Rebus Financial Services Ltd are committed to protecting and respecting your privacy.
This Privacy Notice, together with our Terms and Conditions, our Data Protection Letter (if applicable) and any other documents referred to in any of the aforementioned (together the “Policy”) describes the types of personal information we collect, how we use the information, with whom we share it, how you can exercise your rights on your personal data and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. In some cases, and where applicable, we may ask you to sign a separate form of letter (“Data Protection Letter”) to indicate your explicit consent to our processing of your personal data for the purposes set out in the Policy. However, please note that the absence of (i) such a request, or (ii) a Data Protection Letter signed by you, is not intended to be conclusive of this issue and we shall be entitled to conclude that, by visiting us at any of our approved web sites; applications; or Portals, or using our other digital assets or agreeing to receive Services from us, you are accepting and consenting to the practices described in the Policy. Notwithstanding this, you have the right to contact us to object to, or make certain requests in relation to, the processing of your personal data (as explained further in the Your Rights section of this policy).
This Privacy Notice tells you how Openwork and Rebus Financial Services Ltd use the information you give us and how we protect your privacy. It also explains your rights under the General Data Protection Regulations.
Collecting informaiton and protecting your privacy
Our aim is to offer advice that helps you plan your financial future. To provide such advice, we need to know about your personal situation and your Adviser may request sensitive and private information about you, for example, your income, current financial arrangements, health, family commitments and any legal proceedings you may be involved in. Much of the information you provide will, as part of your application, be passed to the company whose products you apply for and details of how they use your information are included in their data protection literature.
If you are unable or unwilling to provide some, or all, of this information your Adviser will be unable to provide you with advice suitable for your circumstances. We do not collect personal information from third parties.
Openwork and Rebus Financial Services Ltd is committed to protecting your privacy. As we would like you to be a lifetime client, we need to earn your trust and assure you that we will keep your personal information confidential and secure and only for as long as is necessary. The criteria we use to determine how long this period is can be obtained from Openwork’s Data Protection Officer at the address below.
We will use it with care and it will only be shared in the ways explained in this notice, or if we are required to by Law or the Financial Conduct Authority (FCA).
Your personal information will only be held for as long as necessary and collected for the purposes of providing advice in respect of the range of products and services outlined in the Initial Disclosure Document or Client Proposition Brochure provided by your Adviser. In addition, we will make every effort to ensure that the information you provide is recorded accurately and that it is only passed to companies who comply with the General Data Protection Regulations (GDPR). If it is required to send your information abroad, we will only do so to countries within the European Union (EU) or to a third country that the EU has determined provides an adequate level of protection and where you are able to exercise your rights to access your personal information under the GDPR.
Controlling and using your personal information
A Data Controller is someone who determines the purposes for and the manner in which your personal data should be processed. Openwork and Rebus Financial Services Ltd and the companies whose products you buy are all Data Controllers. Your Adviser will have given you their contact details and Openwork’s contact details are shown at the end of this notice.
We use your information in a variety of ways:
- To introduce you to a range of products and services offered by the companies we are associated with (or may be associated with in the future).
- To help with administration.
- To contact you with details of changes to products you have bought.
- For business analysis and research.
- For marketing products and services we think may be suitable for you (if you opt into this service).
- To comply with the Law and/or FCA requirements.
- To verify your identity by searching publicly available records held by credit reference agencies.
- To prevent fraud and money laundering we may pass your details to other companies, public bodies including the police or to an insurer’s database. Insurance companies can search databases for any relevant information that exists about you.
We therefore process your data because it is necessary for:
- the performance of a contract to which you area party.
- compliance with legal obligations to which we as the controller are subject.
None of the information gathered about you will be used in automatic decision making.
Your health details
If you apply for some types of insurance (eg. life insurance, pensions, sickness etc.) you will be required to provide details of your health. Under the GDPR, this is regarded as sensitive personal data.
Your Adviser will have access to your medical details unless you prefer to complete a medical statement of health in private. If this is the case, please send it with your application marked for the attention of the “Consultant Medical Officer” in a sealed envelope.
We do need your explicit consent to collect and process your health details, which of course you may withdraw at any time. To provide this consent, you will be asked to sign our GDPR Privacy Notice and provide a copy of this to your Advisor.
Signing our GDPR Privacy Notice will also indicate that you have read and understood the provisions set out.
Mortgage credit checking
If you apply for a mortgage your information will be passed to the lender, who will carry out a credit check. You will also have to provide details of any criminal convictions you may have had. These details will be passed to the lender to carry out any necessary checks.
Marketing and sharing your information
The information you give us will be added to any other details we hold about you. Openwork and Rebus Financial Services Ltd will never sell your details to a third party, but we will share your information with any product provider whose products we recommend to you. We will collect your marketing preferences from you as part of providing you with advice.
We may have to pass your details to another Adviser if, for example your Adviser is ill or you need advice in a different product area. If your Adviser leaves we may pass your details to another Adviser so that we can continue to provide you with a high standard of service.
We may send your information to third parties that are carrying out work on our behalf.
Your Data Protection rights
You have certain rights under the GDPR. These include the right to:
- Ask for a free copy of your personal information in a portable format.
- Stop us sending you marketing material about products and services.
- Have any incorrect information we hold about you corrected.
- Ask us to restrict processing of your personal data.
As the processing of your personal information is necessary for a legal obligation placed upon us by the FCA and may be required for the establishment, exercise or defence of legal claims, we will not be able to permanently delete your personal information until the end of the period we have deemed necessary.
How to get more information
If you would like further details on how we use your personal information or if you have any data protection queries, please write to:
The Data Protection Officer
You may receive more information about data protection from the companies that we have introduced you to.
We may record telephone calls so we can check we have acted on your instructions correctly and to ensure we are giving you appropriate service. We may also monitor calls for security and training purposes.
If you have any complaints about the way we or your Adviser have handled your personal information, please contact the Data Protection Officer at the address given above.
You also have the right to refer your complaint to the Information Commissioner.
What are Cookies?
Cookies are text files containing small amounts of information, often including a unique identifier, which are downloaded to your computer when you visit a website – if your browser preferences allow it. Cookies are then accessed by the originating website on each subsequent visit. Cookies are useful because they allow a website to recognise a user’s computer.
How are cookies used on our website?
We use Google Analytics cookies to hold information about your visit to our site. This helps us better identify the use and popularity of our services and how successfully the website is functioning. If you do not wish us to do this, you can opt out of the Analytics service by installing an add-on for your browser. This can be found at http://tools.google.com/dlpage/gaoptout.Alternatively you can delete/restrict the cookies as for any other cookie – see ‘How to control and delete cookies’ for more information.
Types of cookies
Session cookies are created temporarily when a user visits a website. Once the user leaves the site/closes the browser, the session cookie is deleted. A persistent cookie file remains on the user’s computer and is re-activated when the user visits the website that created that particular cookie. These cookies expire after a certain period (set in the file), or can be removed manually.
Classification of cookies
The cookies on this website have additionally been categorised based on the categories found in the International Chamber of Commerce (ICC) UK Cookie Guide:
Strictly necessary cookies
These cookies allow the website to remember choices you make [such as your username, language or the region you are in] and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages you can customise. They may also be used to provide services you have asked for such as watching videos or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of time you see an advertisement as well as help measure the effectiveness of the advertising campaign.
How to control and delete cookies
You can manage cookie usage through your browser settings. The help function in your preferred browser should provide you with the correct information. Some browsers provide helpful cookie guides:
Internet Explorer: http://support.microsoft.com/kb/278835
Safari 11 for Mac: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
Alternatively, http://www.allaboutcookies.org provides advice on how to do this, and further information on cookies and how to manage them.
N.B. In the case of some mobile devices, it may be necessary to consult the device’s instruction manual to manage cookies effectively.