Stewart Lyon Limited takes the privacy of personal data seriously and the legal and compliant treatment of this data is at the core of our operations.
This privacy notice explains how we use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage us for financial planning / financial advice / mortgage advice / investment management services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
We will only share your personal data with third parties when it is necessary for the service you have asked us to provide, and we will have contracts/safeguards in place to ensure that they treat the privacy of your personal data with the same importance as we do. You will be advised of the specific third parties with whom we may share your data.
These third parties, amongst others, may include those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
Five years for investment business
Three years for mortgage business
Indefinitely for pension transfers and opt-our business
Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records. We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so.
You have the right to request ‘to be forgotten’, i.e. for us to delete all records of your personal data. We will comply with your request, unless we have a legal obligation to continue to hold your personal data, in which case we will inform you of the reason we are unable to complete your request.
How can I access the information you hold about me?
You have the right to request a copy of any personal information we hold on you. This will be provided in a structured format, free of charge, within 30 days of your request. Requests can be made in writing, by phone or by email, to any of our contact details provided below.
Stewart Lyon Ltd, 18 Pitgaveny Street, Lossiemouth, IV31 6NT
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. You ca request us to rectify any of your personal data which you believe is inaccurate or incomplete. We will respond within one month (this can be extended by two months where the request for rectification is complex). Requests can be made in writing, by phone or by email, to any of our contact details provided above.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Tel 0303 123 1113
How to contact us