Last Updated: 27 June 2018
means Drewberry Wealth Management Limited, a private limited company.
means the General Data Protection Regulation.
means elected Data Controller(s) within Drewberry Wealth Management Limited.
Register of Systems
means a register of all systems or contexts in which personal data is processed by the Firm.
1. Data Protection Principles
The Firm is committed to processing data in accordance with its responsibilities under the GDPR.
Article 5 of the GDPR requires that personal data shall be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. General Provisions
- This policy applies to all personal data processed by the Firm.
- The Responsible Person shall take responsibility for the Firm’s ongoing compliance with this policy.
- This policy shall be reviewed at least annually.
- The Firm is registered with the Information Commissioner’s Office as an organisation that processes personal data. Registration Number: ZA089462 .
3. Lawful, Fair and Transparent Processing
- To ensure its processing of data is lawful, fair and transparent, the Firm shall maintain a Register of Systems.
- The Register of Systems shall be reviewed at least annually.
- Individuals have the right to access their personal data and any such requests made to the Firm shall be dealt with in a timely manner.
4. Lawful Purposes
- All data processed by the Firm must be done on one of the following lawful bases: consent, contract, legal obligation, vital interests, public task or legitimate interests (see ICO guidance for more information).
- The Firm shall note the appropriate lawful basis in the Register of Systems.
- Where consent is relied upon as a lawful basis for processing data, evidence of opt-in consent shall be kept with the personal data.
- Where communications are sent to individuals based on their consent, the option for the individual to revoke their consent should be clearly available and systems should be in place to ensure such revocation is reflected accurately in the Firm’s systems.
5. Data Minimisation
- The Firm shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.
- The Firm shall ensure that personal data is not further processed in a way that is incompatible with the original purpose.
- The Firm shall take reasonable steps to ensure personal data is accurate.
- Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.
- The Firm shall take reasonable steps to ensure that personal data is brought up to date and accurate where appropriate when re-engaging with existing clients.
7. Archiving / Removal
- To ensure that personal data is kept for no longer than necessary, the Firm shall put in place an archiving policy for each area in which personal data is processed and review this process annually.
- The archiving policy shall consider what data should/must be retained, for how long, and why.
- The Firm shall ensure that personal data is stored securely using modern software that is kept-up-to-date.
- Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.
- When personal data is deleted this should be done safely such that the data is irrecoverable.
- Appropriate back-up and disaster recovery solutions shall be in place.
- Drewberry uses SSL encryption on its Site
- In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Firm shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).
Data we collect
If you request a quote from the Drewberry website, you are providing personal data to Drewberry. The purpose of our site is to provide a wide range of quotations from different Partner organisations. In order to do this, we will pass the data you provide to Drewberry to our partners.
In addition, we enable you to return to the Site at any time to retrieve past quotes from partners. This requires Drewberry to store your data and any details of the quotes you’ve received on our servers.
We have kept to a minimum the amount of required information you need to pass us to access the services on our site, but if you do not wish to provide us with certain information we may find it impossible to provide all aspects of our service to you.
We may collect the following information:
- Personal details about you and your family (e.g. names, dates of birth and National Insurance numbers)
- Details about your estate, your finances and financial commitments (e.g. cash and investment holdings, property values and everyday outgoings)
- Details about your current and future incomes, expenditure and taxes
- Details regarding your investment preferences and financial objectives (e.g. your attitude to risk and financial goals)
By providing data to Drewberry, you are consenting to Drewberry converting such information into digital format such that it can be read, utilised and displayed by Drewberry’s computers or any other technology currently in existence or hereafter developed capable of utilising digital information.
Third parties we may need to share your data with
In order to provide you with our service, we need to pass data to third parties, which wish to provide you with quotes or products or services related to the request you have submitted to the Site.
We ensure that we only work with trustworthy third parties with robust data protection policies of their own. However, we cannot guarantee the way in which our third party partners will use your information. Your data will be managed in-keeping with our third parties’ own Privacy Policies, which may be different from ours but will still be in accordance with the General Data Protection Regulations.
Third parties we may need to share your data with…
- Assure Web
- Canada Life
- Hodge Lifetime
- Just Retirement
- Key Retirement
- Legal & General
- Liverpool Victoria
- Old Mutual Weatlh
- Retirement Advantage
- Scottish Widows
We may also pass data to a variety of other providers not listed above, but outlined in our Register of Systems.
We are committed to ensuring that your privacy is protected. We will only use the information that we collect about you lawfully in accordance with the EU’s General Data Protection Regulations (GDPR). We may change this policy from time to time by updating this page.
At all times this information is protected in a manner fully in-keeping with the EU’s General Data Protection Regulations. We will not share your information with any third parties without first obtaining your consent.
You have the right at any time to request from Drewberry:
- What personal data are being processed
- The purposes for which the personal data are being processed
- Who, if anyone, the personal data are disclosed to
- The extent to which Drewberry is using the personal data for the purpose of making automated decisions relating to you, the user and, if so, what logic is being used for that purpose
Drewberry has 30 days to respond to such requests.
You also have the right to request the deletion of all data we hold on you. This is not an absolute right and applies only in certain circumstances, as outlined by your rights under the GDPR legislation.
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