This Johnson Fleming privacy notice applies to all companies within the ‘Johnson Fleming Group’, as well as any Appointed Representatives. This includes Johnson Fleming Group Ltd, Johnson Fleming Ltd, Johnson Fleming Services Ltd and Johnson Fleming Future Life Planning Ltd. This privacy notice explains how we use any personal information we collect about you. You have various rights regarding your data, restriction, rectification, access, objection, erasure and portability and these are referred to throughout this document.
What information do we collect about you?
We collect information about you when you and/or your employer engage us for employee benefits administration and support, financial planning, financial advice, and/or investment management services. The companies covered by this privacy notice do not provide any services other than those listed here.
This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.
If you are a member of a plan that was established by Johnson Fleming, we will continue to receive and retain information from the product provider for the duration that the plan remains under our agency.
We may also collect information when you voluntarily complete client surveys or provide feedback to us.
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. We’ll provide a copy of this privacy notice for them or, where appropriate, ask you to pass the privacy information to 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 and/or your employer. 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, unless consent has already been provided by your employer.
How will we use the information about you?
We collect information about you in order to provide you with the services for which you and/or your employer engage us.
Who might we share your information with?
Where we provide services to your employer, or where you request additional information or services, these services may be provided by more than one company within the ‘Johnson Fleming Group’ as well as any Appointed Representatives. In such cases, data will therefore be shared between these companies, where required.
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, as well as any Appointed Representatives, 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 and Appointed Representatives.
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 or services 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, in line with data protection law.
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?
In principle, your personal data shouldn’t be held for longer than is required under the terms of our contract for services with you. Also, we’re subject to regulatory requirements to retain data for specified minimum periods. We are also able to and reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than 6 months after we become aware of your death.
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.
You can also request that we restrict the way that we use your data and receive the personal data provided to us in a structured, commonly used and machine readable format.
We’d like to send you information about our products and services and those of other companies in our Group, as well as Appointed Representatives, 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 or appointed representatives. If you no longer wish to be contacted for marketing purposes, please contact us by email (firstname.lastname@example.org) or post.
We may use various technologies to collect and store information when you use our website or service, and this may include using cookies and similar tracking technologies, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website and service, and gather demographic information about our user base as a whole.
Some of these cookies are essential, while others help us to improve your experience by providing insights into how the site is being used.
No non-essential cookies will be placed on your computer until you have given explicit consent via an affirmative act.
Our websites do not store any information that would, on its own, allow us to identify individual users without their permission.
Please refer to the Cookies Notice on our websites for more information about the types of cookies used on each site.
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 Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
0303 123 1113 (local rate)
How to contact us
Or write to us at:
Data Protection Officer Johnson Fleming Fleming House Bromsgrove Enterprise Park Bromsgrove B60 3AL
Johnson Fleming Limited is authorised and regulated by the Financial Conduct Authority (FCA), www.fca.org.uk. Our firm reference number is 736842. Registered in England and Wales, number 04385810. Johnson Fleming Future Life Planning Limited is authorised and regulated by the Financial Conduct Authority, register number 624599. Registered in England and Wales, number 08871387. Johnson Fleming Future Life Planning Limited is an Appointed Representative of Johnson Fleming Limited. Our permitted business is advising on and arranging pensions, savings and investment products and non-investment insurance contracts.