regulatory requirements. Recordings are kept secure to prevent unauthorised access and the calls may be monitored for staff training and customer service purposes.

Website data collection (cookies)

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further information visit – www.aboutcookies.org or www.allaboutcookies.org

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in certain cases, some of our website features may not work as a result.

Use of Email

If you send an email to us, please be aware that email is not a secure method of communication and we strongly recommend that you do not send confidential information this way.

Any email sent to us, including any attachments, may be monitored and used by us for reasons of security and for monitoring compliance with our internal policies. Email monitoring or blocking software may also be used.

Please be aware that you have a responsibility to ensure that any email you send to us is within the bounds of the law.

Other websites

Our website contains links to other websites. This privacy policy only applies to our website, so when you link to other websites you should read the privacy policies that relate to them and other organisations.

Changes to our privacy policy

We keep our privacy policy under regular review and we will make changes to this document as and when required. This privacy policy was last updated on 1st February 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you:

• By email (mark.futcher@hartsfield.co.uk)
• Or write to: The Data Protection Officer, Hartsfield Financial Services, Hartham Park, Corsham, Wiltshire SN13 0RP

Marketing

We may like to send you information about products and services of ours and other companies within our group which may be of interest to you. If you have consented to receive marketing – contained within our Client Initial Disclosure Document (CIDD) – you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members within our group.

If you no longer wish to be contacted for marketing purposes, please contact the Data Protection Officer on 0800 612 6633 or write to: DPO, Hartsfield Financial Services, Hartham Park, Corsham, Wiltshire SN13 0RP.

Complaints

In the event that you become unhappy with the way in which we handle your personal information/data, you have the right to complain to the Information Commissioners Office (ICO) via:

www.ico.org.uk/concerns/handling or Tel: 0303 123 111