Last updated: Dec 2019
At Simplified Money, we take your privacy very seriously. The nature
of our business means we are likely to discuss some really personal issues
with you. And the information which those conversations elicit has to be
looked after very carefully.
This Notice therefore outlines all the details you need to understand how
we manage that in accordance with the Data Privacy Laws. If you have any
questions, however, or anything is not clear, please do not hesitate to ask.
Whilst we hold personal information about you, we will only hold the information that we need to carry out our work for you.
If you are a website user only, ie: you are registered for our newsletter, you download one or other of our eBooks or you undertake one of our courses or challenges, this data will be limited only to your basic contact details, usually your name and email address. We will only use this data to carry out the work related to delivery of that content.
If you are a client, or we are talking to you about becoming a client, the data we hold about you will necessarily cover a wider range of details, including what is termed ‘special category data’. Special category data will include information related to your financial position and, in some cases, also your health. We are extremely careful about the way we manage this more personal information.
When you become a client, all the data you provide to us, along with any associated correspondence and records of conversations and transactions, is shared with you via a dedicated ‘secure wallet’. So you have access to virtually all the information we know about you 24 hours a day.
Please note: whether you are a client or a website user, we will never use your details for any marketing purposes unless you have given your prior consent.
Either way, you can ask for full details of the information we hold – and may be able to request that we delete that information. Be aware, however, that where personal financial advice has been given in the past, our regulatory, legal and contractual obligations to keep records for a minimum number of years, sometimes indefinitely, may supersede that request.
At Simplified Money Ltd, we fully understand our obligations with regard to your fundamental right to a private life. And we have implemented systems and controls to ensure your rights and freedoms are protected.
We undertake to meet all our obligations as set out under the Data Protection Act 1998/2018, the Privacy and Electronic Communications Regulations 2003 and the EU General Data Protection Regulation (GDPR).
Why does Simplified Money need my personal data?
Your personal information is required to enable us, at your request, to take the steps necessary to fulfil our contractual obligations to you.
This may include analysing your assets and liabilities, and any other requirements in accordance with rules set by applicable legislation.
Who will process my personal information?
Your personal information will be processed initially by Simplified Money Ltd. We also use various third party sources to assist our analysis of your information.
What happens if I don’t provide my personal information?
Your personal data is essential to our ability to enter into a contract or perform a contract to which you are a party. Without this information we will not be able to provide you with any financial advice or related service.
Why is your processing of my data considered ‘lawful’?
The reasons our processing of your data is considered lawful is because it falls under the following definitions of lawful processing:
For the performance of a contract to which you are a party (or to take the steps necessary, at your request, prior to entering into a contract);
for the performance of a task carried out in the public interest;
for the purposes of the legitimate interests pursued by us.
How will you keep my personal information up to date?
We will record your information exactly as you provide it. Additionally, you may ask us to update it at any time and we will action your request promptly. Where possible, we will also notify any relevant third parties of those changes.
What about highly sensitive personal data?
We may process sensitive personal data (such as that which concerns your health) only in so far as the basic details are expressly provided by you during a recorded telephone or online consultation. We will not require you to go into details about a specific situation, and we will not store the information anywhere other than in that recording.
Recordings are always made available to you via your secure wallet.
How else might you use my personal data?
Our own legitimate interests for using your personal data may include:
To contact you to ensure that our records of your personal information are correct;
To respond to questions or complaints you have about our services;
To update you with changes to our terms;
For statistical or research analysis relating to the performance of our business and understanding the changing needs of our clients;
To review, improve and develop the services we offer and/or how we handle complaints;
To pursue debts or unpaid fees;
To evidence company practices;
To evidence the standards and processes carried out conform to the company's ethical standards and expectations;
To protect the business from risks which might be introduced by an individual.
You have the right to object to processing for these purposes and we shall cease unless we can show we have compelling legitimate grounds to continue.
What about marketing activity?
We may only use the information provided to us for direct marketing activities if you have provided us with your prior consent to do so.
You can choose the methods via which you are happy for us to contact you (eg: by email, telephone, SMS and/or by post) and you have the right to revoke this consent at any time.
To change your profile settings as they relate to marketing and update activity, simply click the ‘change settings’ link at the bottom of our most recent update email – or email us your request directly via firstname.lastname@example.org.
What cookies will I encounter on your website?
Can you process any of my personal information without my consent?
We will and are obliged to use the information provided to protect members of the public against dishonesty or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced.
What information do you need?
We only collect the information that is necessary to carry out the purposes listed above. This includes information you supply and data we receive from reference agencies. Where practical and lawful, we will inform you about any personal data we receive about you from third parties that you may otherwise be unaware of.
How secure will my personal information be?
We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security and encryption measures have been put in place to prevent unauthorised access, alteration, disclosure, loss, damage or destruction of your information.
If we have a contract with another organisation to provide us with a service or services that require processing of your personal information, we’ll make sure they also have appropriate security measures in place and only process your information in the way and for the specific purpose that we’ve authorised them to.
These organisations won’t be entitled to use your personal information for their own purposes. Our security teams check all such organisation to make sure they meet the security requirements we’ve set on an on-going basis.
Where will my personal information go?
We do not usually transfer any of your personal data outside of the EU.
The exceptions to this might be your name and email address and any feedback you provide to our service-related surveys. We currently use Mailchimp for distribution of our marketing messages and newsletters and Wix for our feedback surveys, both of which may hold data on servers based outside the EU. In both cases, however, those businesses comply with the requirements of the EU-US Privacy Shield Agreement – which means their holding and processing of data is managed to the same high standards as that set by the EU itself.
Are any of your processes automated?
We sometimes use automated processes to help us collect your data and carry out initial assessments of your position as part of our research. However, this is only to help us understand and assist the development of any action plan. We do not make personal recommendations and you would never be subject to a decision based solely on automated processing.
Do you record telephone calls or consultations?
Simplified Money Ltd does record all telephone calls and online consultations for training and monitoring purposes. Copies of the audio files relating to such calls will be made available to you via your ‘secure wallet’ – so you can access them and/or listen again at any time.
Can I access all the personal information you hold about me?
It is your legal right to be able to request a copy of the information we hold about you. And, subject to obtaining confirmation of your identity, we will provide a copy of any non-exempt personal information within one month (unless we ask you for an extension of time).
For our individual clients, however, we make the vast majority of that non-exempt, personal information available to you via your ‘secure wallet’. This gives you 24 hour a day access to copies of all personal correspondence, documents, notes, slides, call records and/or other support materials used in the process of fulfilling our contractual obligations to you.
What is a ‘secure wallet’?
A ‘secure wallet’ is essentially a security protected, shared folder, specifically set up to enable the exchange of confidential and personal information in a secure environment. And to facilitate total transparency during the period of our contract with you.
Please note: It is your responsibility to keep the passwords, file links or codes that are supplied to enable access to those folders confidential. If you suspect someone else has gained access to those details, whether for fair reasons or foul, you must let us know immediately so that those access details can be updated.
How long do you keep my information for?
We keep the information you supply to us as a client of Simplified Money for a maximum of three years following completion of our contract with you. If you return to us for further review, or decide to keep us on a retainer contract for on-going support, that time period will start at the end of our extended dealings.
We will, however, never keep your information for longer than is necessary.
What are my rights?
You have the right, at any time, to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. If you do object, we will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms. Or unless processing is necessary for the establishment, exercise or defence of legal claims.
In addition you have the following rights:
To object to processing of your data for marketing activities;
Where you have previously given consent, to withdraw that consent at any time;
To request from us access to and rectification or erasure of personal data or restriction of processing concerning your data;
To receive the data you provided to us in a structured, commonly used and machine readable format;
To lodge a complaint with the regulator (see below).
To exercise any of these rights, or to ask about any data protection or marketing issues, please contact our data privacy officer:
The Data Privacy Officer
Simplified Money Ltd
No 29, Dedmere Court
Marlow SL7 1PL
Tel: 01628 861830
Making a complaint
If you do not receive a satisfactory response to your enquiry, or you wish to make a complaint about our processing of your personal data directly to the Regulator, contact:
Information Commissioner's Office,
Tel: 0303 123 1113