CLS Money is committed to protecting and respecting your privacy.
This policy sets out the basis in which any personal data we collect from you or you provide to us, will be processed by us. Please read the following carefully to understand what information we will take, why we need it, and how we will process your details.
INFORMATION WE MAY COLLECT FROM YOU
In order to fully understand your financial needs and give good advice, we need to obtain information about you, your family, your personal circumstances and your preferences.
Some of the information will be private and may be sensitive, such as details of your income and expenditure, health, debts and credit commitments, legal proceedings and adverse credit. Much of the information you provide will, as part of your application, be passed to the company whose products you apply for.
PROVIDING PERSONAL DATA
In order for us to be able to give you suitable advice, we need you to provide all the information we ask for as openly and honestly as possible. If you prefer not to disclose some information, please tell us that you prefer not to disclose it, and we will assess whether this will alter or impede the work we are doing for you.
HOW YOUR DATA IS USED
There are a number of reasons we need to process your personal data:
1. The primary reason is to allow us to do the job you've asked us to do. Specifically, we will use your data to;
Assess and provide advice to meet your needs and circumstances;
Introduce you to a range of product and service providers in order to meet your requirements;
Administer cases and assist processing of applications;
Tell you about any changes to products and service we have arranged for you;
Inform you about products and services we think may be suitable for you (unless you ask us not to send you this information).
2. We may also process your information in order to meet our legal and regulatory requirements. These may include:
Complying with the regulations set out by the Financial Conduct Authority and other regulators as required;
Preventing financial crimes such as money laundering and fraud by passing your details to other relevant bodies such as the police and National Crime Agency where required.
3. We may also process your personal data for our own legitimate interests. Typically, these would be limited to:
Analysing our business for trends and research how we can improve our services to customers;
Reviewing the work we have carried out for you to ensure we have met the regulations and quality standards;
Ensuring we are able to exercise or defend legal challenges in future.
Once we have received your information, we will use strict physical, electronic and managerial procedures and security features to prevent unauthorised access.
All the information you provide to us is stored securely on our database and on our computer document files.
We use password protection and encryption to prevent unpermitted access to all personal data files.
We may also store manual copies of your personal information in a secure facility where access is restricted.
We will only keep your personal information as long as necessary. How long that is depends on the type of data and what work we have carried out. In most cases, your personal data will be stored for an indefinite period, as we need to keep evidence that we have fulfilled our legal and regulatory requirements.
OBTAINING A COPY OF YOUR DATA
If you would like a copy of your personal data, please write to our Data Controller (details below) and we will provide a copy of any personal data we hold within one calendar month of receiving your request. Please note that we may need to verify your identity before providing the information.
INCORRECT OR INCOMPLETE DATA
You have the right to have your data corrected or completed by contacting our Data Controller in writing (details below). Please be aware that we need to maintain records of information as it was at the time of the advice or the transaction taking place.
If we have provided you with advice or processed a transaction on your behalf, we will not normally be able to erase your personal data. This is because we are obliged to maintain records of our advice and transactions to meet our regulatory requirements and in case we need to exercise or defend legal claims in future.
Our Data Controllers are:
CLS Money Limited
Vantage House, 6-7 Claydons Lane, Rayleigh, Essex, SS6 7UP
Registration number on the Information Commissioner's Office register is Z2887625
HL Partnership Limited
Pharos House, High Street, Worthing, West Sussex, BN11 1DN
Registration number on the Information Commissioner's Office register is Z8588911
If you would like further details on how we use your personal information or if you have any data protection queries, please write to:
The Data Protection Officer, HL Partnership Limited, Pharos House, 67 High Street, Worthing, West Sussex, BN11 1DN
Telephone: 01903 602664*
*Telephone calls may be recorded and monitored for training and security purposes.
If you would like to make a complaint about how we have handled your personal data, please write in the first instance to The Data Protection Officer at the above address.
If you are not satisfied with the Data Protection Officer's response, you can make a complaint to:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email through their website at: https://ico.org.uk/concerns/
**IMPORTANT NOTES ON PROTECTING YOUR OWN DATA
**Please be aware of cybercrime and protecting your own information online, particularly financial information. Do not send unsecure personal information over the internet. We recommend you use encryption software or provide any information to us using the online tools we provide.
Do not respond to emails asking you to pay money. Never make a payment purely in response to an email. Always call the company to validate any payment requests and check the phone number independently from the email i.e. via a secure web site. If you receive a phone call asking for payment ensure you are satisfied the call is genuine, or else call the company back to check. Neither CLS Money nor HL Partnership will take responsibility if you transfer money to a fraudster in error.