IM Asset Management Limited is a member of the Irwin Mitchell Group and is a specialist financial services business providing clients with financial advice, wealth management, investment management, portfolio management, financial protection planning, inheritance tax planning, pension and retirement planning and periodical payment checking services across the UK.
As an essential part of our business, we collect and manage client data. In doing so, we observe the UK data protection legislation, and are committed to protecting and respecting clients’ privacy and rights. Specifically, we act as a “Data Controller” in respect of the information gathered and processed by us. A Data Controller determines the purposes of which, and the manner in which, any personal data is processed.
In order that you are reliably informed about how we operate, we have developed this privacy notice, which describes the ways in which we collect, manage, process, store and share information about you. The privacy notice also provides you with information about how you can have control over the use of your data.
What Information Do We Collect About You?
In general terms, we seek to collect information about you so that we can:
- Provide you with financial planning and investment advice which may result in the recommendation of products and services,
- Provide you with advice on tax planning, trusts, wills and inheritance tax,
- Assist you with income and expenditure planning,
- Help you achieve your financial goals, and
- Ensure you are kept up-to-date with information and advice that might affect your financial affairs.
The information that we need for these purposes is known as your “personal data”. This includes your name, home address, email address, telephone and other contact numbers and financial information. We collect this in a number of different ways. For example, you may provide this data to us directly online or over the telephone, or when corresponding with us by letter.
We also process sensitive classes of information that includes:
- Physical or mental health details,
- Religion and other beliefs, and
- Racial or ethnic origin
We will seek your permission if we need to record any of your sensitive personal data on our systems.
We may record our telephone conversation with you therefore any information captured via this medium will automatically be stored, for regulatory, training and monitoring purposes.
Please also be advised that when you visit our website, cookies will be used to collect information about you such as your Internet Protocol (IP) address which connects your computer or mobile device to the Internet, and information about your visit such as the pages you viewed or searched for, pages response times, download errors etc. We do this so that we can measure our website’s performance and make improvements in the future. Cookies are also used to enhance our website’s functionality and personalisation, which includes sharing data with third party organisations. You can control this by adjusting your cookies settings as described in our Cookies Policy.
How Will We Use The Information?
We use the data collected from you for specific purposes.
Download this document to view these specific purposes.
Please note that the document also explains:
- The legal basis for processing your data, linked to each processing purpose and
- What type of third party organisations we may share your data with.
Under the terms of data protection legislation, you have the following rights:
Right To Be Informed
This privacy notice and our Cookies Policy, which can be found on our website, together fulfil our obligation to tell you about the ways in which we use your information.
Right To Access
You have the right to ask us for a copy of any personal data that we hold about you. This is known as a “Subject Access Request”. Except in exceptional circumstances (which we would discuss and agree with you in advance), you can obtain this information at no cost. We will send you a copy of the information within 30 days of your request.
To make a Subject Access Request, please write to our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT, or via email at firstname.lastname@example.org.
Right To Rectification
If any of the information that we hold about you is inaccurate, you can either:
- Contact us on 0370 1500 900, or
- contact our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT or via email at email@example.com.
Right To Be Forgotten
From 25 May 2018, you can ask that we erase all personal information that we hold about you. Where it is appropriate that we comply, your request will be fully actioned within 30 days. For further information, please contact us on 0370 1500 900 or alternatively, please contact our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT or via email at firstname.lastname@example.org.
Right To Object
You have the right to object to:
- The continued use of your data for any purpose listed in section 3 above for which consent is identified as the lawful basis for processing i.e. you have the right to withdraw your consent at any time, and
- The continued use of your data for any purpose listed in section 3 above for which the lawful basis of processing is that it has been deemed legitimate.
If you wish to exercise your right to object please contact our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT or via email at email@example.com.
Right To Restrict Processing
If you wish us to restrict the use of your data because:-
- You think it is inaccurate but this will take time to validate,
- You believe our data processing is unlawful but you do not want your data erased,
- You want us to retain your data in order to establish, exercise or defend a legal claim, or
- You wish to object to the processing of your data, but we have yet to determine whether this is appropriate.
Please contact our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT or via email at firstname.lastname@example.org.
Right To Data Portability
If you would like to move, copy or transfer the electronic personal data that we hold about you to another organisation, please contact our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT or via email at email@example.com.
Rights Related To Automated Decision-Making
If you would like to object to automated decision making without any individual involvement, and to the profiling of your data, please contact our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT or via email at dataprotection@irwinmitchell.
Is The Processing Of Information Likely To Cause Individuals To Object Or Complain?
IM Asset Management Limited is not aware of any legitimate reason for objecting or complaining about the way we process or control information.
How Long Will We Retain Information For?
IM Asset Management Limited will typically retain information for a period of seven years after the termination of our business relationship, other than:
- Where we have a legitimate interest to continue to hold it, such as because of regulatory reasons, or to ensure our business records are adequate to maintain the requisite levels of insurance to protect our clients, or
- It relates to pensions transfer business, Opt Outs or FSAVC advice, which we hold indefinitely, or
- The recordings of telephone calls, which are retained for a period of 7 years from when the call was made, or
- We are asked by a Court of Protection appointed Deputy to hold information for longer.
It may sometimes be necessary to transfer personal information overseas. When this is needed information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with all aspects of the data protection act. This includes information that is exchanged with any third party organisation as described above.
Data Privacy And Security
At IM Asset Management Limited, we maintain a comprehensive data management work programme, which includes processes for ensuring that data protection is a key consideration of all new and existing IT systems that hold personal data. Where any concerns, risks or issues are identified, we conduct relevant impact assessments in order to determine any actions that are necessary to ensure optimum privacy.
We also maintain an active information security work programme which seeks to protect the availability, confidentiality and integrity of all physical and information assets. Specifically, this helps us to:
- Protect against potential breaches of confidentiality,
- Ensure all IT facilities are protected against damage, loss or misuse,
- Increase awareness and understanding of the requirements of information security, and the responsibility of our colleagues to protect the confidentiality and integrity of the information that they handle, and
- Ensure the optimum security of our website.
Location Tracking Via Our Website
Geo-location tracking, which shows us where you are in the UK, is not used on our website.
You can contact our Group Data Protection Officer if you have any concerns or complaints about the ways in which your personal data has been handled as a result of you using our services.
If you are unable to resolve any complaint about the way we handle your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office who may be contacted at Wycliffe House, Water Lane, Wilmslow SK9 5AF or https://ico.org.uk.
Questions and comments regarding this Privacy Notice are welcomed, and should be sent to our Group Data Protection Officer at firstname.lastname@example.org, or alternatively, you can write to our Group Data Protection Officer at IM Asset Management Limited, Riverside East, 2 Millsands, Sheffield, S3 8DT.