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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, SmartSave, 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.

To contact your Data Protection Officer, to find out more about how we process your personal data or exercise any of your rights (see below), get in touch.

How we collect your personal information

We’ll collect your personal information in the following ways:

  • Direct - we’ll collect the personal information you’ve entered when you’ve got in touch or applied for a job role directly through our website
  • Intermediary - we’ll collect the personal information you’ve provided through a recruitment agency during the job application process

We also collect personal data from other third parties such as Fraud Prevention Agencies (FPA’s).

What kinds of personal information we collect and process

We’ll collect some or all of the following information about you:

  • Personal information - your name and date of birth
  • Contact and residential information - your address, address history, telephone numbers, email address
  • Financial information - your salary
  • Nationality and citizenship information - your nationality and/or whether you have the permanent right to reside in the UK
  • A unique number or code given to you by a government body to identify who you are, such as a National Insurance number
  • Employment details - your current and past employer history
  • Education history
  • Contact history - records of when and how you’ve contacted us including your IP and MAC address
  • Information about your devices and the technology you use
  • Personal information about your credit history which we’re given by Credit Reference Agencies (see the section on CRAs below)
  • Personal information which we collect from Fraud Prevention Agencies
  • Information about criminal proceedings, outcomes and sentences

Why we process your personal 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 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:

Grounds Purpose

Contractual obligation

Processing of your personal data is necessary for us to perform our contract with you or for taking steps before entering into the contract

  • Updating your internal records or to contact you
  • Managing our business relationship including enquiries and job role applications
  • Verifying and updating your contact information
  • Addressing any enquiries or complaints we receive from you

Consent

Processing of your personal data requires us to obtain your clear consent

  • When you request and give consent that we share your information with someone else
  • For direct marketing communications
  • For some of our processing of special categories of personal data including, for example, your health or if you’re a vulnerable customer

Legal obligation

Processing of your personal data is necessary for us to comply with laws we abide by

  • For activities relating to the prevention, detection and investigation of crime
  • To carry out identity checks
  • To deal with requests from you to exercise your rights under data protection laws;
  • When we share your personal information with other people or organisations that is necessary for the administration of justice
  • Complying with laws which require us to provide information to any national authority
  • To otherwise meet our obligations under all laws and regulations based on law which apply to our business activities

Legitimate interest

Processing your personal data is necessary for your individual legitimate interests or the legitimate interests of a third party including their commercial interest or the broader interests of society

  • Administering and managing our business relationship
  • Updating our internal records or to contact you
  • Responding to enquiries and requests for information by any of our Regulators
  • Internal reporting and compliance obligations
  • For market research, analysis and developing statistics
  • Sharing your personal information with other people or organisations intermediaries or professional advisers and auditors

Vital interests

Processing of your personal data is necessary to protect someone’s vital interests including protecting someone’s life

  • Processing of special categories of personal data. For example, about your health
  • To fulfil our legal obligation and regulatory requirements
  • When we share your personal information with other people and organisations. For example, if they need to know you’re a vulnerable customer, social services, your carer or relatives and anyone who has power of attorney over your affairs

Public interests

Processing of your personal data is necessary for us to perform a task in the public interest

  • Processing of special categories of personal data. For example, about your health
  • To fulfil our legal obligation and regulatory requirements
  • When we share your personal information with other people and organisations. For example, if they need to know you’re a vulnerable customer, social services, your carer or relatives and anyone who has power of attorney over your affairs

How we use Credit Reference Agencies

In order to process your application, we’ll perform credit and identity checks on you with one or more credit reference agencies (“CRAs”).

CRAs collect and maintain information about consumers' and businesses' credit behaviour.

CRA’s use information from:

  • Electoral register
  • Credit information
  • Public information such as County Court Judgments, decrees, and bankruptcies

We’ll continue to exchange information about you with CRAs while you have a relationship with us.

We’ll use this information to:

  • Verify your identity
  • Check the accuracy of the data you have provided to us
  • Prevent criminal activity, fraud and money laundering
  • Manage the relationship

How we use 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.

IP addresses

When you visit our website, our web servers automatically take note of 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, share this information with third parties and to cooperate with law enforcement.

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.

Do you have to provide the information to us?

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’ll make this clear.

How we monitor your personal information

his 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 and other communications.

Some of our monitoring may be to comply with:

  • regulatory rules
  • self-regulatory practices
  • procedures relevant to our business,
  • to prevent or detect crime
  • 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
  • for quality control and staff training purposes

How long will we keep your personal information?

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

  • 12 months from the point of application - your information is used to undertake the relevant identify, credit status and criminal record checks
  • 6 years after the end of an employee's service - your information is used as evidence of employment and role suitability, help us provide entitlements and benefits and for potential future claims or queries

How and when can you withdraw your consent?

Much of what we do with your personal information is not based on your consent, instead it’s based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time.

You can do this by contacting us through our website. 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’ll also tell the intermediary who introduced you to us, if any, that you have withdrawn your consent, but only if they are our data processor (an organisation who is processing personal information on our behalf) or if we’re required to do so under data protection laws.

Your rights

Here are your rights under data protection laws. There may be reasons why you can’t exercise your rights, but we’ll always tell you if this is the case and explain in more detail when your request is made.

  • Right to be Informed – the right to know we’re processing your personal information
  • Right to Access - the right to request access to the personal information we hold about you
  • Right to Rectification - the right to request we update and correct any out of date or inaccurate personal information we hold about you
  • Right to Erasure (‘The Right to be Forgotten’) - the right to request that we remove all personal information we hold about you, if there is no need for us to keep it
  • Right to Restrict to Processing - the right to request we restrict the processing of your personal information
  • Right to Object to Processing - the right to request we stop processing your personal information
  • Right to Data Portability – the right to request us to provide personal information you’ve supplied to a third party
  • Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

If you want to contact us to exercise these rights, get in touch with us on our website.

If you wish to exercise any of these rights against the CRAs, or an intermediary, you’ll need to contact them directly as they’re data controllers in their own right.

Complaints

If you’re not happy 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 who enforce data protection laws. They can be found at: https://ico.org.uk/.

What should you do if your information changes?

Get in touch with us as soon as possible if your information changes so we can update our records.

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. Take a look at our cookie policy to find out more.

Data Privacy notices from other organisations

We’ve mentioned that we share your personal information with CRAs. They require us to let you know how they use your personal information to perform their services. You can find out more about this in a helpful leaflet here: http://www.experian.co.uk/crain/index.html

Changes to our privacy policy

From time to time we update our policy to reflect changes we’ve made. This privacy policy was last updated in August 2018.

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