Privacy Policy

Heritage Independent Financial Consultancy Ltd is the data controller for the personal information described here. We are registered in England and Wales under company number 09191775, with our registered office at 1 Scott House, Cook Way, Bindon Road, Taunton, Somerset TA2 6BG. We are authorised and regulated by the Financial Conduct Authority under reference 624976.

We are not required to appoint a Data Protection Officer. Privacy questions go to Jon Hutchins, who is responsible for data protection at the firm. Contact us at info@heritageifc.co.uk, on 01823 322 222, or in writing at the address above.

We are registered with the Information Commissioner’s Office as a data controller. [Registration number to be added.]

If you send an enquiry through this website we collect your name, email address, telephone number if you give it, the subject of your enquiry and anything else you choose to tell us.

If you go on to take advice from us we collect a great deal more. That normally includes your date of birth, address history, family circumstances, income and outgoings, assets and debts, existing policies and pensions, employment details, attitude to investment risk, and identity documents. Where it affects the advice, for example on protection or annuities, we also collect information about your health and lifestyle. Where we are required to screen you under anti money laundering rules, that screening may return information relating to criminal offences.

Health information is special category data. We collect and use it on the basis of your explicit consent, given when you complete a health questionnaire or application, and in reliance on the substantial public interest condition for insurance purposes in the Data Protection Act 2018.

Any criminal offence information returned by anti money laundering or sanctions screening is processed because we are legally obliged to carry out that screening, and in reliance on the condition in the Data Protection Act 2018 covering the prevention and detection of unlawful acts.

We use enquiry details to reply to you and, if you ask, to arrange an initial conversation. Our lawful basis is your consent when you submit the form, and our legitimate interest in responding to people who contact us.

Once we are advising you, our basis changes. Most processing is necessary to perform our contract with you. Some is necessary to comply with our legal obligations, including the FCA Handbook, the Money Laundering Regulations and tax law. A small amount rests on our legitimate interests in running and improving the firm, where we have satisfied ourselves that this does not override your rights.

You do not have to give us anything to browse this website. If you want advice, you do have to give us the information we ask for. Some of it we are legally required to collect, in particular the identity information required by the Money Laundering Regulations. The rest we need in order to give you suitable advice.

If you decline to give us information, or give us information that is incomplete or inaccurate, we may not be able to advise you, and any advice we do give may not be suitable.

We do not only collect information from you. We commonly receive personal information about you from your existing pension, investment and insurance providers, from lenders and estate agents, and from accountants, solicitors and other professionals who introduce you to us or work alongside us. This is usually the same categories of financial and personal information described above.

Where we receive information about you from someone else and we have not already given you this notice, we will provide it within one month, or at the point we first contact you, whichever is sooner.

This website uses Google Analytics 4 to understand how visitors use the site. Analytics cookies are not set unless you accept them through the cookie banner, and you can change your choice at any time using the cookie settings link in the footer. Full detail, including the individual cookies, is in our cookie policy.

We do not sell your information. We share it where we need to in order to do the job, and where we are required to by law:

• Product providers, lenders, platforms and insurers, when arranging or servicing a product for you.
• Google Ireland Limited and Google LLC, who process website analytics data on our behalf.
• Our IT, back office and file storage suppliers, under written contracts that limit what they may do with it.
• Our compliance consultants, auditors and professional advisers.
• The Financial Conduct Authority, HMRC, the Financial Ombudsman Service, the police, or a court, where we are required or permitted to disclose.

Most of your information stays in the UK. Website analytics data is processed by Google and may be transferred to the United States. Where information is transferred outside the UK we rely either on UK adequacy regulations, including the UK Extension to the EU to US Data Privacy Framework, or on the International Data Transfer Agreement or the UK Addendum to the standard contractual clauses, together with additional safeguards where these are needed.

You can ask us for a copy of the safeguards that apply to any particular transfer using the contact details above.

We do not make decisions about you by automated means alone, and we do not carry out profiling that produces legal effects for you or similarly significant effects. Advice at this firm is given by a person.

If you ask us to, or if you are an existing client and the subject is closely related to advice we have already given, we may send you occasional updates about tax changes, seminars or services. Every message includes an unsubscribe link, and you can tell us to stop at any time by replying or by calling the office. We do not pass your details to anyone else for their own marketing.

Enquiries that do not lead to a client relationship are deleted after two years.

Client records are kept for at least six years after our relationship ends. Where advice carries an open ended liability, in particular pension transfers and pension opt outs, we keep the file indefinitely, because a complaint about that advice can be made many years later and we need the file to answer it. Where we are required to keep something for a specific period by the FCA, the Money Laundering Regulations or HMRC, we keep it for that period.

You can ask us for a copy of the information we hold about you, ask us to correct it if it is wrong, ask us to delete it, ask us to restrict or stop using it, object to our using it, and ask for it in a portable form. Where we rely on your consent you can withdraw that consent at any time, although this does not affect anything we did before you withdrew it.

Some of these rights are qualified. We cannot delete records we are legally required to keep. Contact us using the details above and we will respond within one month.

If you are unhappy with how we have handled your information, please tell us first so that we have the chance to put it right. You can also complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113.