We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.
Radcliffe & Co Life & Pensions Limited collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “Radcliffes “we”, “us” or “our” we are referring to Radcliffe & Co Life & Pensions Limited.
Radcliffe & Co Life & Pensions Limited are a company registered in England and Wales (2114114) Radcliffe & Co Life & Pensions Limited, whose registered office is at Meridians House, 7 Ocean Way, Ocean Village, Southampton, Hampshire. SO14 3TJ. Radcliffe & Co Life & Pensions Limited is authorised and regulated by the Financial Conduct Authority. Radcliffe & Co Life & Pensions Limited Financial Services Register number is 125160.
We provide you with Independent Financial Advice
The personal data we collect and use
In the course of providing our service to you we may collect the following personal data when you provide it to us:
• contact information
• identity information
• financial information
• employment status
• lifestyle information
• health information
• data about criminal convictions or offences
• details of any vulnerability
• details of your dependents and/or beneficiaries under a policy (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.)
• product and investment details
• Your attitude towards investment risk and your capacity for loss.
Information collected from other sources
We also obtain personal data from other sources in the course of providing our intermediary and advice services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
The personal data we obtain from other sources may include the following:
• From lenders and/or product providers:
– product details
• From identification and verification checking agencies:
– identity information
– sanction check information]
How we use your personal data
The below table sets out:
• how we use your personal data
• the lawful bases upon which we collect and use your personal data
• who we routinely share your personal data with
Rationale/Reason for Processing Lawful Basis for Processing Third party recipients linked to that activity
• to apply for decisions in principle for mortgage products and/or quotations for protection and/or general insurance products on your behalf
• to apply for products on your behalf
Performance of a contract
• to refer you to third party advisers to provide you with advice in relation to the advice we give you
Product providers / discretionary fund managers
• to retain records of any services or advice provided to you by us in order to defend potential legal claims or complaints
• to provide you with details of products and services from us and third parties that may be of interest to you in accordance with your preferences. For more information see ‘Marketing’ below
Legitimate interests / Consent
External supplier(s) of data storage and data hosting services to retain records on our behalf
Special category data
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process:
• health information and lifestyle information when providing intermediary financial services in relation to a protection insurance product; and/or
• criminal conviction or offence information when providing intermediary services in relation to a general insurance product or most likely for a mortgage application
In addition to the lawful basis for processing this information set out in the above table, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.
In the course of our activities relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or offence information. Where we do so, in addition to the lawful basis for processing this information set out in the above table, we will be processing it for the purpose of compliance with regulatory requirements relating to unlawful acts and dishonesty.
We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.
You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please contact us:
By phone: 02380 222444
By email: email@example.com
By Post: Meridians House, 7 Ocean Way, Ocean Village, Southampton, Hampshire. SO14 3TJ
In addition, you can opt out of receiving marketing at any time by clicking the ‘unsubscribe’ link at the bottom of our monthly email newsletter. This will remove you from any further marketing and your preference will be recorded on our main system. You will however still receive information from us in relation to your services that we provide and you may also hear from us for any legitimate reason such as a change in legislation.
Whether information has to be provided by you, and if so why
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.
How long your personal data will be kept
We will hold your personal data for differing periods of time depending upon the reason we have for processing it. These retention periods are set out below.
Type of Record Retention Period
Personal details obtained during the course of collecting information to provide the services we are contracted for you Indefinitely for legitimate reasons
Transfer of your information out of the EEA
We will not transfer your personal data outside of the European Economic Area or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
You have a right to ask us for more information about the safeguards we have put in place as mentioned above. To learn more, please see ‘Your rights’ below.
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:
• To access personal data
• To correct / erase personal data
• To restrict how we use personal data
• To object to how we use personal data
• To ask us to transfer personal data to another organisation
• To object to automated decisions
• To find out more about how we use personal data
We will always ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.
We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
To access personal data
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.
To rectify / erase personal data
You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
To restrict our use of personal data
You can ask that we restrict our use of your personal data in certain circumstances, for example
• where you think the information is inaccurate and we need to verify it;
• where our use of your personal data is not lawful but you do not want us to erase it;
• where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
• where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.
We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
To object to use of personal data
You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
To request a transfer of personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).
You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
To contest decisions based on automatic decision making
If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.
You can contact us for more information
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.
If you would like to exercise any of the above rights, please:
• email or write to our Data Protection Officer/Data Privacy Manager at firstname.lastname@example.org or Meridians House, 7 Ocean Way, Ocean Village, Southampton, Hampshire. SO14 3TJ;
• let us have enough information to identify you, e.g. name, address, date of birth;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our supervisory authority
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before the ICO.
How to contact us
Please contact our Data Protection Officer/Data Privacy Manager if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact our Data Protection Officer/Data Privacy Manager, please send an email to email@example.com or write to: Meridians House, 7 Ocean Way, Ocean Village, Southampton, Hampshire. SO14 3TJ
Glossary of Terms
we, us or our Radcliffe & Co Life & Pensions Limited
a company registered in (England and Wales) company number [ 2114114] and having its registered office at [ Meridians House, 7 Ocean Way, Ocean Village, Southampton, Hampshire. SO14 3TJ]
contact information these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address
data controller means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services
data protection regulation applicable data privacy and protection laws
employment status this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance
FCA the Financial Conduct Authority, being the independent watchdog that regulates financial services – our number 125160
financial information this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60
health information this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history
identity information this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number
intermediary services these are the services we provide to you in relation to the products, which may include:
• Independent Financial Planning Advice
• Pension advice
• Investment advice
• Advice on general insurance
• Advice on mortgages
• Tax advice
lenders a mortgage lender (for a list of current lenders which we work with, please contact us – see How to contact us above)
lifestyle information this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits
product this is an investment, pension, mortgage, protection and/or general insurance product in respect of which we provide intermediary services to you
product provider a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above)
sanction check information this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering
vulnerability a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence)
Data Privacy Notice v1.0 May 2018
Everything you need to know about General Data Protection Regulation (GDPR):
The 25th of May marks a big day, not just for financial services but for all companies operating in the UK that hold and protect customer data, it is the day GDRP comes into practice. This new legislation means we have made some changes to the way we manage and use your data.
We believe GDPR is a good thing for clients and businesses, and are committed to making sure we fully comply with the new legislation. Because this move is about greater protection and more transparency, it is important to us that you understand how we manage and process your personal data.
We have outlined our data policies and processes in more detail overleaf. Should you have any questions, requests or concerns relating to your personal data privacy or the information in this flyer, please contact our Data Protection Officer:
GDPR means you have more control
GDPR is purely to do with how we manage and protect data and will not impact on the investment and advice service we provide to you. We are still, if not more so, committed to delivering a market-leading investment management and financial planning service or services.
Personal data – what is it, and what we do with it?
Personal data is information which directly or indirectly identifies you. At Radcliffe & Co we are committed to processing your personal data in accordance with EU data protection laws.
What kind of information will we collect?
We may collect certain personal data, which will aid us in delivering the services set out in our contract with you. This includes personal identity details, financial information, information given during interactions or correspondence, and sensitive personal data. It is important to note that we will only collect this with your consent, unless we have a legal obligation or other lawful basis to do so.
How we collect your data
We may collect your personal data directly from you, as well as from other parties. This includes personal data from someone applying for a joint product or service, like a joint account, as well as from third parties, such as credit reference agencies, fraud prevention agencies, financial advisers, introducers and other product providers.
What we will do with your data
The use of your data could include, but is not limited to, verifying your identity, providing you with advice on products and services, managing your accounts or any contractual relationship with you, or administering surveys and competitions. We will also use it to help improve and keep you up to date with products and services we can provide to you.
Who will have access to your data?
We may disclose your data to a number of parties, including:
Professional advisers, receivers, administrators and product/service providers
Courts, government and non-governmental agencies, law enforcement agencies, tax authorities and the Financial Conduct Authority.
Third parties that acquire, or may acquire, Radcliffe assets, shares or a portion of the business
Credit Reference Agencies and Fraud Prevention Agencies
Registrars and custodians where the market rules dictate
A full list is available at
Data protection outside the EU
We will not transfer your personal data to recipients outside of the EEA.
Knowing your data rights
Under EU data privacy laws, you have a right to request access to, change or object to processing of your personal data.
You can ask us to provide you with the data we hold about you, and if you want to, for us to delete it; although we would advise we do have a legal obligation to retain certain information for compliance with our regulator, the Financial Conduct Authority. In special circumstances, you can even request your data is transferred from Radcliffe & Co to another firm.
Should you wish to do any of the above, please contact the Data Protection Officer.
Products and services that are right for you A better understanding of your circumstances through personal data will help us deliver more products, services and events that may be of interest. We may contact you periodically to provide information regarding the above and invite you to participate in market research. If applicable laws require it, we will always ask for your consent before we send you certain types of marketing communications.
Our promise to you
We will take steps to protect your personal data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. We will retain your personal data for a period of at least 7 years from the end of the relationship to fulfil our record keeping obligations, and will not retain personal data longer than is necessary, unless there is a legal reason for extended retention.
The full Data Protection Notice
For our full Terms and Conditions, and the detailed Data Protection Statement, please visit
Alternatively you can request a paper copy.
We may revise or supplement our Data Protection Statement from time to time to reflect any changes in our business, law, markets or the introduction of any new technology.
Should you have any questions, requests or concerns relating to your personal data privacy or the information in this flyer, please contact our Data Protection Officer:
Data Protection Officer
Radcliffe & Co
7 Ocean Way
Information Collection and Use:
We are the sole owner of the information collected on this site. We will not sell, share, or rent this information to others.
When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.
What are cookies?
These pieces of information are used to improve services for you through, for example:
- enabling a service to recognise your device so you don’t have to give the same information several times during one task
- recognising that you may already have given a username and password so you don’t need to do it for every web page requested
- measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast
- analysing anonymised data to help us understand how people interact with govt services so we can make them better
First-party cookies (cookies set by us)
These are cookies set by our web domain known as ‘first-party’ cookies. Some are necessary to the functionality of the site, others provide information to us that we analyse to monitor and improve the site. These first-party cookies do not store or collect any personal information or anything that make you personally identifiable to us. Typically, the cookies generate a random, unique number to store information about a user.
Cookies for measuring website usage
Google Analytics cookies: _utma, _utmb, _utmc, _utmv, _utmd,_utmz
- Data stored by cookies:
- _utma stores each user’s number of visits, time of the first visit, the previous visit and the current visit
- _utmb and _utmc checks how long a visitor stays on the site: when a visit starts and ends
- _utmz tracks where a visitor came from (search engine, search keyword, link)
- _utmv and _utmd track visitor journeys through the site and classifies them into groups
- Duration of cookies:
- _utma expires two years after your last visit to this site
- _utmb expires 30 minutes after your visit, or after 30 minutes of inactivity
- _utmc expires at the end of a session (when you close your browser)
- _utmz expires six months after it was last set
- _utmv (not set) expires immediately
- _utmd (not set) expires immediately
- Where it is used: all pages of our website
How to control and delete cookies
Alternatively, you may wish to visit the About Cookies website, which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies.
Please be aware that restricting cookies may have an impact upon the functionality of our website.
If you wish to view your cookie code, just click on a cookie to open it. You’ll see a short string of text and numbers. The numbers are your identification card, which can only be seen by the server that gave you the cookie.
For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual. To opt-out of third-parties collecting any data regarding your interaction on our website, please refer to their websites for further information.
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