This policy was last updated: 15 May 2018
Date to be reviewed: 15 May 2019
This policy explains how Robyn Allen Solutions Limited will handle the privacy of your information. We are committed to maintaining robust privacy protections for all our users and will take the necessary steps to ensure that users information is safeguarded and kept in accordance with all applicable laws and regulations.
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data, as defined by the Data Protection Act 1998 OR EU Regulation 2016/679 General Data Protection Regulation (“GDPR”)];
“Robyn Allen Solutions Limited” means Robyn Allen Solutions Limited, a Limited Company registered in the United Kingdom, company number 10049195) whose registered address is 27 Halberdier Way, Rothwell, Northamptonshire, NN14 6GW and whose main trading address is 27 Halberdier Way, Rothwell, Northamptonshire, NN14 6GW
“Openwork” are the network that Robyn Allen Solutions Limited is an appointed representative of. Openwork is a Limited Company registered in England (4399725) whose registered address is Washington House, Lydiard Fields, Swindon, SN5 8UB.
“We/Us/Our” means Robyn Allen Solutions Limited.
“You” the user of our website, products and/or services.
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 we 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 our information are included in their data protection literature.
If you are unable or unwilling to provide some, or all, of this information we will be unable to provide you advice suitable for your circumstances. We do not collect personal information from third parties.
We are 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 our 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 policy, 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 us. 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). It if 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.
A Data Controller is someone who determines the purpose for and the manner in which your personal data should be processed. Robyn Allen Solutions Limited, and the companies whose products you buy are all Data Controllers. We will provide you with their contact details.
We use your information in a variety of ways:
We therefore process your data because it is necessary for:
None of the information gathered about you will be used in automatic decision making.
If you apply for some types of insurance (e.g. life insurance, pensions, sickness etc) you will be required to provide details of your health. Under GDPR, this is regarded as sensitive personal data.
We 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 market 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 provided with a hard copy of our Data Protection Policy which you must sign and date. Signing this form will also indicate you have read and understood the provisions set out.
The information you give us will be added to any other details we hold about you. We will never sell your details to a third party, but we may share your information with carefully selected companies we are associated with. Therefore, we (or they) may contact you (by post, email, telephone, or other appropriate means) to tell you about products, services or offers we believe may interest you. The products and services may not be related to financial services. You can ask us not to contact you for this reason, at any time, by writing to us at The Data Protection Officer, Robyn Allen Solutions Limited, 27 Halberdier Way, Rothwell, Northamptonshire, NN14 6GW.
Robyn Allen Solutions is an appointed representative of Openwork Limited. Openwork 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 Openwork may pass your details to another Adviser so that they can continue to provide you with a high standard of service. Openwork may send your information to third parties that are carrying out work on their behalf.
You have certain rights under the GDPR. These include the right to:
As the processing of your personal information is necessary for a legal obligation placed on 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.
If you would like further details on how we use your personal data or if you have any data protection queries please write to:
The Data Protection Officer
Robyn Allen Solutions Limited
27 Halberdier Way
You may receive information about data protection from the companies that we have introduced you to. We may record telephone calls to ensure that the correct actions have been taken based on your instruction, and that the appropriate service is being given. Calls may also be monitored for security and training purposes.
If you have any complaints about the way we have handled your personal information please contact The Data Protection Officer, Openwork Limited, Washington House, Lydiard Fields, Swindon, SN5 8UB. You also have the right to refer your complaint to the Information Commissioner
www.robynallensolutions.com is owned and operated by Robyn Allen Solutions Limited. When you visit our website the server collects IP addresses to provide security and prevent brute force or malicious attacks. These IP addresses are not linked to any other personal data. The address for the UK data centre we use is : Reynolds House, 4 Archway, Manchester M15 5RN
We have a ‘Contact Us’ page which enables you to email us. We require you to complete the fields for your name, phone number, and email address so that we can contact you and provide details of our services to you, as well as deal with general company enquiries. Data collected is held on the grounds of being for legitimate business interests or to fulfil a contractual obligation.
We use social media to engage with users and the Robyn Allen Solutions Limited website links to our Facebook and LinkedIn pages. We do not keep any specific data that identifies an individual user but hold details of our followers on these platforms.
We use an internal CRM to hold our client data. The CRM is based locally on Robyn Allen Solution Limited hardware fully encrypted to AES 256 bit key. Hardware remains locked in Robyn Allen Solution Limited premises at all times.
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our policies as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
Our website uses social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised that before using such social sharing buttons, that they do so at their own discretion, and should consider that the social media platform may track and save requests to share a web page, through the users’ social media platform account.
The General Data Protection Regulation (GDPR) gives individuals, known as ‘data subjects’, the right to access personal data that is held by organisations by a subject access request (SAR). We will endeavour to respond quickly to any such requests, which legally require us to respond within one month of receiving the request and necessary information. If you wish to access the personal data we hold then please email us at firstname.lastname@example.org or write to us at The Data Protection Officer, Robyn Allen Solutions Limited, 27 Halberdier Way, Rothwell, Northamptonshire, NN14 6GW. You will need to tell us how we acquired the information. If you wish to access the information Openwork hold then please contact The Data Protection Officer, Openwork Limited, Washington House, Lydiard Fields, Swindon, SN5 8UB. If you wish to access the information your insurer holds you will need to contact their Data Protection Officer provided to you in your documentation.