J C Roxburgh (Financial Services) Ltd
J C Roxburgh (Financial Services) Ltd takes your data privacy seriously. In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for complying with Data Protection Laws and the General Data Protection Regulations (GDPR) which apply in your country of residence.
We are an Independent advisor providing advice on a range of finance and investment to Individuals and Businesses. We collect and process information about you in order to provide you with the right advice and arrange the right products and services to suit your individual needs. Your information is also used for business purposes such as fraud prevention and detection and financial management. This may involve sharing your information with third parties such as product providers, credit reference agencies, service providers, professional advisors, our regulators, police and government agencies or fraud prevention agencies.
In this Privacy Notice, we want to inform you what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.
If you are providing personal data of another individual to us, you must tell them you are providing their information to us and show them a copy of this notice.
Our Contact Details
If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact us at:
J C Roxburgh (Financial Services) Ltd
151 Glasgow Road
Tel: 0141 952 0371
Why we do we collect your information?
Where we collect and process personal data, we identify both the purpose and legal basis for doing so. The legal bases which are:
Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose
Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject
Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person
Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
Legitimate Interests - Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal date, in particular where the data subject is a child.
Our Processing of Your Personal Information
For all of our services we collect the following types of information:
- General contact details such as, Name, Address, email address, Telephone number
- Business Activities or occupation of the person whose information we are processing
- Details of Services provided to you
- Identification details and Information required to understand your needs in respect of financial advice such as, Date of Birth, Marital Status, Nationality, National Insurance Number, Residency details
- Financial Details – such as details of assets, investment or shareholding, credit history, retirement information, mortgage details, expenditure, salary and payment details.
- Existing insurance and protection arrangements that we are being asked to review
- Power of Attorney Status where applicable
- Correspondence and communications between us and a data subject
- Your marketing preferences
Please Remember: Where you provide any of this information relating to or on behalf of another individual such as a dependant or other family member, you must remember to ensure that you have the consent of the individual and provide them with a copy of or access to this Privacy Notice.
Special Categories of Personal Data that we collect:
- Details relating to medical history or health where it is relevant to the policy being arranged
- Information relating to criminal sanctions (including offences and alleged offences and any caution, court sentence or criminal conviction), which can be established directly from you or as a result of carrying out sanctions checks.
How we collect your information
In most cases, we collect your data directly from you. We collect data and process it when you
- Complete an online ‘contact us’ form
- Speak to us on the telephone to discuss or use our services
- Email or write to us to enquire about or use our services
We also receive your data indirectly from the following sources:
- From third parties acting on your behalf with Power of Attorney Status or your Consent
- Social Media Sites such as LinkedIn or Facebook
- Public sources – demographic data, Market Research, Local Directories
Our purpose and legal basis for the information we collect, and process allows us to:
|Purpose||Lawful Basis||Lawful Basis for Any Special Category of Information|
|To understand your financial advice requirements, needs and risk appetite prior to arranging quotes for you and entering into a contract of service with you||The processing is necessary for the performance of an anticipated Contract||It is necessary for an Insurance Purpose|
|To add you as a prospective client including carrying out credit, fraud, sanctions and anti-money laundering checks||The processing is necessary to enter into a Contract.||The prevention of fraud is in the substantial public interest.|
|To comply with our legal or regulatory obligations (such as our requirements to report to the FCA)||We have a legal or regulatory obligation||It is necessary to establish and exercise our legal rights.|
|To communicate with you, respond to your queries and notify you about changes to our service||It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you||N/A|
|For Marketing of Similar Services to Existing Customers or Previous enquirers||It is in our Legitimate Interests to market similar services to individuals who have enquired about of purchases services from us previously. We will always provide an option to opt out of such marketing.||N/A|
|For electronic Marketing of services to new individual customers||We rely on Consent for direct electronic marketing to individuals||N/A|
|For Direct Marketing to Businesses||It is in our Legitimate Interests to market our services to other businesses which can include personal business email addresses||N/A|
|Managing our Business operations such as maintaining accounting records, analysing financial results, complying with internal audit requirements and receiving professional advice (e.g. tax or legal advice)||It is in our Legitimate Interests to manage and improve our business operations and activities.||N/A|
Where we rely on your consent you have the right to withdraw this consent at any time by contacting our Data Protection Officer. Contact details can be found at the beginning of this policy.
Legitimate Interests - Where the processing of personal data is based on our Legitimate Interests, it is to improve on our service, security and prevent fraud or illegal activity in favour of the wellbeing of our customers and shareholders.
We may send you details of similar services to those you have enquired about or purchased from us previously. You can opt out of receiving this information from us at any time by contacting us at the above address or clicking ‘unsubscribe’ on any messages you may receive.
We will never share or sell your information to any other party for marketing purposes.
Who we share your information with?
From time to time we may share your personal information with third parties for the various purposes set out above. These are:
- Insurers with whom we are obtaining quotations or placing cover
- Industry bodies
- Accountants, Regulators or Auditors
- Payment Services Providers
- Service Providers such as Software Providers (I.T. Suppliers, Product Software providers, Cloud Services)
- Fraud detection Agencies
- Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
- Debt Collection Agencies
- Credit Reference Agencies
- Selected Third Parties in connection with the sale, transfer or disposal of our business
International data transfers
Sometimes we (or third parties acting on our behalf) will transfer personal information that we collect about you to countries outside of the European Economic Area (EEA). As a safeguard to protect your information, we ensure that the relevant safeguards are in place including checking that adequacy decisions have been made or where necessary we rely on Standard Contractual Clauses (Controller to Processor)).
Automated decision-making or Profiling
We do not use automated means to make decisions about the products we source, however providers can do so when providing us with a quotation. They consider the information provided (for example, details of your level of cover required, financial status etc) to determine whether your application can be accepted and the appropriate rates. All of such decisions are however reviewed by us and you can request that the decision be made by an individual decision maker.
How Long do we keep personal data for?
The following details the criteria used to establish the retention period set out within our policy.
Where it is still necessary for the provision of our Services
This includes the duration of any contract for services we have with you and for a period of 12 months after the end of any contract with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule only where we are not required to retain the data for longer.
Where required by Statutory, contractual or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation, for example depending on the type of product we arranged for you. It may also be necessary to store personal data with regard to pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be also subject to statutory storage obligations depending on national law.
Your Rights as a data subject
As a data subject, you have rights in relation to your personal data. These are:
The Right to Access – You have the right to request details of personal information held or processed and to copies of this data. We do not usually charge for this service.
The Right to Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.
The Right to Erasure – You have the right to request that we erase your personal information under certain conditions
The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances
The Right to Object to Processing – You have the right to object to our processing of your data, under certain conditions.
The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organisation or directly to you, under certain conditions.
As previously detailed, you also have the Right to Withdraw Consent where you have previously provided this at any time.
To exercise any of these rights or wish to make a complaint to us in respect of those rights, please contact us using the details at the beginning of this notice.
You also have the right to complain to the Supervisory Authority. Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:
Information Commissioners Office
Helpline: 0303 123 1113
Contractual Obligations and Consequences
In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, legal obligations) or can also result from contractual provisions such as payment details. This means that it may sometimes be necessary to conclude or fulfil a contract, that the personal data be provided. In those circumstances where the data is not provided or where certain rights are exercised, (Erasure, Object) there is a possible consequence that the contract could not be fulfilled or concluded and may be cancelled.
Cookies & similar technologies
Please remember: When you click on any external links on our site including the member log in, or where you find us on social media, you are redirected to those websites. We have no control over the privacy of those domains, so please check and review the privacy information on those sites.
How we keep your Personal Data Secure
We protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.
We store your data in in files within Insurance Software, Cloud Service Providers and use firewalls, antivirus, malware protection and encryption. We have a full data protection policy which includes a records management and information security policies. These include access controls, password security requirements, remote working and clear desk restrictions.
Changes to our Privacy Notice
All businesses and their operations change from time to time. J C Roxburgh (Financial Services) Ltd consider and embed data privacy prior to making any such changes. We keep our Privacy Notice under regular review to ensure that any changes are captured, and you are kept informed.
This Privacy Notice was last updated on 14th January 2021.