Privacy policy

Data Controller

Personal data we collect

To provide the highest quality service and advice, First Group Capital Finance Ltd. is required to obtain certain personal data about you and our ability to provide you with comprehensive financial advice is dependent on us obtaining certain personal data about you. First Group Capital Finance Ltd. may request personal data from you, which will generally comprise, but not be limited to the following:

• Personal details e.g. name, address, contact details (phone, email), marital status, date of birth;
• Employment details and employment history;
• Details of your financial needs and objectives;
• Financial details including your assets and liabilities (both actual and potential), income and expenditure;
• Details of your current investments, insurance cover and superannuation including amounts, investor numbers and bank account details;
• Details of your personal goals and objectives; Details of your investment preferences and aversion or tolerance to risk;
• Taxation information including your tax file number;
• Information you may provide us about other people e.g. joint applicants or beneficiaries including status of wills, and powers of attorney;
• Information about your contact with us e.g. meetings, phone calls, emails / letters; and
• Information on children e.g. where a child is named as a beneficiary, we will collect and use only the information required to identify the child (such as their name, age, gender). We DO NOT collect Sensitive Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, and data concerning health or sexual preferences.

How we collect your data

In most circumstances, the data that we hold about you has been provided to us by you or under your authority. We may collect your personal data directly from you from a variety of sources, including:

• an application form for a First Group Capital Finance service
• phone conversations with us
• emails or letters you send to us
• meetings with one of our Investment Managers

What we do with the data we hold

We will process your data for limited purposes that will include responding to your requests; providing our services in accordance with our terms and conditions; developing and improving our services to you and to other customers; and informing you by letter, telephone or computer about our services that may be of interest to you. You may tell us if you do not wish to receive marketing material by emailing us at privacy@bellcapitalfnc.com.

Lawful basis for processing data

We take your privacy seriously and we will only ever collect and use data which is personal to you where it is necessary, fair and lawful to do so. Under the General Data Protection Regulation, the lawful bases we rely on for processing data are below. At least one of these must apply when we process personal data:

• Consent: We have been given clear consent for us to process data for a specific purpose
• Contract: To perform any contractual obligations we have with you
• Legal Obligation: Processing data is necessary for us to comply with the law (this includes a regulatory obligation or any agencies for the prevention and detection of crime)
• Vital Interests: Data processing is necessary to protect someone’s life
• Public Task: Data processing is necessary for us to perform a task in the public interest
• Legitimate Interest: Data processing is necessary for our legitimate business interests

Data sharing

To ensure that First Group Capital Finance Ltd. provides you with efficient and effective financial services we will sometimes need to share your data with our partner organisations that support the delivery of the service you may receive, for example:

• Across the First Group Capital Finance Group
• Any financial institution (including fund managers, share brokers, clearing and settlement providers) with whom you will be investing, are invested in or have previously invested in.
• Government departments e.g. HMRC Tax office,
• Your Professional Advisors such as solicitor, or accountant;
• Your Executor or Power of Attorney if required;
• Any other external party as authorised by you at the time.

We will only ever share your data if we are satisfied that our partner organisations have sufficient data protection measures. The organisations receiving this data are not permitted to use your data for any purpose other than for the specific purpose that it was provided. We will never share your data for marketing purposes.

Details of transfers to third country and safeguards

Your personal and sensitive data will be stored and processed on servers based within the European Economic Area (EEA). This data may be shared for registering as a foreign entity/setting up offices in other jurisdictions, including governmental authorities in such countries. We maintain the highest regulation to ensure the data being sent remains secure. Where third party custodians are used, we ensure that they have equivalent measures in place to protect your data in the same way that we do.

Data storage

First Group Capital Finance Ltd. recognises how important the privacy of your personal data is to you and has arranged to store such data in a secure environment. Your personal data may be stored both in hard copy and/or electronically. At all times your personal data is treated as confidential and sensitive. We restrict access to your data by maintaining login and password control on all computer systems and have in place secure, lockable filing cabinets to store hard copies of personal data.

Data retention

We will keep your personal data only where it is necessary to provide you with our products or services while you are a client. We may also keep your data after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your data for these purposes will vary depending on the obligations we need to meet. Once your data is no longer needed it will be securely and confidentially destroyed.

Your data protection rights

You have certain rights under the EU General Data Protection Regulations (GDPR), these are:

• The right to be informed about the collection and use of personal data;
• The right of access to any personal data First Group Capital Finance Ltd. holds about yourself;
• The right of rectification we must correct inaccurate or incomplete data within one calendar month;
• The right to erasure you have the right to have your personal data erased and to prevent processing unless we have a legal obligation to process your personal data;.
• The right to restrict processing you have the right to suppress processing. We can retain just enough data about you to ensure that the restriction is respected in future;
• The right to data portability we can provide you with your personal data in a structured, commonly used, machine readable form when asked; The right to object you can object to your personal data being used for profiling, direct marketing or research purposes.

Access to your personal data

You can request details of the data we hold about you at any time. This is called a Subject Access Request

You can make a Subject Access Request by contacting our Data Protection Officer. You are generally entitled to access the data we hold about you unless there are certain legal reasons that prevent you from doing so. Where you are entitled to access, the time we require to give you access will depend on the type of information requested. We endeavour to respond to your request as soon as practical (within one calendar month) and we may also ask you to identify yourself to our satisfaction. There are certain conditions under which we may refuse you access to your personal data, such as when your request may unreasonably impact upon another person’s right to privacy. If we refuse to give you access, we will tell you and provide reasons for our decision. We will not charge a fee for making a request to access your personal data however, we may charge a fee for accessing your personal data if your request creates additional administrative burdens. If a fee is applicable, we will disclose this to you prior to providing you with the data.

Changes to our privacy notice

We may need to make changes to our Privacy Notice, so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed, we will contact you to let you know. This Privacy Notice was last updated on 24th Feb. 2023.

Complaints

If you make a Subject Access Request and are dissatisfied with our response, you may have the right to complain to the Information Commissioners Office (‘ICO’). A detailed description of the ICO can be found at their website www.ico.org.uk or by contacting them at their address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow Cheshire, SK9 5AF
Helpline Number: 0303 123 1113