Privacy Policy

At Temple Row Wealth Management, we understand our obligations to you and your private life. We have rigorous systems and controls in place, ensuring your privacy, rights and freedoms are protected.

Temple Row Wealth Management undertakes to meet its obligations under the Data Protection Act 1998/2018, the Privacy and Electronic Communications Regulations 2003 and the EU General Data Protection Regulation (GDPR).

Who will process your personal information?

Your personal information will be processed by The Temple Row Wealth Management team initially. After this, your data will be processed by ValidPath Limited. They act as our Principal for regulatory purposes. We can assure you, all parties will process your personal data in accordance with this privacy notice.

Why do we need your personal information?

For us to take the steps to enter you into a contract and to perform such a contract, your personal information is required, allowing us to proceed.

This could include reviewing assets and liabilities, bank account validation, identity and age verification checks, credit checks, preventing and detecting fraud, money laundering or other crimes and any other requirements in accordance with rules set by the Financial Conduct Authority (FCA) or other applicable legislation.

What happens if we want to process your information for other reasons?

Though there are some legal exceptions, if we need to process your personal data for a purpose unrelated to those you have been informed of, we will let you know.

What happens if you do not provide your personal information?

We need your personal information for us to be able to take steps at your request prior to entering a contract or to perform a contract to which you are a party. Without this information, we won’t be able to provide you with a financial service.

What makes the processing lawful?

The processing is essential:

• For the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• For compliance with a legal obligation to which we are subject;
• For the performance of a task carried out in the public interest;
• For the purposes of the legitimate interests pursued by us.

Keeping your information up to date

We ensure your information is recorded exactly as it is received from you. We are happy to update your information at any time, at your request. We will action updates promptly and, where possible, notify relevant third parties of any changes.

What about sensitive personal data?

Unless we are processing because it is necessary for reasons of substantial public interest, we will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific processing activities.  In a case like this, you will be asked to sign a separate consent form to show this and to show that you understand the purpose(s) of processing this data. You can withdraw your consent at any time.

How else will we use your personal information (our legitimate interests)?

• When we need to contact you to make sure our records of your personal information are correct
• To respond to questions or complaints you may have regarding our services
• To ensure we can keep you updated with any possible changes in our terms
• For statistical or research analysis relating to the performance of Wealth Management, or that of our principal and to understand how our clients needs may change
• So we are able to review, improve and develop services we offer or the way complaints are dealt with
• To pursue debts or unpaid fees
• To evidence company practices
• To evidence the standards and processes carried out conform to the company’s ethical standards and expectations
• To use for our direct marketing activities
• To ensure the business is protected from risks which may be introduced by an individual

You have the right to object to processing for these purposes and we shall cease immediately unless we can demonstrate that we have compelling, legitimate grounds to continue.

Processing when performing a task carried out in the public interest

The information provided will be used to protect members of the public against dishonesty, money laundering or fraudulent activities. It is necessary that this is carried out without your consent to ensure this function is not prejudiced.

Part of this processing involves verifying your identity using third parties such as SmartSearch, etc.

What information is required?

We only collect information that is essential to carry out the purposes listed above. This includes information you supply and data we receive from reference agencies. Where practical and lawful, we will inform you about any personal data we receive about you from third parties that you may be unaware of.

How safe is your data?

We will ensure that your data is only accessible to authorised people in our firm and will be confidential at all times. Security measures are put in place to stop unauthorised access, alteration, disclosure, loss, damage or destruction of your information. If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding appropriate security measures in place and only process your information in the way we’ve authorised them to do so. These organisations won’t be permitted to use your personal information for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we’ve put in place. 

Will we share your information with anyone else?

There is a possibility your information will be shared with:

• Appropriate staff, such as those who carry out financial or compliance functions
• Organisations that need your information because it is a legal requirement (eg. The FCA, ombudsman services, HMRC etc)
• Organisations that carry out credit references or identity checks such as GB Group Plc, CreditSafe Business Solutions Ltd and SmartSearch. There is a possibility these organisations will keep a record of the information, and may disclose the fact that a search of its records was made to its other customers for the purposes of assessing the risk of giving credit, to prevent fraud and to trace debtors
• Sometimes, other authorised firms with specialist advisers, such as pension specialists, who assist us in providing suitable financial advice and services. You will be provided with their details if this applies.
• Law enforcement agencies, courts or other public authorities if necessary, or if we are authorised to by law.
• Our auditors.
• Product providers we use to provide financial services or for direct marketing (see below).
• Where we or our Principal go through a business transaction, such as a merger, being acquired by another company or selling a portion of its assets, your information will, in most instances, be part of the assets transferred.

Transferring data outside the European Union

We do not usually transfer any of your personal data outside of the EU except when we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases the third party organisation encrypts any data it sends to other agencies and only transfers information necessary to carry out checks.

What about direct marketing?

The information that has been given to us now and in the future will be used to carry out direct marketing activities. These are legitimate interests pursued by us. Sometimes this includes, with your consent, sharing data with product providers for their marketing activities. You can let us know your preferred method of contact (by email, telephone, SMS or post) and you have the right to object at any time to the use of your personal data for this purpose. If you do not wish to receive direct marketing, we will cease immediately. 

Automated decision-making processes

We sometimes use automated processes when making decisions, but you will not be subject to a decision based solely on automated processing. This includes profiling.

Telephone call recording

In line with The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000, we may record incoming or outgoing telephone conversations for the following purposes:

• To establishing facts and evidence for business transactions
• Ensuring compliance with regulatory or self-regulatory practices
• Ascertaining and demonstrating that standards are being met
• Crime prevention or detection 
• Investigating or detecting the unauthorised use of that or any other telecommunication system
• Safeguarding the effective operation of the telecommunications system

How Long will we keep your information for?

The Financial Conduct Authority lays down rules relating to how long information should be held for and we will keep your information to meet these requirements. We will not keep your information for longer than is necessary.

Requesting a copy of the information we hold

You may ask for a copy of the information we hold about you at any time – it is your legal right. We will provide you with a copy of any non-exempt personal information within one month unless we ask you for an extension of time. To protect your personal data, we will ask you to verify your identity before we release any information. We may refuse your request if we are unable to confirm your identity.

Important rights

On the grounds relating to your situation, you have the right to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest at any time. We will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defence of legal claims.

You have the right to object to processing your personal data for marketing activities at any time. In such a case, we must stop processing for this purpose.

What are your other legal rights?

In addition to the rights listed above, here are your other legal rights:

• Where you have given consent, you have the right to withdraw previous consent to processing your personal data at any time
• You have the right to request from us access to and rectification or erasure of personal data or restriction of processing concerning your data
• You have the right to receive data you have provided to us in a structured, commonly used and machine readable format
• You have the right to lodge a complaint with the regulator (see below)

If you wish to exercise any of these rights. please contact our office.

How to contact our Data Privacy Officer

You can contact our data privacy officer/data protection officer about any data protection or marketing issues by:

Writing to: 

Data Privacy Officer
Temple Row Wealth Management
1^st Floor, 7 Wrens Court
Sutton Coldfield
Birmingham
B72 1SY

Telephoning: 0121 663 6058

Emailing: hello@templerow.co.uk

How do you make a complaint to the regulator?

Writing to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephoning: 0303 123 1113

Emailing: casework@ico.org.uk

By using their website: https://ico.org.uk/