Scope

All data subjects whose data is processed by Compass IFS Ltd.

Responsibilities

Compass IFS Ltd’s data processers are responsible for ensuring that this notice is placed in front of potential data subjects prior to Compass IFS Ltd collecting/processing their personal data.

All Employees of Compass IFS Ltd who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

Fair Processing Notice

Data protection law says that we are allowed to use personal information only if we have proper reason to do so. This includes sharing it outside of Compass IFS Ltd

These are the ways we may use your personal information and which of the reasons we rely on to do so:

What is Personal Data?

Under the EU’s General Data Protection Regulation, Personal Data is defined as

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

Special Categories of Personal Data

Certain data is classified under the Regulation as” special categories”:

• Racial
• Ethnic origin
• Political Opinions
• Religious Beliefs
• Trade-union membership
• Genetic Data
• Biometric Data
• Health Data
• Data concerning a natural person’s sex life
• Sexual orientation
• Other

Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

Why does Compass IFS Ltd need to collect and store personal data?

In order for us to provide you with services, we need to collect personal data for correspondence purposes and/or detailed service provision

In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy. We may pass your personal data on to Third Party service providers who are contracted to Compass IFS Ltd in the course of dealing with you.

Our contractors are obliged to keep your details securely and use them only to fulfil the service requested. Once your service need has been satisfied or the case has been closed, they will dispose of the details in line with our firm’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do so. We will look to communicate by encrypted messaging however at times we may be required to send information in the post which is not as secure

How Compass IFS Ltd uses your information

Compass IFS Ltd will process – that means collect, store and use – the information you provide in a manner that is compatible with the EU’s General Data Protection Regulation (GDPR).

We will endeavor to keep your information accurate and up to date and not keep it for longer than is necessary. We will keep your data for as long as you are customers of Compass IFS Ltd.

After you stop being a customer of Compass IFS Ltd we reserve the right to keep your data for longer for one of the following reasons

• To respond to any questions or complaints
• To show that we have treated your fairly
• For Legal reasons
• Regulatory Reason
• Technical Reasons

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Information about connected individuals

We may need to gather personal information about your close family members and dependents in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.

How do we collect personal information?

Data you give to us:

• When you talk to us on the phone, at our office or at external meetings
• When we provide financial advice
• When you apply for products and services
• When you use our website
• In emails, letters and mobile devices
• In financial reviews
• If you take part in competitions
• Information if you visit our office e.g. visual images collected by CCTV

Data from third parties

• Companies that introduce you to us
• Social networks
• Fraud prevention agencies
• Medical practitioners
• Government and law enforcement agencies

Who we share your personal information with

• HM Revenue & Customs, regulators and other authorities
• Fraud prevention agencies
• Any party linked to you or your business
• Organisations that introduce you to us
• Companies that we introduce to you
• Price comparison websites and similar companies that offer ways to research and apply for financial products and services
• Companies you ask us to share your data with.
• Product providers
• Fund houses

Where is your information processed?

The majority of your information is processed in the UK and European Economic Area (EEA)

However, some of your information may be processed by us or third parties we work with outside of the EEA, including countries such as the United States.

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we put checks in place that they meet these obligations.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot advise on your accounts which could mean that we cancel our service you have with us.

Any data collection that is optional would be made clear at the point of collection.

Marketing

We may use your personal information to tell you about news about Compass IFS Ltd or contact you about events.

You can ask us to stop sending you marketing messages by contacting us at anytime

How to get a copy of your personal information?

You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information, please write to us at the below address:

FAO Data Controller
Compass IFS Ltd
1 Doctors Road
Blofield
Norwich
Norfolk
NR13 4LF

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the right to object and right to erasure or the right to be forgotten.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

How to complain

Please let us know if you are unhappy with how we have used your personal information by contacting us.

You have the right to complain to the Information Commissioner’s Office.

Cookies

To find out more about how we use cookies please see our Cookies Notice

Legal Services

Legal services are provided by Compass IFS Legal Ltd, which is a wholly owned subsidiary of Compass Independent Financial Services Ltd.