This privacy notice explains how we (HJS Financial Planning Ltd) use any personal information we collect about you.
What information do we collect about you?
We collect information about you when you engage us for financial planning/financial advice/mortgage advice/investment management services. This information will relate to your personal and financial circumstances and may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us.
Where appropriate we would ask you to pass the privacy information to them. If necessary and if requested, we’ll provide a copy of this privacy notice for them.
Why do we need to collect and use your personal data?
The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data is required we’ll obtain your explicit consent in order to collect and process this information.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you.
If you agree, we’ll pass on your personal information to our group of companies so that they may offer you their products and services.
We won’t share your information for marketing purposes with companies outside our group of companies/other companies.
In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data we’ll have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they’ll only act in accordance with our written instructions.
Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures to protect your personal data in transit such as secure email, encryption/password protected transmissions or direct transmission.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we keep hold of your information?
During the course of our relationship with you we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship.
We’re are also subject to regulatory requirements to retain your data for specified minimum periods. These are, generally:
- Five years for investment business
- Three years for mortgage business
- Indefinitely for pension transfers and opt-outs
- Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it's in our legitimate interests to do so. In any case, we’ll not keep your personal data for longer than 5 years after our relationship with you has ended.
You have the right to request deletion of your personal data. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information you hold about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
We may like to send you information about our products and services and those of other companies in our group which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other members of the group. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.
For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However in a few cases some of our website features may not function as a result.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner's Office
0303 123 1113 (local rate)
How to contact us
Or write to us at:
HJS Financial Planning Ltd
12 – 14 Carlton Place
This agreement sets out the terms under which our services are to be provided, including details of the specific services and a summary of our charges for those services.
HJS Financial Planning Ltd is a financial planning business, focused on helping you understand and plan for your financial future.
We are also able to act on your behalf in advising you on investments, non-investment insurance contracts and mortgages. We offer you an initial discussion (without charge) during which we will describe our services more fully and explain the payment options.
The areas we can advise on include
|· Open Ended Investment Companies
· Unit Trusts
· Investment Bonds
· Exchange traded Funds
|· Structured Products
· Investment Trusts
· Venture Capital Trusts Pensions
· Income Drawdown
· Phased retirement
|· Term Assurance
· Critical illness Cover
· Income Protection
We do not provide advice in relation to individual share holdings, Options, futures and other derivatives as we believe they are unlikely to be suitable for our clients.
Following our initial discussion, should you decide to go ahead, there may be a cost for our advice and services.
If you have a question or concern about any aspect of our services, please contact us at:
In writing to: HJS Financial Planning, 12-14 Carlton Place, Southampton SO15 2EA.
- Before providing advice, we’ll assess your needs, consider your financial objectives and assess your attitude to any risks that may be involved. If you don’t want to discuss a particular area of financial planning and that area should not form part of the advice given, we can exclude it, if you instruct us to do so. This might of course have a bearing on the advice that might have been given.
- Before making any recommendations, we’ll carry out a suitability assessment so that we are able to act in your best interests.
- We’ll confirm any recommendations we make in writing (our suitability report) along with details of any special risks that may be associated with the products or investment strategies we’ve recommended.
- Where we agree to provide you with a service that includes an ongoing review of the suitability of the investments we have recommended, we’ll carry out this review at least annually. To do this we will need to make contact with you to assess whether the information we hold about you remains accurate and up to date. We’ll issue you with a report setting out the results of our assessment and, if relevant, any updated recommendations.
- Please be aware that investments can fall, as well as rise, and that you may not get back the full amount invested. The price of investments we may recommend may depend on fluctuations in the financial markets, or other economic factors, which are outside our control. Past performance is not necessarily a guide to future performance.
- Specific warnings relevant to the investments, investment strategies or other products we arrange are provided in the relevant product literature provided.
Advice that we offer
Investments and Pension Advice
Before providing advice we’ll assess your needs, consider your financial objectives and assess your attitude to any risks that may be involved. If you don’t want to discuss a particular area of financial planning and that area should not form part of the advice given, we can exclude it, if you instruct us to do so. This might of course have a bearing on the advice that might have been given.
Before making any recommendations we’ll carry out a suitability assessment so that we are able to act in your best interests.
We’ll confirm any recommendations we make in writing (our suitability report) along with details of any special risks that may be associated with the products or investment strategies we’ve recommended.
We advise on non-investment protection products e.g. term assurance, income protection and critical illness from a range of insurers.
Our advised protection planning services are suitable if you are looking for the best way to protect you, your family or your business through products such as critical illness cover, health insurance and life cover.
We may receive a commission payment from a product provider. Typically, the commission payment will be offset against the charges you owe us for our services. If the commission payment relates to a regular contribution policy and you stop paying premiums on that policy, we may be obliged to refund the commission received back to the policy provider. In such cases, we reserve the right to request the full payment of any outstanding balance of charges for our services.
We advise on mortgage products, this means that we will make a recommendation for you after we have assessed your needs.
We offer a comprehensive range of mortgages from across the market, but not deals that you can only obtain by going direct to a lender.
We offer mortgages in the non-business and business markets for first charge loans in both markets. We do not provide advice on 2nd charge mortgages or bridging loans. Where customers have a need for these types of loan we will refer you to a specialist broker.
We will potentially receive various fees from various sources in payment for this advice.
If we intend to advise you on mortgages, we will provide you with a separate document detailing the services we offer and the costs of those services.
Legal and accounting advice
We are not qualified to provide legal or accounting advice or to prepare any legal or accounting documents. This means that the onus is on you to refer any point of law or accountancy that may arise during the course of discussions with us, to a solicitor or accountant.
The Cost of our Services
No fee for Life Assurance, Critical Illness, Income Protection, Accident Sickness & Unemployment, Home Insurance, and Private Medical Insurance. We will be paid by commission from the company.
You will receive a quotation which will tell you about any other fees relating to any particular insurance policy.
Our charges/fees will be VAT exempt as the work we provide for you only involves advice and/or preparing a report. There will be occasions when VAT may be applicable, but we will always tell you if you have to pay VAT before we undertake any work for you. Charges for the on-going service will not be liable to VAT (unless the initial service was liable to VAT) where both the initial and on-going services are part of the same package.
Investment and Pensions
Standard fees – where you wish to take advantage of our full advice process, or our on-going service options. These are shown by way of implementation (initial) and on-going service fees, and it is likely that no VAT is due on these fees.
Ad hoc fees – where you do not wish to subscribe to an on-going service, or where you want specific advice or project work. This will be on an agreed hourly or percentage basis.
Payment for our services will be on the basis of an agreed Advice fee. We will discuss your payment options with you and answer any questions you have. No fee will be due until we have agreed the basis of that fee and how it will be paid along with the work to be carried out.
This process only begins once we have your agreement on the arrangements to be put in place. This involves arranging investments or other products on your behalf, as required, and may extend to implementing a specific financial planning process, such as estate planning.
We will act as the intermediary between the product provider(s) and you with a view to arranging the purchase of the Retail Investment Products as we have agreed.
Fees for the design, production and implementation of a financial strategy are calculated as follows:-
Lump Sum Investments and Single Premium Pensions (including Defined Benefit Transfers)
The fee is calculated according to the size of the transaction, as set out below:-
Unless otherwise explained, the charges below will cover a full advice process: understanding your current situation, objectives, attitude to risk, research to identify suitable solutions, documenting our recommendations and implementing the agreed solutions.
Where we discover a plan is more complex we will inform you of this and ask for your instruction as to whether you want us to review any such additional plan at a cost to be determined at outset.
Initial Advice Options
1. Percentage of Investment or Transfer amount
When our work involves investing a lump sum of money, our charges are:
- 3% on first £200,000
- 2% on the next £100,000 and
- 1% on any balance
This means that our initial charge for an investment of:
- £50,000 would be £1,500
- £250,000 would be £7,000
- £350,000 would be £8,500
As there is a minimum amount of work involved with even relatively small sums to be invested, the percentage is typically higher for smaller investments, such as with an ISA, set up of a new pension plan or pension transfers of funds below £34,000.
Our typical charge for a pension or ISA investment below £34,000 or other similar size investment would be £1,000.
This means that a single premium transaction (ISA/investment/Pension Switch/Transfer) with a value of £30,000 will cost £1,000.
2. Fixed fee
We can agree a fixed fee for the work that we carry out for you in advance.
Our minimum fee for establishing a new Regular Premium Pension or investment contract is £1,000.
For any other work our fee will be on an hourly rate basis, normally subject to a £1,000 minimum fee. Hourly rates are as follows:
- Pension Transfer Specialist £450 per hour
- Director Adviser £300 per hour
- Adviser £200 per hour
- Para-planner £150 per hour
- Administrator £100 per hour
This means that, if a client were to go down the fee route rather than an agreed percentage charge for a Defined Benefit Pension Transfer, the costs would be approximately as follows:
|Rate per hour||No. of hours||Cost|
|Pension Transfer Specialist||£ 450||10||£ 4,500|
|Para-Planner||£ 150||4||£ 600|
|Administrator||£ 100||6||£ 600|
We will provide you with a quotation before undertaking any work that you might be charged for.
Please note; in the event we review a Defined Benefit Scheme (Occupational Pension) and our recommendation is not to transfer, you will still be liable for the agreed fee.
Paying our initial charges
Our charges are payable on completion of our work and must be settled within 28 business days. Payment can be made either by:
- Cheque, card or electronic transfer (we do not accept payments by cash)
- You may pay our charges via deductions from the financial product(s) that you might invest in, where the product/platform provider allows this.
Please note that if you choose to pay by deduction from a financial product this will reduce the amount left for investment and may have other consequences.
Paying our ad-hoc charges
Our charges are payable on completion of our work and must be settled within 28 business days. Payment can be made either by Cheque, card or electronic transfer (we do not accept payments by cash).
You may pay our charges via deductions from the financial product(s) that you might invest in, where the product/platform provider allows this. Please note that if you choose to pay by deduction from a financial product this will reduce the amount left for investment and may have other consequences.
All fees will be agreed before any work commences and where our charges are based on a % of your investments, the amount of our ongoing charges may increase as the size of your fund grows.
On-going Services & Fees – Investments and Pensions
Set out below are the detailed elements for the indicative levels of on-going service that we deliver to our clients. You can, if you wish to, add or enhance levels of service with your adviser if you feel appropriate.
Where we agree to provide you with a service that includes an ongoing review of the suitability of the investments we have recommended, we’ll carry out this review at least annually. To do this we will need to make contact with you to assess whether the information we hold about you remains accurate and up to date. We’ll issue you with a report setting out the results of our assessment and, if relevant, any updated recommendations.
We have 3 service levels:
(£50,001 - £100,000)
|This is our most pro-active service level that provides a full, face-to-face review at least annually, but can be more frequently if agreed with your adviser.
We will offer a detailed review of your taxation affairs including estate planning and capital gains tax as well as your wider circumstances to ensure on-going suitability of the plans that we have recommended.
|This service includes an annual review with an adviser, which may take place in person or over the telephone.
It also includes access to our in-house portfolio services, with quarterly reviews of the funds in which you are invested.
|This is our ‘light touch’ service where we will issue an annual review to you and conduct a telephone review with you on a 2 or 3 yearly basis.
It includes access to our passive portfolio service which combines a range of low cost funds, tailored to your attitude to risk.
At a review, we will cover (not exhaustive):
- Assessment of personal circumstances
- Review of your goals & objectives
- Reassessment of your attitude to investment risk/return
- Review of investment performance & holdings
- Valuations & investment commentary
- Where appropriate, make product or fund switch recommendations in order to keep your plans in line with your objectives
Advice on new investments and savings, including pensions, will be subject to our ‘initial fees’ as shown under our ‘Investment Fees - Standard’ section earlier.
Service will include recommending changes to existing investments and pensions to help meet your goals at an acceptable level of investment risk, providing fund analysis and valuations and a wide range of associated ad hoc services.
Some service levels include a review, the style and frequency alters as shown in the table overleaf. If you choose our Basic service level, then the portfolio that we recommend will be constructed in such a way as to minimise the requirement for review. However, if the funds that we initially recommend are no longer suitable, we will contact you to recommend a change.
Any products we have arranged for you will only be kept under review as part of an ongoing service for which have agreed to pay. Our ongoing services are optional, but if you agree to purchase an ongoing service, unless otherwise agreed, the ongoing service will be provided as a follow up to the initial service.
Ongoing services can be cancelled at any time by informing us in writing (refer to 'Cancellation and amendments' section below) but please note that we do reserve the right to charge you for services we have provided before cancellation.
|On-going Service Offering||Comprehensive||Standard||Basic|
|Keeping you informed with pertinent and relevant information||YES||YES||YES|
|Telephone and email access to your adviser included||YES||YES||YES|
|Telephone and email access to the administration staff 9am – 5pm Monday to Friday||YES||YES||YES|
|Annual valuation of plans invested via ourselves||YES||YES||YES|
|Biennial Review meeting||NO||NO||YES|
|Quarterly portfolio review including fund switches and commentary||YES||YES||NO|
|Annual telephone/Web review meeting||YES||YES||NO|
|Annual Face-to-Face review meeting||YES||NO||NO|
|Additional review meeting, as agreed||YES||NO||NO|
|Liaising with your other professional advisers i.e. legal, accountancy without extra charge||YES||NO||NO|
|Annual Service Charge||1.0%||1.0%||1.0%|
|Minimum fees that may apply||£1,000||£1,000||£500|
Please note the fee is based on the plan value which means that although each client is charged the same percentage, the actual amount levied will vary and as a result, clients who have the basic level of service will pay the same percentage as Standard and Comprehensive, but less in actual monetary value which explains why the three levels of service provide different access and support.
If a client who has a substantial fund value wishes only to have the basic ongoing service we will limit the cost of the basic service to £2,000
The actual amount we received will increase (or decrease) in proportion to any increase (or decrease) in the value of your portfolio.
£50,000 @ 1% = £500 then reduces by £5,000 to £45,000
£45,000 @1% = £450 then Increases to £55,000
£55,000 @ 1% = £550
Alternatively, for clients and their families with more complex financial arrangements likely to need a range of support services over time such as IHT planning, re-mortgaging, taking retirement benefits over time and regular cash flow monitoring, we may agree a bespoke service proposition and fee structure based on expected work, time spent and staff involved. Any such fee agreement will be fully discussed and agreed at outset.
Examples of On-going Fees
If we look after you via our Comprehensive service (as detailed above) & your investments are valued at £150,000, our charge is 1%. Therefore the annual payment to us will be £1,500.
If we look after you via our Standard service (as detailed above) & your investments are valued at £80,000, our charge is 1%. Therefore, the annual payment to us will be £800.
If we look after you via our Basic service (as detailed above) & your investments are valued at £25,000, our charge is 1%. Therefore the annual payment to us will be £250.
Please note: as the value of funds can rise and fall the ongoing fees can also rise and fall.
Paying Our On-going Charges
Payment of on-going charges can be made either by a regular fee, paid by standing order or by deduction from your investment(s) on a monthly, quarterly, six-monthly or annual basis, where the product / platform provider is able to offer this facility.
On-going services can be cancelled at any time by simply informing us in writing with one month notice. Please note that we reserve the right to charge you for services during the notice period.
Payment for services
- By signing this agreement, you are agreeing to pay the charges for our services as set out in section 5 (Services agreed). Your selected payment method is also confirmed in section 5. We’ll tell you if any payments are subject to VAT.
- Our initial charges are payable once we’ve completed our agreed work and must be settled within [28 business days].
- If you are paying our initial charges by instalment (only applies when you have taken out a regular contribution contract) it’s important that you make payments as agreed. Where you miss a payment, or cancel the contract from where the payments are coming from.
Cancellation and amendments to this service
Ending this agreement:
- You or we may terminate this agreement at any time, without penalty
- Notice of termination must be given in writing and will take effect from the date of receipt
- Any transactions already initiated will be completed according to this agreement unless otherwise agreed in writing
- You will be liable to pay for any services we have provided before cancellation and any outstanding fees, if applicable
From time to time it may be necessary to amend the terms set out in this agreement where it’s not necessary to issue a new agreement. If this is the case we’ll write to you with details of the changes at least [28 business days].
Depending on the services we provide, there may be costs and charges (including taxes), not charged by us, but related to the financial products we arrange for you. These charges may be one-off charges (payable up front) or charges payable on an ongoing basis. For example:
- Service costs: If your investments are held on a platform (an online investment administration service) or held with a DFM, the platform provider / DFM will make a charge for administering / managing your investments.
- Investment costs: These are the costs relating to the manufacturing and managing of your investments – for example, fees charged by the investment fund manager, costs relating to investment transactions.
We’ll always disclose any third party costs as part of making our recommendations.
- Aggregated costs and charges: Before we provide you with our advice we will add together all the costs and charges payable so that you are able to understand the overall costs of our services and recommendations. This is referred to as aggregated costs and charges information.
OTHER IMPORTANT INFORMATION
Our Regulator - The Financial Conduct Authority
HJS Financial Planning Limited is authorised and regulated by the Financial Conduct Authority (FCA), 25 The North Colonnade, Canary Wharf, London, E14 5HS.
Our Financial Services Register number is 755721.
Our permitted business is advising on and arranging pensions, savings and investment products, non-investment insurance contracts and mortgages.
You can check this on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/firms/systems-reporting/register or by contacting the FCA on 0800 111 6768.
Unless we notify you in writing to the contrary, we will be treating you as a retail client. This means that you are afforded the highest level of protection under the regulatory system and should have the right to take any complaint to the Financial Ombudsman Service.
There are other classifications of customer that don’t have these rights. These are “professional” customers - such as listed companies, local authorities and larger partnerships or trusts. Also “eligible counterparties” (e.g. national governments and other state bodies, banks or regulated financial services firms).
If you are not happy with our Service
If you have a complaint about your Adviser or any financial advice you have received from your Adviser please contact us at: 12-14 Carlton Place, Southampton, SO15 2EA
We will be happy to provide you with a summary of our internal procedures for handling complaints, this is available without charge upon request.
If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (e.g. if we arranged insurance or a regulated mortgage product). The Financial Ombudsman Service can be contacted as follows:
The Financial Ombudsman Service
Telephone 0300 1239123
Alternatively, where your complaint relates to products or services purchased online, or by other electronic means such as by email, you may refer your complaint to the online dispute resolution (ODR) platform at http://ec.europa.eu/odr
Financial Services Compensation Scheme (FSCS) Current limits
We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim, i.e. it differs for investments, insurance, mortgages and bank accounts.
- Insurance: Insurance advising and arranging is 90% of the claim for non-Compulsory Insurance without any upper limit
- Mortgages: Mortgage advising and arranging is covered up to a limit of £50,000
- Investment: Most types of investment business are covered up to a limit of £50,000
Further information about compensation scheme arrangements is available from the FSCS www.fscs.org.uk
We do not handle Client Money. We never handle cash and will only accept a cheque made payable to us in settlement of Advice or Service fees. Our preferred method of payment is via bank transfer.
If we receive a check for payment to a provider prior to a written recommendation being accepted we are not liable for any movement in markets and potential loss due to none investment.
This section sets out your obligations in agreeing to receive our services.
- Providing information about your circumstances
- Our advice will be based on the information that you give so it’s important that you provide us with accurate and up to date information when we request details about your circumstances and objectives.
This will allow us to provide you with suitable advice. If the information you provide is inaccurate or if you limit the information provided this could affect the suitability of the advice we give.
If it is later proven that our advice would have been different if we had been made aware of a fact or facts that had not been disclosed by you we do not accept any liability for any loss as a result of that advice.
Providing information to your insurer
Your insurance / protection cover is based upon the information you provide to the insurance company. Where you are buying insurance as an individual, this means that you must take ‘reasonable care’ to answer all questions asked by the insurer fully and accurately. This is explained in full within the provider literature.
Investment Advice and Recommendations Scope
Any investment advice we provide will be based on your personal financial circumstances and objectives. We will confirm these and the reasons for any recommendation in an Advice Report.
If you have asked for any restrictions on the types of investment or the markets you wish to invest in, these will be confirmed in the Advice Report. We will always make it clear when products are not within the ‘regulated’ scope, and advise you of your rights.
- Where we send investment applications on your behalf to third parties (e.g. to put an investment into force), we’ll take all sufficient steps to ensure that we obtain the best possible result for you. This is referred to as ‘best execution’.
- We have a best execution policy. If you want to see a copy of it please ask us.
Conflict of interests
- Although we’ll always try to act in your best interests there may be situations where we or one of our other clients has some form of interest in the business being transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your own interests, we’ll write to you and ask for your consent to proceed before we carry out any business for you. We’ll also let you know the steps we’ll take to make sure you are treated fairly.
- We have a conflicts of interest policy. If you want to see a copy of it please ask us.
- We are obliged to put in place controls to prevent our business from being used for money laundering and other forms of financial crime.
- We’ll verify your identity before undertaking any business with you. To do this we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning. The check may leave a ‘footprint’ on your credit file but it will not affect your credit rating.
All of our agreements provided are governed and construed in accordance with the laws of England and Wales. In relation to any dispute, for your protection you agree to submit to the non-exclusive jurisdiction of the English courts.
Other benefits we may receive
From time to time we may attend training events funded and /or delivered by product providers, fund managers and platforms. These events are designed to enhance our knowledge and ultimately therefore enhance the quality of service we provide to our clients.
Under the rules of our regulator, the FCA, as a firm providing independent advice we are unable to accept or retain payments or benefits from other firms (e.g. product providers) as this would conflict with our independent status.
Further details are available on request.
Protecting your personal information
- To provide our services properly we’ll need to collect information about your personal and financial circumstances. We take your privacy seriously and will only use your personal information to deliver our services.
- Processing of your personal data is necessary for the performance of our contract for services with you. Generally, this is the lawful basis on which we intend to rely for the processing of your data. (Please see the reference to special categories of data below). Our policy is to gather and process only that personal data which is necessary for us to conduct our services appropriately with you.
- 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 engage the services of third party providers of professional services in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of 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 (e.g. telephone/ email /letter etc.).
- The organisations to whom we may pass your details also have their own obligations to deal with your personal information appropriately. 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.
- We will issue you with our Privacy Notice. This is a is a separate 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.
- As part of this agreement we’ll ask you to consent to the transfer of personal information in accordance with the protections outlined above.
- Special categories of personal data: there are certain categories of personal data that are sensitive by nature. The categories include: data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and data concerning health. Depending on the nature of the products and services that you engage us for we may need to obtain your sensitive personal data particularly in relation to health. Our policy is that should we require any special category of personal data we will only gather this with your explicit consent.
- Consent - Sensitive Personal Data: The Primary basis on which we intend to process your personal data is for the performance of our contract with you. In the case where we need to process special category (sensitive) data as described above we require your consent by indicating your agreement on the separate Consent Form.
- To enable us to facilitate our service to you we may also engage the services of third party providers of professional services in order to enhance the service we provide to you. These parties may also need to process your personal data in the performance of their contract with us. If you wish to know the names of these third parties please contact us for further information.
- If you are concerned about any aspect of our privacy arrangements please speak to us.
Product cancellation rights
Full details of the products we recommend to you including, for example, the minimum duration of the product, information on your right to cancel or whether no right to cancel exists, and any other early termination rights and penalties, will be covered in the relevant product disclosure information you will receive before the conclusion of any contract.
In most cases you can exercise a right to cancel by withdrawing from the contract. In general terms, you will normally have a 30-day cancellation period for a life, protection, payment protection or pension policy and a 14-day cancellation period for all other policies.
Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be provided to you.
If you cancel a single premium contract, you may be required to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.
Communicating with you
- Our normal ways of communicating with you are by telephone, post, e-mail, SMS text message or in person.
- Our communications will be in English.
- We may ask you to confirm your instructions to us in writing as this helps to avoid any future misunderstandings.
Recording telephone calls
- To ensure we carry out your instructions accurately and to help us to continually improve our service and in the interests of security, we may monitor and record your telephone communications or conversations with us.
- Copies of our telephone recordings will be available on request, for a period of 5 years after the recording was made.
HJS Financial Planning has a complaints procedure for the speedy and efficient resolution of complaints that is available on request.
To contact us in relation to a complaint you can write to us at:
The Compliance Manager
HJS Financial Planning
12-14 Carlton Place
Tel: 0808 1644 222
If you are not happy with the outcome of a complaint investigation, in most cases you can take your complaint to the Financial Ombudsman Service (FOS). The FOS are independent and their job is to consider each case impartially on its own merits and mediate in the event of a dispute between clients and financial firms.
The Financial Ombudsman Service can be contacted at:
Financial Ombudsman Service
Tel: 0800 0234567