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Privacy policy

Who we are and how to contact us

Your personal information will be held securely by Chetwood Financial Limited, company number 09964966 of Ellice Way, Wrexham Technology Park, Wrexham, LL13 7YT. Chetwood Financial Limited is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority, under registration number 740551.

Authorisation can be checked on the Financial Services Register at www.fca.org.uk. In this policy, we, us and our, refers to Chetwood Financial Limited (‘Chetwood’).

Chetwood are the data controller (this means an organisation who determines the purposes and manner in which any personal data is processed) of your information under data protection laws because, in the context of our business relationship with you, we decide how and why it is processed in the ways explained in this policy. We’re registered with the Information Commissioner's Office, in compliance with the Data Protection Act 1998, under registration ZA218401.

Chetwood as data controller and our Data Protection Officer can be contacted at the ”Contact Us” section on our website at any time, including if you have queries about this policy, or wish to exercise any of the rights mentioned in it.

You will see at the end of this policy that we mention the privacy policies of Credit Reference Agencies (CRAs) we use. We need to share these with you. Please read them carefully and contact those organisations if you have any questions (their details are in their policies).

Have you been introduced to us by an intermediary?

We conduct some recruitment through intermediaries such as Recruitment Agencies.

When an intermediary processes your personal information on our behalf, this policy will apply and you should contact us to exercise your rights under data protection laws. When an intermediary processes your personal information as a data controller in its own right, its own privacy policy will apply and you should ask them for a copy if you do not have one.

Where we obtain your information

We will generally collect your personal information from you directly. If you are introduced to us by an intermediary, we may obtain some personal information about you indirectly from them when they introduce you to us.

This will include information you provide, and any additional information provided by others in various ways, including: (a) in emails and secure website messages; and (b) information Chetwood receives from other organisations (for example, CRAs, recruitment agencies and Disclosure and Barring Service (DBS)). This can also be from information we gather from your use of, and interaction with, our internet services.

Some of the personal information obtained from CRAs will have originated from publicly accessible sources. CRAs draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about CRAs below.

What kinds of personal information do we process?

This will include:

  • Your title, full name, your contact details, including for instance your email address and mobile telephone numbers;
  • Your home address and address history;
  • Your date of birth and/or age;
  • A number or code given to you by a government to identify who you are, such as a National Insurance number;
  • Personal information which we obtain from Recruitment Agencies;
  • Your financial details e.g. your salary;
  • Personal information about your credit history which we obtain from CRAs, including data which originates from Royal Mail (UK postal addresses), local authorities (electoral roll), the insolvency service, Companies’ House, court judgments decrees and administration orders made publicly available through statutory public registers (see the section on ‘Credit Reference Agencies’ below);
  • Information about your current and past employment history;
  • Information about your education history;
  • Information that you choose to reveal about your racial or ethnic origin, religious or philosophical beliefs, trade union membership, health, disability or sexual orientation that will allow us to meet your needs in the workplace;
  • Information which is relevant for your residency and/or citizenship status, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside and work in UK; and
  • Information about criminal proceedings, outcomes and sentences.

What are the legal grounds for how we use your information

Data protection laws require us to explain what legal grounds justify us using your personal information (this includes sharing it with other organisations). The laws refer to “processing” of information – a term which includes everything we do with your personal information from its collection, right through to its destruction or deletion when we no longer need it. For some processing, more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us:

  1. Processing necessary to perform our contract with you for employment, or for taking steps before entering into it, during the application stage:
    • Administering our business relationship, updating your internal records or to contact you; and
    • All stages and activities relevant to managing our business relationship including enquiries and role applications.
  2. Where we consider that, on balance, it is appropriate for us do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations (who we list below) are:
    • Administering and managing our business relationship with you, updating your internal records or to contact you;
    • To adhere to guidance and best practice under the regimes of governmental and regulatory bodies such as the Financial Conduct Authority, the Prudential Regulation Authority and the Information Commissioner’s Office;
    • For management and audit of our business operations;
    • To carry out searches at CRAs both at the application stage, and periodically after that;
    • To carry out monitoring and to keep records (see below for more information);
    • To administer our good governance requirements (such as internal reporting and compliance obligations);
    • For market research and analysis and developing statistics; and
    • When we share your personal information with these other people or organisations including:
      • Other members of our group;
      • The intermediary who introduced you to us;
      • Our legal and other professional advisers and auditors;
      • Financial institutions and trade associations;
      • Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, Financial Services Compensation Scheme and the Information Commissioner’s Office;
      • Other organisations and businesses who provide services to us; and
      • Credit Reference Agencies (see below where we explain more).
  3. Processing necessary to comply with our legal obligations:
    • For compliance with laws that apply to us;
    • For establishment, defence and enforcement of our legal rights, or those of any other member of our group;
    • For activities relating to the prevention, detection and investigation of crime;
    • To carry out identity checks and anti-money laundering checks;
    • To carry out monitoring and to keep records (see below);
    • To deal with requests from you to exercise your rights under data protection laws;
    • To process information about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud); and
    • When we share your personal information with these other people or organisations:
      • Law enforcement agencies and governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, Financial Services Compensation Scheme, the Prudential Regulation Authority and the Information Commissioner’s Office; and
      • Courts and to other organisations where that is necessary for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations.
  4. Processing with your consent:
    • When you request that we share your personal information with someone else and consent to that;
    • When processing or storing information, you choose to reveal about your racial or ethnic origin, religious or philosophical beliefs, trade union membership, health, disability or sexual orientation that will allow us to meet your needs in the workplace. This would require your explicit consent.
  5. Processing for a substantial public interest under laws that apply to us where this helps us to meet our broader social obligations such as:
    • Processing that we need to do to fulfil our legal obligations and regulatory requirements; and
    • When we share your personal information with other people and organisations.

How and when can you withdraw your consent?

As set out in the previous section, much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent (this is set out in point 4 of the previous section), you have the right to take back that consent for future processing at any time.

You can do this by contacting us through the “Contact Us” section on our website. If you do, you should tell us which of the relevant uses you want to withdraw your consent from. Withdrawal of your consent will not prevent us using your personal information where we are doing so on one or more of the other legal grounds.

We will tell the intermediary who introduced you to us that you have withdrawn your consent, only if they are our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do so when you exercise certain rights under data protection laws.

You should make sure to contact them directly to withdraw your consent for what they do with your personal information, as a data controller in their own right.

Where we store your details

We’re based in the UK and will generally store it in the UK, but we may transfer your personal information abroad, which may involve a transfer to another country in the European Economic Area (EEA) or outside the EEA. If your information is processed within the EEA it is protected by European data protection standards. If your information is transferred outside the EEA, we’ll make sure that suitable safeguards are in place before we transfer the information. These safeguards may include contractual obligations imposed on the recipients of your information to protect it to the same standards required in the EEA and/or to require the recipient to subscribe to international frameworks intended to enable secure data sharing. You can find out more by contacting us through “Contact Us” on our website.

How we use Credit Reference Agencies

In order to process your application for employment, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). CRAs collect and maintain information about natural persons credit behaviour. This includes the Electoral Register, fraud and crime information, and credit information, including details of the conduct of your accounts, and public information such as County Court Judgements, decrees, and bankruptcies.

Where you have a business relationship with us we may also make periodic searches at CRAs to manage the relationship. To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation, financial history and fraud prevention information.

We will use this information to:

  • Verify the accuracy of the data you have provided to us;
  • Prevent criminal activity, fraud and money laundering (including by helping us check your identity as described further below); and
  • Manage the relationship.

We will continue to exchange information about you with CRAs while you have a relationship with us. The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail by following the link at the end of this privacy policy.

What should you do if your information changes?

You should tell us without delay so that we can update our records by getting in touch at “Contact Us” on our website. If you were introduced to us by an intermediary who have informed you they are a data controller in its own right (they will have given you a similar policy to this one), you should contact them separately. In some cases where you exercise rights against us under data protection laws (see below), we may need to inform the intermediary, but this will not always be the case.

Do you have to provide the information to us?

You are unable to enter a business relationship with us without us having personal information about you. Your personal information is required before you can enter into the relevant contract with us, or it is required during the life of that contract, or it is required by laws that apply to us. In cases where providing some personal information is optional, we will make this clear.

Do we monitor any of your information?

In this section, where we refer to “monitoring” this means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, internal Chetwood assets and other communications.

We may monitor, where permitted by law, and we will do this where the law requires it. Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you and for quality control and training purposes.

How we check your identity

When we search CRA files in assessing your application, the CRAs also give us other details and information from the Electoral Register to verify your identity. They keep a record of our application, whether or not your business relationship commences with us.

Using your personal information to contact you

Chetwood will use your personal information so we can contact you regarding matters relating to our business relationship. We might contact you by mail, telephone, email, or text message.

Cookies

At Chetwood we use cookies to give you the best possible experience on our website. Cookies are text files stored on your computer, mobile or tablet, when you visit websites. Our cookie policy explains what types of cookie we use, why and how to identify and delete them. You can choose to delete or disable our cookies, but if you do this, some of our services may not work properly.

IP addresses

When you visit our website, our web servers automatically obtain your domain name, IP address and details about your device. These details reveal nothing personal about you. We use this information to investigate abuse of our website and its users, and to co-operate with law enforcement. We share this information with third parties, but only in aggregate.

Data anonymisation and use of aggregated information

Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this policy.

How long will we keep your information?

Unless we explain otherwise to you, we will hold your personal information for the following periods:

  • We retain candidate’s personal information for 12 months from the point of application. The information you provide on application is used to undertake the relevant identify, credit status and criminal record checks; to assess your suitability to do the role you have applied for and; for potential future claims or queries;
  • At the end of an employees’ service we will retain personal information for 6 years. We use employee information as evidence of employment and role suitability; to enable us to provide entitlements and benefits; and for potential future claims or queries.

What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. For example, there may be legal reasons, such as the need to prevent fraud or crime, for us to comply with our regulatory requirements or to perform the contract with you, which limit when they can be exercised. If you wish to exercise any of them, we will explain at that time if they are engaged or not.

  • The right to be informed about your processing of your personal information;
  • The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
  • The right to object to processing of your personal information;
  • The right to restrict processing of your personal information;
  • The right to have your personal information erased (the “right to be forgotten”);
  • The right to request access to your personal information and to obtain information about how we process it;
  • The right to move, copy or transfer your personal information (“data portability”).

If you are not satisfied with any aspect of the way that we process your information or fulfil our obligations, you have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/

If you want to contact us to exercise these rights, select “Contact Us” on our website.

If you wish to exercise any of these rights against the CRAs, or an intermediary who is data controller in its own right, you should contact them directly.

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll reflect any updates within this policy. You should revisit this page from time to time to make sure you are aware of any updates we have made. This privacy policy was last updated in May 2018.

Data Privacy notices from other organisations

We have mentioned that we share your personal information with Credit Reference Agencies. They require us to pass on to you, information about how they will use your personal information to perform their services or functions as a data controller in their own right. This notice is separate to our own. It is in the separate leaflet that can be found at;

Experian: http://www.experian.co.uk/crain/index.html

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