Privacy Notice

Why you should read this

Data protection regulation gives you more control over the way organisations collect and use your information.  In short, it’s a good thing.

This privacy information notice is about when and why PageRussell collects information about people who visit our website or seek our services, how we use it, when we might pass the information on to others and how we keep it secure.  If you are happy with what we’ve outlined below, no further action is necessary.

How we collect your information

We collect information from you, the providers of your financial products and other organisations.

We collect your information in the following ways:

  • From you over the telephone, in meetings, via our client portal or online questionnaires.
  • We ask your permission to contact your financial plan providers or use a data aggregation service.
  • We use a verification service to check your identity information and make sanctions checks.
  • Our website uses cookies which collect anonymous information about visitors to our website.

Information we collect and use

The quantity and sensitivity of your information that we collect and use increases throughout your journey to become a PageRussell client.

To provide our service to you we may collect and use the following information about you:

  • Contact information such as telephone numbers, post and email addresses.
  • Financial information such as your assets and liabilities, income and expenditure.
  • Employment details and, if self-employed or a business owner, information about your business.
  • Your financial goals and lifestyle interests.
  • Health information including whether you smoke and what medication you take.
  • Any vulnerabilities you may have including loss of capacity to make decisions.
  • Your financial products, such as pensions, investments and insurance plans.
  • Your attitude to financial risk, capacity for loss and return required.
  • Information about financial dependents or beneficiaries. If you provide information about other people we expect you to tell them and that they are happy for you to do so.  We recommend you share this privacy notice with them and ask them to contact us if they have any questions.
  • Identity information such as passport or other identity document information. We may conduct electronic money laundering checks on you.  This will not leave a footprint which would impact your credit rating.
  • Our website uses anonymised third-party cookies from Google Analytics which provide us with information about the location of visitors, what pages they look at and for how long.

Why we collect your information and who we may share it with

Before we can collect or use your information we must have a valid reason and a lawful basis for doing do.  PageRussell uses different reasons for different situations.

We may share your information with other organisations who help us provide our services to you, or to whom we may have a legal obligation to give the information.  We do not sell or rent your information to other organisations or share your information with them for their marketing purposes.

The reasons we collect your information and who we might routinely share it with are:

Reason for using your information Lawful basis Other organisations we might share your information with
·       To provide you with our independent financial planning, investment and tax compliance services. Performance of a contract Product providers and fund managers; data base, call recording, email, research, risk profiling, cash-flow, tax compliance and accounting software providers; outsourced paraplanners.
·       To refer you to third party professional advisers to provide you with advice. Consent Solicitors, accountant, mortgage advisers.
·       To provide you with details of products and services from us and third parties that may be of interest to you electronically. Consent Data base and email software provider.
·       To keep records of any services or advice we provide you to defend potential legal claims or complaints. Legitimate interest Data storage supplier, professional indemnity insurance broker and insurer, compliance consultant.
·       To keep records of any services or advice we provide you to respond to a legitimate request by a regulator, court or tribunal. Legal obligation The Financial Conduct Authority or other regulator, court or tribunal.

We give other organisations only the information they need to complete their task.  We require our suppliers to keep your information secure and not use it for their own marketing to you.  We do not share, sell or rent your information to other organisations for their own marketing purposes.

Electronic marketing

We ask for your permission to send you electronic marketing material via a separate consent form.  You can withdraw your consent at any time by contacting us.

Bombarding people with spam is a great way to upset them; so, we don’t.  However, the definition of electronic marketing is broad, so we ask for your permission first.  We may contact you to arrange a review (if we provide ongoing services), if we think you need to act (for example, after a tax change) or if we want to update you on economic, legal, regulatory or business changes that affect you.

Sensitive information

Sometimes we may collect sensitive information about you to provide our services.  We ask for your permission before collecting this information.

Sensitive information (called special category data) includes information about your health or lifestyle.  To advise you on insurance or your retirement we need to collect and use this sensitive information.  We ask your permission to do this, but if you decline we may not be able to advise you.

Transferring your information outside Europe

The data protection regulations we comply with apply across the European Economic Area (EEA).  Sometimes we may transfer your information outside the EEA.

If we need to share your information outside the EEA, we will comply with European data protection regulation.  You can ask us for more information about this.

Our employees may access our systems remotely when working abroad, which may be outside the EEA.  When they do so, they must follow our data protection procedures which comply with EEA data protection regulations.

How long we keep your information

Depending on the service provided we may have to keep your information indefinitely.

We may hold your information for longer than you might expect because of a legitimate interest or legal obligation.  The periods for which we may keep your information depend on the type of service provided:

Service provided How long we keep your information
·       Financial advice was given or a regulated product recommended. Indefinitely
·       Tax advice or tax compliance services only were provided. Seven years, unless we are notified by HMRC that a period is considered “open” in which case it will be until we are notified the period is “closed”.
·       An enquiry about our services, but no further information was gathered. One year from last contact.
·       An enquiry about our services where further information was gathered but no advice was provided. Three years from last contact.

Keeping your information secure and accurate

Email and the post are not secure, so we ask you to send your information and instructions to us via our client portal wherever possible.

We normally update your information during a regular review.  If you stop using our services, your information will not be kept up to date.

We make our best efforts to ensure the security of your information on our systems.

Where you have a password for accessing our client portal, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.

Where we provide an ongoing service, we will update your information as appropriate during a regular review.  If between reviews you change your contact details please let us know. Where we provide a one-off service the information we keep about you will reflect your situation at that time and we will not normally update this.

Your rights

You have the right to:

  • Request access to your information.
  • Correct inaccurate information.
  • Request the erasure of your information.
  • Restrict how we use your information.
  • Object to how we use your information.
  • Request we transfer your information to another organisation.
  • Object to automated decisions.
  • Request more information about how we use your information.

To ensure we are dealing with the right person, we may ask you for proof of identity if you ask to exercise any of these rights.

We will not ask for a fee unless we think your request is unfounded, repetitive or excessive.  Where a fee is necessary, we will tell you before answering your request.

We aim to reply to valid requests within one month.  It may take us longer if the request is complicated or you have made several requests.  We will let you know if we think it will take us longer than one month.  To help us we may ask you for more detail about your request.

We may not be able to address your request in full.  For example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request differently.

  • Access: You can ask for a copy of your information that we hold.
  • Correct: You can ask that we correct (or rectify) any information about you that is incorrect. We will be happy to do so, but will need to check the accuracy of the information first.
  • Erase: You can ask that we erase (or delete) your information if you think we no longer need it for the purpose we collected it. We may not be able to comply with your request. For example, where we need to keep your information to comply with our legal obligations or establish, exercise or defend legal claims.
  • Restrict: You can ask us to stop processing your information. This means that we will keep it but no longer actively use it (in other words we will archive it).  We may not be able to comply with your request.  For example, where we need to use your information to comply with our legal obligations or establish, exercise or defend legal claims.
  • Object: You can object to our use of your information if you think your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If we can demonstrate we have compelling legitimate interests to use the information we may continue to do so.
  • Transfer: You can ask us to transfer your information to you or another organisation in an appropriate electronic format.
  • Object to automated decisions: If we make a decision about you based solely by automated means (that is, with no human input), and our decision produces a legal effect concerning you or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision-making processes to protect your rights and freedoms.
  • More information: You can contact us to ask us for more information about your information that we hold, what we use your information for, who we give your information to, whether we transfer it abroad, how we protect it, how long we keep it, what rights you have, how you can make a complaint, where we get your information from and whether we have carried out any automated decisions using your information.

If you are not happy

If you are not happy about how we use your information please contact us first.  You can also complain to the Information Commissioners Office either online at or by calling 0303 123 1113.

Contacting us

  • 0345 345 6282
  • Privacy Manager, Page Russell Ltd, 14 Forbes Business Centre, Kempson Way, Bury St Edmunds, IP32 7AR