We take your privacy very seriously. Please read this Privacy Notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
Montage Wealth Management is a trading style of Montage Portfolio Management Ltd, which is a limited company registered in England under number 4137475 and whose registered office is at 135/137 New London Road, Chelmsford, Essex CM2 0QT, and is authorised and regulated by the Financial Conduct Authority under number 194768.
Your Personal Data
We collect information about you when you engage us for financial planning, investment management, and mortgage and insurance advice. 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. Your Personal Data will include:
- Your name, address, telephone numbers, electronic contact details including email address and mobile number, date of birth, gender, nationality, civil/marital status. We will require documents to enable us to verify your identity.
- Employment and remuneration information, including salary, bonus, overtime, sick pay, employment benefits and employment history. If you have your own business this will include company details, including turnover, profits, salary and dividend information. We will require documents to enable us to verify your income, and /or the company profits.
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants.
- Health status and history, details of treatment and prognosis, medical reports.
- Details of existing deposits, investments, pensions, trusts, mortgages, finance and insurance products, the terms and conditions relating to these. We will require documents / statements to enable us to verify these funds.
We may need to gather personal information about your spouse / partner and 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 will provide a copy of this Privacy Notice for you to pass the privacy information to them.
Special Category Data
As part of your financial planning, and in particular when applying for plans that require medical underwriting, we will ask you for Sensitive Personal Data, which will include information about your health and your medical history. This is seen as Special Category Data, and we will record and use your Special Category Data in order to make enquiries for products that require medical underwriting that may meet your needs, and to provide you with financial planning advice regarding the suitability of any product that may be available to you. We will ask you to sign a separate consent to process your Special Category Data.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially to their Special Category Data. The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management. We will use Special Category Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice. Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How And Why We Use Your Personal Data
When we provide financial planning advice, investment management, mortgage and insurance advice, and our client service to you, we do so on the basis that we are entering into a contract with you to supply a service to you. This will also include the steps required before entering into a contract with you. The information that we collect about you (Your Personal Data) is essential for us to be able to perform that contract to supply the client service that you require from us, and to arrange products for you. We also need to collect Your Personal Data to fulfil our legal and regulatory obligations.
When the contract between us has come to an end, we will have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. We may need to use Your Personal Data for contractual responsibilities to our regulator the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
How We Collect Your Personal Data
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to financial planning, investment management, mortgages and insurance. You will provide information to us verbally and in writing. We will request copies of documents to verify your identity, and copies of statements / documents to research your existing investments, pensions, insurance plans, mortgages and loans. We will also request copies of bank statements to verify your funds, and copies of payslips and tax returns to verify your income.
We often work as a team with client’s Professional Advisers (your accountant and/or solicitor), and we may collect Your Personal Data from your Professional Advisers. We will ask you to sign a Professional Adviser Agreement to confirm your agreement to collect Your Personal Data, including your Sensitive Personal Data, from your Professional Adviser.
We perform electronic verification of identity checks, both at the start and from time to time throughout our relationship, and these do not require your consent to perform. These checks may leave a ‘footprint’ on your credit file but will not affect your credit rating.
We will obtain some information from other third parties, which may include information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your credit status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner.
We may use your personal data to send you updates by email, app notification, text message, telephone or post about developments that might be of interest to you and/or information about our services, including offers, promotions, or new services or products. We have a legitimate interest in processing your personal data for promotional purposes to an existing client, a former client, or as an individual who has expressed an interest in our services, or made an enquiry to us.
This means that we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes. You can change the basis of any consent you may have provided to us including withdrawing any consent in its entirety. You have the right to opt out of receiving promotional communications at any time by contacting us by email, telephone or post, by clicking unsubscribe in emails, or STOP in reply to texts.
What Happens To Your Personal Data
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, on our internal computer systems, including secure emails, hard drives, mobile devices and cloud facilities. This information can only be accessed by employees and consultants within Montage and only when it is necessary to provide our Wealth Management or Wealth Builder service and discretionary investment portfolio management to you, and to perform any administration tasks associated with or incidental to those services.
- Submit Your Personal Data to platform providers, product providers, mortgage lenders and insurance product providers, both in paper form and online via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made for you and to deal with any additional questions or administrative issues that may arise.
- Use Your Personal Data to deliver our client service, including providing ongoing financial planning advice and discretionary investment portfolio management, and to responding to any queries you may have in relation to financial planning, investment management, mortgage and insurance plans you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware.
Security And Retention Of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party. We also ask you to take reasonable steps to safeguard your own privacy when transferring information to us, such as sending confidential information to us securely through a Portal Account instead of unprotected email, and using secure methods of postage when original documents are being sent to us.
During the course of our relationship with you we will retain Your Personal Data, including data provided to us historically, which is necessary to provide our services to you. We will take all reasonable steps to keep your personal data up to date throughout our relationship.
On termination of our services, we will retain Your Personal Data in an archive file either electronically or in paper format, for a minimum of six years, or in instances whereby we have a legal right to such information we will retain records indefinitely. We are subject to regulatory requirements to retain your data for specified minimum periods, which are generally five years for investment business, three years for mortgage business, three years for insurance business and indefinitely for pension transfers and opt out business. These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain Your Personal Data for longer where we believe it is in our legitimate interests to do so. This includes keeping records to be able to respond to future regulatory requests and any future complaint enquiries. You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests detailed above.
Sharing Your Personal Data
In order to deliver our services to you we may send Your Personal Data to third parties such as those that we engage for professional compliance, accountancy or legal services, as well as product and platform providers that we use to arrange financial, investment, mortgage and insurance products for you. To fulfil our obligations in respect of prevention of money laundering and other financial crime we will send your details to third party agencies for identity verification purposes.
We often work as a team with client’s Professional Advisers (your accountant and/or solicitor), and in order to do this we may send Your Personal Data to your Professional Advisers. We will ask you to sign a Professional Adviser Agreement to confirm your agreement to send Your Personal Data, including your Sensitive Personal Data, to your Professional Advisers.
Where third parties are involved in processing your data we will 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 will only act in accordance with our written instructions. Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit, including secure portal transfer.
In each case, Your Personal Data will only be shared for the purposes set out in this Privacy Notice, in other words to progress your investment, pension, mortgage or insurance enquiry or application and to provide you with our professional advice and client service. Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages, it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Privacy Notice. We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Your Rights In Relation To Your Personal Data
- Access. You have the right to request a copy of Your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Correction. You have the right to ask us to correct any mistakes in Your Personal Data. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Erasure. You have the right to ask us to delete Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove Your Personal Data where you have exercised your right to object to processing (see below).
- Object. You have the right to object to us processing Your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Restrict. You have the right to require us to restrict or stop processing Your Personal Data in certain circumstances if you contest the accuracy of the data (details as to the extent to which we can do this will be provided at the time of any such request). This enables you to ask us to suspend the processing of Your Personal Data, for example if you want us to establish its accuracy or the reason for processing it.
- Portability. You have the right to ask us to send an electronic copy of Your Personal Data to another organisation should you wish.
How To Contact Us
If you have any questions or comments about our Privacy Notice, or wish to make contact in order to exercise any of your rights set out within it:
Write to us: Montage Wealth Management, 135/137 New London Road, Chelmsford, Essex CM2 0QT
Email us: email@example.com
Phone us: 01245 506010
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time. You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
How To Complain
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator by writing to:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
or enquire online at https://ico.org.uk/global/contact-us/, or phone 0303 123 1113.