Formed in 2003, Holden & Partners is a chartered firm of FCA regulated independent financial advisers based in Farringdon, London. We provide financial planning advice and investment advice (or ‘wealth management’ advice as it is also called), to individuals, charities, trusts and companies. Read more about us following this link.
When this policy mentions “Holden and Partners”, “we”, “us”, “our” all of those terms refer to PETER R.T. HOLDEN & PARTNERS LLP (company number: OC318393) with registered offices located at The Piano Works, 117 Farringdon Road, London EC1R 3BX.
The person responsible for data protection is Andrew Johnston. You can contact him by emailing him at firstname.lastname@example.org, or by calling him on 0207 812 1460, or by writing to him at The Piano Works 117 Farringdon Road London EC1R 3BX.
Our website is designed for the use of UK clients and if you are based outside of the UK you should not rely on its content.
Purpose of this policy
The objective of this policy is to give clear indications on how Holden and Partners processes your personal data when you visit the website. It also gives information with regards to the way personal data is being processed when you submit a request to be contacted.
Data protection laws
We process your personal data in line with UK laws and regulations and more specifically The General Data Protection Regulation (GDPR)
Under GDPR, consent should be given in a positive and affirmative way by individuals who share their personal data with organisations. According to the European Data Protection Directive, consent means: “any freely given specific and informed indication of his wishes by which the data subject signifies his agreement to personal data relating to him being processed.”
When you submit your personal data on the website, you need to submit it along with your affirmative consent. We will also record your consent.
Personal data collected
We gather a certain amount of personal data from the website. We only collect the personal data that you directly submit to us through the “contact us” form.
The data collected includes all of the following:
First name, Surname, Phone number, Address and a summary of your enquiry.
Holden and Partners collects this data so as to be able to contact you once you have submitted a request.
The following details how we use the data that you have submitted to Holden and Partners through the website:
- Understand your needs and whether we may be able to help you.
- Contact you with regards to the query you have submitted
- Provide you with information as to how the firm may be able to help you
- Confirm what is required so that the firm can provide you with advice
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-out 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 and due to the nature of our business, we will retain all records indefinitely.
Third parties and overseas transfers
When your personal data needs to be transferred to an overseas country that is not part of the EEA (European Economic Area), we will always ensure that there are adequate levels of protection and a similar legislation with regards to data protection. Each country might have different laws and regulations with regards to data protection, however there are some agreements in place, e.g. the privacy shield for the United States of America. Overseas transfers will only be possible when we have your prior affirmative consent to process your personal data. We will contact you to obtain such consent when required.
Data security safeguards
You have several rights with regards to your personal data under GDPR. You can submit a “subject access request” if you wish to obtain a copy of all the personal data we hold about you. You can request to have your personal data updated and you can also require to have your data deleted and not be further processed. You can also request to have your personal data transferred to another controller.
Your rights under the General Data Protection Regulation
Under the GDPR, you have all the following rights:
- The right to rectification
- The right to access
- The right to erasure
- The right to restriction
- The right to object
- The right to lodge a complaint
In order to exercise those rights, please contact Andrew Johnston by eMailing him at email@example.com, or by calling him on 0207 812 1460, or by writing to him at The Piano Works 117 Farringdon Road London EC1R 3BX.
Subject Access Request
You can ask us to provide you a copy of the personal data you provided us with during the initial collection. With regards to access to your personal data, please contact Andrew Johnston by eMailing him at firstname.lastname@example.org, or by calling him on 0207 812 1460, or by writing to him at The Piano Works 117 Farringdon Road London EC1R 3BX.
The Information Commissioners Office (ICO)
If you would like to learn more about the General Data Protection Regulation, you can visit the ICO’s website following this link: https://ico.org.uk/. You can also find an overview of the GDPR following this link: https://ico.org.uk/for-organisations/data-protection-reform/overview-of-the-gdpr/