OFS DPN 2024

Data Protection Notice

It’s all about data

Data is a big part of the world we live in and it can be misused. That is is why we treat your data with great care.

Our advice is at its best when we know everything we need to know. We don’t ask questions to be intrusive, we just want to give you the best advice and provide the best possible outcome.

If there are important facts you don’t tell us, we may give you advice which isn’t right or we may miss a great opportunity. It’s really important that we start this partnership on the right footing, with openness and transparency.

Before reading the finer details of how your data is processed, there are a few key principles we stand by:

We take your privacy very seriously, and only use your information to give you the best advice.

We don’t sell your data on to any third party, give it away or pass it on to any unrelated organisations without your consent unless we are required to do so by law.

We only keep your data for as long as we need to and we don’t bombard you with marketing.

Below are some of the finer points around why and how we collect and keep your data, and who else may see it.

• Processing of your personal data is necessary for the performance of our contract for services with you and for meeting our obligations to prevent money laundering or terrorist financing. Generally, this is the lawful basis which we intend to rely for the processing of your data. (Please see the reference to special categories of data below).

• We adopt a transparent approach to the processing of your personal data. Sometimes, we may need to pass your personal information to other organisations. If you apply to take out a financial product or service, we’ll need to pass certain personal details to the product or service provider.

• We may use the services of third-party providers of professional services in order to enhance the service we give you. They may also need to process your personal data in their contract with us. Your personal information may be transferred electronically (e.g. by email or over the internet) and we, or any relevant third party, may contact you in future by what we believe to be the most appropriate means of communication at the time for example by telephone, email or letter. Third parties won’t typically contact you though without warning. If you wish to know the names of these third parties, or if you have any concerns about a request for information from another company, please contact us for further information.

• The organisations we may pass your details to also have their own obligations to deal with your personal information in the right way. Sometimes a product or service may be administered from a country outside Europe. If this is the case, the firm must put a contract in place to ensure that your information is adequately protected.

• As part of this agreement, we’ll ask you to consent to the transfer of personal information in accordance with the protections outlined above.

• We have a separate Privacy Notice which can be found on our website. This is a document which provides more information about the nature of our personal data processing activities and includes details of our retention and deletion policies as well as your rights of access to the personal information that we hold on you. If you want a copy of this, please let us know.

If you are concerned about any aspect of our privacy arrangements, please speak to us

Sensitive Personal data

There are certain categories of personal data that are sensitive by nature. These categories include: data revealing health, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership.

It is normal that we would ask or find out about your health in the majority of planning exercises we may carry out, whether for a one-off piece of advice or an ongoing relationship between us, and as a result, we will be quite likely to hold Sensitive Personal Data. By signing this document you agree that we can hold this information for you.

The main reason for all of the above is to allow us to fulfil our service contract with you. In the case where we need to process special category (sensitive) data as described above we require your consent by signing at the end of this document.

Marketing

We don’t agree with irrelevant and impersonal marketing to gain business. However from time to time we may wish to contact you to share relevant information or offer additional products or services which may be of interest to you. We don’t want you to miss out on anything which may benefit you and so it’s important we have the opportunity to get in touch when we need to. To do this, we require your consent by agreeing to one or more of the options on the next page.

The Foreign Account Tax Compliance Act (FATCA)

This is a US law aimed at reducing tax evasion by US citizens. The UK opted into FATCA, so investment providers must report clients’ nationalities and residences for tax purposes to HMRC; HMRC will then pass the details of US nationals and/ or US residents for tax purposes to the Internal Revenue Service.

You are expected to know all your nationalities and residencies for tax purposes and be able to provide proof. Failure to report can result in a substantial fine on the client. If you are not solely a UK national and UK resident for tax purposes, please complete the box below. Your adviser must seek approval from a Director prior to advising you and completing applications.

Consent and Agreement

I/We consent to be contacted for marketing purposes (explained in the Marketing section) by:

By signing you confirm acceptance of the terms of this Data Protection Notice and your choices for marketing activity as described above.

Client Name(s)

Client Signature(s)

Date

Please note that you may withdraw this consent at any time by notifying us at our main business address:

295 Aylsham Road, Norwich NR3 2RY