The Partners of Premier Clients are committed to ensuring that the FCA principle of treating customers fairly (TCF) is applied in all areas of our day to day business activities.
In adopting the TCF principle we recognise that fair treatment of our customers is about adding value to the service we offer by aiming to:
- protect the interests of our customers at each stage of the product life cycle, from promotion right through to after sales service
- meet as best we can the unique needs of each customer by offering a transparent, efficient and professional service, and constantly reviewing our service to identify areas for improvement
In practical terms for the different areas of our business this means:
- ensuring that promotional material is clear, compliant, jargon free and appropriately targeted
- ensuring that sales staff (both on and off-site) have thorough training on all products they advise on or sell, understand who they are and aren’t suitable for, and are encouraged to challenge product providers where they spot inconsistencies, ambiguities or potential unfairness in the product literature or product features
- operating sales remuneration systems which assure fairness to the customer as well as customer satisfaction, rather than only rewarding sales volumes
- finding ways to encourage non sales staff to implement TCF in their day to day business activities
- keeping detailed records of customer instructions and profile/attitude to risk, and of the advice and options given before, during and after a sale – to help ensure we treat customers fairly and can deal with any complaints that may arise swiftly and fairly
- encouraging after sales contact with clients where appropriate to correct or improve on the service already offered
- ensuring that customer complaints are assessed fairly, promptly and impartially, and in line with FCA deadlines and rules
- encouraging staff to recommend improvements to service following customer complaints – and monitoring the outcome
- ensuring that staff are kept up to date with relevant training in relation to competence, data protection and other matters directly affecting the quality of service offered to customers
- offering regular training in the principle of TCF at all levels of the business
- regularly monitoring and reporting on all of the above TCF activities as part of the company’s monthly statistics/MI, in order to assess TCF performance across the business and recommend changes where appropriate
- ensuring that TCF values, which are set and communicated by Senior Management, are supported by all staff and understood in the same way
1. Data Protection
1.1 For the purposes of the Data Protection Act 2018 and the General Data Protection (Regulation (EU) 2016/679) (together, the data protection legislation) Premier Clients is the data controller of your personal information. We are registered with the Information Commissioner's Office (the ICO) under registration number Z9800519.
1.3 Our appointed Data Protection Officer is Simon Rogers, who can be contacted at firstname.lastname@example.org
2.What personal information do we collect and why do we collect it?
2.1 Personal information (or personal data) means any information that can personally identify you, whether directly or indirectly.
2.2 We collect a variety of personal information about you, including:
- Personal demographics such as your title, name, date of birth, residential and employment details
- Financial information, such as bank account details, income and expenditure
- Contact details and records of all correspondence with you, including any call recordings
- Any other information that you provide to us
Please note that we require certain personal information to be able to provide you with our services or products. If you do not provide such information, this may limit our ability to do so. We may ask you to provide information that contains special categories of personal data about you (for example, your health information). In such cases we will obtain your express consent to process the information. If you volunteer information to us that contains special categories of personal data you will be regarded as giving your explicit consent to us processing it. We will always seek to confirm with you that this is the case. We may process personal information relating to criminal convictions or offences as a result of our fraud prevention searches.
2.3 We will collect personal information:
- Directly from you, for example:
- through information provided in completion of our forms, whether submitted electronically or in person
- in correspondence with you, whether in person, by telephone or online
- Indirectly, for example from:
- our agents and intermediaries, or other introducers such as solicitors, accountants or financial advisers
- credit reference agencies (CRAs) or fraud prevention agencies (FPAs) from their records relating to you and other people with whom you are linked financially
- any person that provides your information to us (for example, a member of your household in seeking to obtain a product or service from us)
- publicly available sources, such as Companies House and social media sites
3. Why do we collect your personal information and on what lawful grounds?
3.1 We process your personal information for a number of reasons connected with the provision of financial planning and execution-only stockbroking services. These include:
- understanding your circumstances and verifying your identity before we offer you a service or a product
- administering and managing any account you have with us
- communicating with you, including to send marketing to you by post and email in respect of services and products which we feel will be of interest to you (unless you have opted out of receiving such marketing communications)
- maintaining and improving the website
- reporting to our regulator, the Financial Conduct Authority (FCA), or any other regulatory or enforcement body or government agency
3.2 The lawful basis that we rely upon in order to process your personal information are that the processing is necessary:
- for the performance of any contract we enter into with you or to take steps at your request prior to entering into a contract with you
- in order to comply with our legal obligations
- to fulfil our legitimate interests of:
- ensuring that we provide you with responsible advice and appropriate services and products
- seeking to prevent fraud and money laundering
- providing you with an excellent standard of service, which includes providing you with information about services or products, investment news and opportunities, invitations to seminars & events and publications and newsletters that we feel will be of interest to you
3.3 Where we send marketing communications by email, or we call you by telephone, we will obtain your consent. Where you have provided consent please note that you may withdraw it at any time. This shall not affect the lawfulness of any processing that was based on your consent before you withdrew it.
3.4 If you do not wish to receive marketing communications from us, you may opt out at any time. You can send an email to email@example.com or write to us at the address below. If you opt out of our use of your personal information for marketing purposes, we will honour such choice once we have had reasonable opportunity to process your request.
4. Who will we share your personal information with?
4.1 In providing our services to you as described above, we may disclose your personal information to the following third parties:
- regulatory bodies and enforcement agencies
- government agencies, such as HMRC, and the London Stock Exchange
- CRAs and FPAs
- third parties who we engage to provide services to us
4.2 We will ensure that appropriate data processing agreements are in place where appropriate.
5. Storage and transfer of your personal data
5.1 All information you provide to us is stored on secure servers within the UK. We do not systematically transfer your personal data outside the European Economic Area (EEA).
5.2 If you hold shares/investments overseas we may transfer personal information relating to your shareholding to the location in which they are held. We do so on the basis that the transfer is necessary for the performance of the contract that we have with you or the implementation of pre-contractual measures taken at your request, or that necessary for the conclusion or performance of a contract concluded in your interest.
5.3 Should we transfer your personal information outside the EEA in any other ways we will ensure that there is adequate protection in place in respect of that transfer.
6. Retention of your personal data
7. What are your Data Protection rights?
7.1 You have specific rights in respect of the personal information that we process about you. If you seek to exercise your rights we will explain whether or not the right applies to you. Please be aware that if your request is manifestly unfounded or excessive we may refuse to deal with your request or charge you a reasonable fee for dealing with it.
7.2 Your rights include:
- The right of access to the personal data we hold about you.
- The right to rectify (i.e. correct) your personal data where it is inaccurate or incomplete.
- The right to delete your personal data, but only in specific circumstances, for example where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed. It may not therefore always be possible for us to delete the information we hold about you if you request this, for example, if we have an ongoing contractual relationship with you.
- The right to restrict processing in specific circumstances, for example while we are reviewing the accuracy or completeness of the data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the request.
- The right to data portability which means the right to receive, move, copy or transfer your personal data to another controller. You have the right to this when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.
- The right to object to processing in cases where processing is based upon our legitimate interests or where processing is for direct marketing purposes (including profiling).
7.3 Please write to firstname.lastname@example.org if you would like to exercise any of your data protection rights or if you have any queries in respect of your rights.
9. Links to other websites
10. Contacting us
Office opening times: 8am - 4.30pm, Monday to Friday
Please note that you can complain to our supervisory authority, the ICO by telephoning 0303 123 113 or writing to: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. For further information, the ICO's website can be accessed at www.ico.org.uk