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Privacy notice
This website is provided by Brooks Macdonald Group plc (“Us”, “We”, “Brooks Macdonald”) which is the holding company of:
- Brooks Macdonald Asset Management Limited;
- Brooks Macdonald Financial Consulting Limited;
- Cornelian Asset Managers Limited;
- Brooks Macdonald Asset Management (International) Limited;
- Brooks Macdonald International Fund Managers Limited;
- Adroit Financial Planning Limited;
- Integrity Wealth Solutions Limited.
Brooks Macdonald Group plc is registered in England (Company No. 04402058). Its registered office is at 21 Lombard Street London EC3V 9AH. This is also the registered office of Brooks Macdonald Asset Management Limited (Company No. 03417519), Brooks Macdonald Financial Consulting Limited (Company No. 2621847). Adroit Financial Planning Limited (Company No. 07980535) and Integrity Wealth Solutions Limited (Company No. 08462446).
Cornelian Asset Managers Limited is registered in Scotland (Company No. SC113646). Its registered office is at Hobart House, 80 Hanover Street Edinburgh, EH2 1EL.
Brooks Macdonald Asset Management Limited Adroit Financial Planning Limited and Integrity Wealth Solutions Limited are each authorised and regulated by the Financial Conduct Authority.
Brooks Macdonald International (“BMI”) is a trading name of Brooks Macdonald Asset Management (International) Limited, a company incorporated in Jersey (company number: 143275) with its Registered Office at Third Floor, No.1 Grenville Street, St Helier, Jersey JE2 4UF. In Jersey, BMI is licensed and regulated by the Jersey Financial Services Commission, in respect of investment and fund services business.
The Guernsey branch of BMI is licensed and regulated by the Guernsey Financial Services Commission, providing investment management, financial planning and advice services. Business address: Suite 1, Block C, Hirzel Court, St Peter Port, Guernsey GY1 2NN.
The Isle of Man branch of BMI is licensed and regulated by the Isle of Man Financial Services Authority, in respect of investment business. Business address: Exchange House, 54-62 Athol Street, Douglas, Isle of Man, IM1 1JD. The Isle of Man branch will only provide advice from the range of solutions within Brooks Macdonald Asset Management (International) Limited.
In the Republic of South Africa, BMI is an authorised Financial Services Provider, regulated by the South African Financial Sector Conduct Authority.
Brooks Macdonald International Fund Managers Limited is authorised and regulated by the Jersey Financial Services Commission under the Collective Investment Funds (Jersey) Law 1988.
Brooks Macdonald is committed to protecting the privacy of the people that we receive information about. This means that we take steps to lawfully, fairly and transparently process any personal data that is made available to us, in accordance with the UK General Data Protection Regulation (UK GDPR), the General Data Protection Regulation (Regulation (EU) 2016/679) in relation to services offered in the European Economic Area, the Data Protection (Jersey) Law 2018, the Data Protection (Bailiwick of Guernsey) Law 2017, the Isle of Man Data Protection Act 2018 and any other applicable domestic legislation (the “Data Protection Laws”).
This Privacy Notice (“Notice”), together with our Cookie Policy, sets out the basis on which we will process your personal data. If you have any queries about this Notice or how we use your data, you can contact us using the contact details below.
When we refer to “personal information” or “personal data" in this Notice, we mean information which identifies you as an individual, or is capable of doing so. In the context of this Notice, the terms “personal information” and “personal data” may be used interchangeably.
We may hold and use data about you in your capacity as a consumer, business customer, individual, as a shareholder, or any other capacity in which you may visit our websites. Please read this Notice carefully. By clicking ‘accept’ and continuing to visit any of our websites or use of any of our services, you indicate your agreement to our use of your personal information as set out in this Notice.
When do we collect information?
When do we collect information?
We may collect personal information about you when:
- You, or someone acting on your behalf, enquires about our services;
- You register with us, apply to use any of our services, become our client, or contact us in person, by telephone, by e-mail or by post and we go on to provide services to you;
- You voluntarily complete customer surveys, enter a competition or promotion, provide feedback or complete a contact form on our website;
- We receive some personal data about you through the course of providing services to one of our clients, for example if you are;
- A professional adviser, guardian or attorney of one of our clients; or
- A relative or an associate (such as the employer) of one of our clients and we receive your personal data whilst providing services to them; or
- An employee of one of our clients and they have instructed us to source or arrange benefits for members of their staff.
In most instances, we will be the data controller, as defined under applicable Data Protection Laws, of any personal data which we collect from or about you.
We may collect information about you from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks, as explained further below.
Information may also be collected about you when you visit our websites (for example via cookies), such as your IP address and other browser-generated information. More information about this can be found in our Cookie Policy.
We record all calls for training and quality purposes and to enable us to deal effectively with queries or complaints and in the case where customers place transactions on regulated markets, in order to comply with our regulatory obligations.
In order for us to provide services to our clients we may need to process some personal data about other people who are connected to them (third parties).
Typically, the personal data we will collect will either be:
- Data that has been provided to us directly by the third party (for example, because they have contacted us about one of our clients); or else
- Data that has been provided to us by our client or their representative (for example, because records about our clients’ affairs also contain personal data about third parties).
This personal data may be contained in telephone call recordings, electronic communications, minutes of face-to-face meetings and written correspondence.
If you have any queries, comments or requests regarding this Notice or you would like to exercise your rights, set out above, you can contact us via our contact details below.
What information will we collect?
What information will we collect?
We may collect the following information:
- Your contact details, such as your name, address, telephone number and email address;
- Your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
- Passport details, driving license and utility bills;
- Details of the services you request from us;
- Any records held by financial crime prevention agencies, on the Electoral Register and by providers of utility services; and
- Details of your employment status, income and source of wealth.
In some cases, you are not obliged to provide any personal data to us, but if you have requested information or a service from us, we will not be able to provide it without certain information, such as your contact details. Before we can begin providing you with our services, we need to obtain certain information about you, so that we can verify your identity in order for us to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Criminal Justice (Proceeds of Crime) (Financial Services Businesses) Bailiwick of Guernsey) Regulations 2007, the Money Laundering (Jersey) Order 2008 (the “Money Laundering Regulations”), or the Anti-Money Laundering and Countering the Financing of Terrorism Code 2019 (Isle of Man) and any other applicable legislation and for the purposes of crime prevention and fraud prevention. You are obliged to provide this information and if you do not provide it, we will be unable to provide you with our services.
How we will use your information
How we will use your information
We use information held about you in the following ways:
- To process your application to use our services;
- In the case of a third party whose personal information is provided to us, to process a potential client’s application to use our services;
- To undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
- To comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- To help protect your information and prevent unauthorised access to it;
- To deal with any queries, complaints or problems reported by you;
- To generate statistics relating to use of our website, such as the popularity of certain features or services. We do not use personally identifiable information for these purposes;
- To provide you with information about other services we offer that are similar to those that you have already engaged us to provide, or enquired about. You may opt out of receiving this information when we collect your details or at any time by contacting us using the contact details below;
- If required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
- To notify you of changes to our services; and
- To help improve the services we provide to you.
Unless otherwise stated in this Notice, the legal basis for our use of your personal data will be that this information is required for one or more of the legitimate interests described above.
How we protect your information
How we protect your information
We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure. For example, only authorised employees are permitted to access personal information, and they may do so only for permitted business functions. In addition, we use firewalls to help prevent unauthorised persons from gaining access to your personal information.
You are responsible for maintaining the confidentiality of your User ID and password which relate to your access to certain pages of this website or any account you set up with us. You agree to accept responsibility for all activities which occur in relation to the same.
You should not permit other people to use your User ID or password. Please contact us promptly if you believe your User ID or password may have been compromised. We will not be responsible to you if there is unauthorised access to your login details or unauthorised activity on this website as a result of someone else using your login details, unless we caused this to happen because of our negligence.
Despite our efforts regarding security it is important to bear in mind that the internet is not a secure means of communication. Personal information communicated through the internet may be intercepted by other people. We cannot guarantee the security of personal information sent to us through this website. You accept that you use this website at your own risk.
Disclosure of your information
Disclosure of your information
We may disclose your information:
- To businesses that are legally part of the same group of companies within Brooks Macdonald, or that become part of that group;
- To our brokers, dealers, IT providers, services providers and agents in order to provide and maintain the provision of the services;
- To our appointed auditors, accountants, lawyers and other professional advisers, to the extent that they require access to the information in order to advise us;
- To fraud prevention agencies and other organisations to allow us to undertake the checks set out below. We will supply details of such agencies on request;
- To providers of investments or services we recommend, including providers of pensions, offshore bonds, onshore bonds, trusts, investment platforms, discretionary management services, mortgages, mortgage protection products, insurance products or other such products or services. We may also be required to share information with auditors appointed by the providers of such products or services;
- If required to do so by the Financial Conduct Authority, Jersey Financial Services Commission, Guernsey Financial Services Commission, the Isle of Man Financial Services Authority or any relevant regulatory authority where they are entitled to require disclosure;
- If required to do so to meet applicable law, the order of a Court or market rules and codes of practice applicable to the circumstances at the time;
- To investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
- If tax regulations require us to collect information about each investor’s tax residency. In certain circumstances (including if we do not receive a valid self-certification from you), we may be obliged to share information about your account with the relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions;
- In the event that we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets; or
- If any one of the Brooks Macdonald Group companies or substantially all of its assets are acquired by a third party, in which case personal information held by it about its clients may be one of the transferred assets.
We will not lend or sell your information to third parties.
Fraud Prevention Checks
Fraud Prevention Checks
As part of our application process we will arrange for automated checks to be carried out using your personal data, such as your name, postal address, date of birth, telephone numbers and employment status. These checks will be undertaken on our behalf by a third party company that we have instructed to carry out this function for us. The checks will include identification verification checks and financial crime checks and involve us obtaining information from fraud prevention agencies and any records held by financial crime prevention agencies, on the Electoral Register and providers of utility services.
We need to carry out these checks in order to meet our obligations under the Money Laundering Regulations. The information obtained from these checks is used by us to determine if we can accept you as a client, whether further information is required or the application is rejected, based on factors such as whether we have been able to verify your identity.
We may carry out further periodic checks during the course of our relationship with you to verify the information we hold remains correct and that there has been no change in your status (for example when you are a politically exposed person or if you have been subject to a financial sanction).
We may also provide information to financial and other organisations involved in fraud prevention to protect ourselves and our customers from theft and/or fraud. If false or inaccurate information is provided and fraud is identified or reasonably suspected, details will be passed to fraud prevention agencies who will record this. This information may also be accessed by law enforcement agencies. This information may be used by us, other Group companies and other organisations to prevent fraud and money laundering, for example, when processing applications for services or for debt recovery.
Data retention
Data retention
We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this Notice, and for as long as we are required or permitted to keep it by law.
We retain copies of our customer contracts in order to enable us to deal with any legal issues and the information provided to us for identification verification checks, financial crime and anti-money laundering checks (as required by law) for not less than 5 years after termination or expiry of our contract with you. We retain details of complaints for not less than 5 years from the date of receipt.
We shall keep records of the following for not less than 5 years:
- Call recordings, electronic communications and minutes of face-to-face meetings;
- Suitability and appropriateness assessments;
- Periodic statements (for example, valuations); and
- All orders and transactions in financial instruments on your behalf (including information about your identity).
Brooks Macdonald Asset Management (International) Limited retains copies of all records aforementioned for 10 years.
Where applicable, we will keep records of pension transfers, pension conversions, pension opt-outs or Free Standing Additional Voluntary Contributions indefinitely.
Transferring information overseas
Transferring information overseas
We may share your personal information with our service providers and this may involve transferring it to countries outside the European Economic Area (EEA) whose Data Protection Laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Data Protection Laws and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
We may transfer your personal information between businesses that are legally part of the Brooks Macdonald group of companies for the purposes of providing our services to you as follows:
- From our businesses based in the United Kingdom to our businesses based in Jersey, Guernsey or the Isle of Man on the basis that the European Commission has given a formal decision that such countries provide an adequate level of data protection similar to that which applies in the United Kingdom and EEA; and
- From our businesses based in Jersey, Guernsey or the Isle of Man to our businesses based in the United Kingdom on the basis that the United Kingdom is an authorised jurisdiction for the purposes of the relevant Data Protection Laws.
Special Categories of Data
Special Categories of Data
In certain circumstances, in order to provide some services to you, it may be necessary for us to process special categories of data about you (for example, because you have instructed us to recommend certain products such as pensions, insurance policies, or wellbeing products).
Data Protection Laws define the following as special categories of data:
- Data revealing your racial or ethnic origins, your political opinions, religious or philosophical beliefs, or any trade union membership you may hold;
- Data concerning your health, your sex life or your sexual orientation.
We will only ever process such data in a manner that is permitted under Data Protection Laws. This means that, in some circumstances, we may need you to give us your explicit consent to process this data, which we will request where relevant.
In most circumstances, we will not need you to send us any reports or documents about you that contain any special categories of data about you (for example, letters from your doctors or care providers). You should never send these to us unless we specifically ask you to do so.
Your rights and how to contact us
Your rights and how to contact us
You have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below.
The right:
- To ask us not to process your personal data for marketing purposes;
- To access personal data held about you and to obtain a copy of it;
- To request the rectification or completion of personal data which are inaccurate or incomplete;
- To restrict or object to the processing of your personal data;
- To request its erasure under certain circumstances;
- In certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible;
- To be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
- To lodge a complaint about the way in which your personal data is being used to your Data Protection Authority: the Information Commissioner's Office (United Kingdom), the Office of the Information Commissioner (Jersey),the Office of the Data Protection Commissioner (Guernsey) or the Information Commissioner (Isle of Man)
When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.
If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at:
E-mail: [email protected]
By post: United Kingdom: Data Protection Officer, Brooks Macdonald Group plc, 21 Lombard Street, London, EC3V 9AH
Jersey: Data Protection Officer,1 Grenville Street, St Helier, Jersey JE2 4UF
Guernsey: Data Protection Officer, Suite 1, Block C, Hirzel Court, St Peter Port, GuernseyGY1 2NN
Isle of Man: Data Protection Officer, Exchange House, 54-62 Athol St, Douglas, Isle of Man, IM1 1JD
Alternatively, if you would like to contact your Data Protection Authority, please use the contact details below.
United Kingdom: Information Commissioner’s Office
Jersey: The Office of the Information Commissioner
Guernsey: The Office of the Data Protection Commissioner
Isle of Man: Information Commissioner's Office
Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.
Marketing
Marketing
We would like to send you information about products and services of ours and other companies in our Group which may be of interest to you. We would also like to send you news and information about the financial markets and financial services. We will seek your consent before sending you any such marketing or communications. When you register with us or apply to use our services you may specify your marketing and communication preferences or indicate that you do not wish to receive news or information. If you have consented to receive marketing communications you may change your preferences or opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at [email protected]
We may from time to time offer joint or co-branded products and services.
Cookie policy
Changes to our Privacy Notice
Changes to our Privacy Notice
We reserve the right to amend this Notice at any time. Any substantive changes we make to this Notice in the future will be placed on this webpage. This Notice was last updated in September 2023.
