Privacy policy
Basis for Holding Personal Information
This notice explains the terms under which personal information is obtained and stored by Dentons Pensions under the General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018. Personal data is defined as any information that relates to an identified (or identifiable) person.
Dentons Pensions collects sufficient personal information from its clients in order to establish and administer SIPPs and SSASs. It is also used to comply with anti-money laundering regulations and legislation, such as the FCA’s ‘Know Your Client’ guidelines. This information includes basic facts such as their name, address, dependants and contact details but may include health information that is categorised as sensitive personal data, for which we will require the client to provide their explicit consent to process this information.
The lawful basis of the data processing is that the data subject is giving their consent that collection of the data is necessary for the performance of a contract with Dentons Pensions in respect of the products and services provided in accordance with our terms of business. Other bases include where the processing is necessary in relation to the fulfilment of any contract, or where the processing is necessary to pursue our legitimate interest in the operation of Dentons’ business.
Where relevant, clients have the right to withdraw their general and explicit consent at any time, however, without their consent, we will not be able to process the data they have provided.
Information to or from other sources
We may share client information, including by electronic transfer e.g. email, to other product providers and third-party investment advisers we use. We also have a legal obligation to provide information to government departments and regulatory bodies such as the Financial Conduct Authority (FCA), The Pensions Regulator (TPR), HM Revenue & Customs (HMRC), appropriate Ombudsmen and the Information Commissioner’s Office (ICO). We may also use third party companies to administer and communicate information in respect of our legal and regulatory obligations.
Dentons Pensions and its associated trustee companies are controllers and processors of the personal data provided to us. Our registered office is Sutton House, Weyside Park, Catteshall Lane, Godalming, Surrey, GU7 1XE.
How we hold personal data
All the personal data we use is controlled by Dentons Pensions in the United Kingdom. No third parties have access to client personal data unless the law allows them to do so. We have a data protection regime in place to oversee the effective and secure processing of personal data.
All information at Dentons Pensions is stored on secure servers. All our data transfers to and from authorised third party recipients have built-in security features, including encryption, to best protect personal data. Email communications cannot be secured in such a robust manner, although we do endeavour to supply confidential information in password protected files wherever possible.
Client's basic personal data will be kept for a maximum of 6 years, or as long as is required by the FCA (our regulator), following the end of their business relationship with Dentons Pensions, after which time it will be destroyed.
Data Subject Rights
Data subjects have rights relating to how their data is held. This includes being able to request that Dentons:
- Provides copies of personal information held
- Corrects incorrect or incomplete personal information
- Restricts its processing of their personal data
- Stops processing personal data
- Does not use fully automated processing for decision making
Clients may also request that their data be transferred to another data controller in a machine-readable format.
Dentons Wealth will respond to all requests relating to data subjects’ individual rights, however there may be reasons that requests are not able to be carried out, such as if this would prevent the fulfilment of legal or regulatory obligations.
If a data subject wishes to raise a complaint on the handling of their personal data, they can write to our Compliance Officer at Dentons Pension Management Limited, Sutton House, Weyside Park, Catteshall Lane, Godalming, Surrey, GU7 1XE. Alternatively they can email compliance-officer@dentonspensions.co.uk or telephone us on 01453 521 521.
If a client is not satisfied with our response or believe we are not processing their data in accordance with the law, they can complain to the Information Commissioners Office (https://ico.org.uk/).