We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.
Who we are
Goldsmith Invest is a trading style of Goldsmith Financial Solutions, who are Independent Financial Advisers (IFAs) who collect, use and are responsible, for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “we“, “us” or “our” we are referring to Goldsmith Invest.
Our registered office is at Harwell Innovation Centre, 173 Curie Avenue, Harwell, Oxon, OX11 0QG. Goldsmith Financial Solutions is authorised and regulated by the Financial Conduct Authority (FCA). Goldsmith Financial Solutions’ Financial Services Register number is 506317.
We provide regulated investment and life assurance business, advisory services and wealth management solutions, which are most appropriate to you.
How we collect information from you
We will collect information about you if:
- You have completed a ‘contact us’ form either via our website or social media pages (e.g. Facebook, LinkedIn & Twitter)
- You have contacted, or met with, a representative of Goldsmith Invest
The type of personal data we collect and use
In the course of providing our service to you we collect some or all of the following personal data from you:
- contact information
- identity information
- financial information
- employment status
- lifestyle information
- health information
- details of any vulnerability
- product details
- details of your dependents and/or beneficiaries under a policy
If you are providing information about another person we expect you to ensure that they know you are doing so, and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us in one of the ways described below.
Information collected from other sources
We will only obtain personal data from other sources with your authority.
How we use your personal data
The table below sets out how we use your data and the lawful bases upon which we collect and use your personal data:
| Rationale/Reason for Processing | Lawful Basis for Processing |
| To provide you with intermediary services | Performance of a contract |
| To provide quotations for investment and protection products on your behalf. | Performance of a contract. |
| To apply for products on your behalf. | |
| To retain records of any services or advice provided to you by us in order to defend potential legal claims or complaints. | Legitimate interests |
Primarily, we use your data and data about your family’s circumstances to provide financial advice to you and complete transactions on your behalf. We analyse and assess your data to maintain and develop our relationship with you.
Depending on the instructions we receive from you, we may pass your data to other professional advisers to enable us to provide advice most suited to your circumstances. Usually, this would be referrals to accountants, solicitors, tax advisers and sometimes to specialist advisers in the financial and insurance industry where you may benefit from the expertise of such third parties. We, and any third party specialist advisers to whom we introduce you, will pass your data to organisations when you agree to purchase or amend policies and products.
Any personal data obtained for the purpose of meeting with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 will only be processed for the purposes of preventing money laundering or terrorist financing, unless the use of the data is permitted by or under another enactment other than those Regulations, or otherwise where consent has been obtained from you.
We may be required to share your data with our regulator and other third parties including our auditors or insurers.
We will share your information with relevant and carefully vetted third parties in order to provide you with intermediary services. If you would like further information regarding these third parties please let us know.
Special category data
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process health and / or lifestyle information when providing you with our services in relation to a protection insurance product.
In addition to the lawful basis for processing, we will be processing it either (i) for the purpose of advising on, arranging or administering an insurance contract or (ii) for the establishment, exercise or defence of legal claims.
Marketing
We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will only do so where we have obtained your consent and then have a legitimate business reason to do this and will do so in accordance with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.
You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences please unsubscribe from our website or contact us directly:
By phone: 01235 375595
By email: gaynor@goldsmithfs.co.uk
By Post: Harwell Innovation Centre, 173 Curie Avenue, Harwell, Oxon, OX11 0QG.
Why information has to be provided by you
We will tell you if providing additional personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with advice or intermediary services.
How long your personal data will be kept
We will keep your personal data only for so long as is necessary and for the purpose for which it was originally collected. In particular, for so long as there is any possibility that either you or we may wish to bring a legal claim, or where we are required to keep your personal data due to legal or regulatory reasons. Our policy is to hold client data, until the data subject is deceased. This data will be archived as necessary and held securely.
Transfer of your information out of the European Economic Area (EEA)
Generally we will not transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.
In certain circumstances we may transfer your personal data to an area located outside the EEA. In doing so, we will ensure those organisations have appropriate organisational and technical measures to protect your personal information. We will only transfer data outside of the EEA with an appropriate legal basis, and based on your consent to do so.
Your rights
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:
- To access personal data
- To rectify / erase personal data
- To restrict how we use your personal data
- To object to how we use your personal data
- To request a transfer of personal data
- To understand how we protect information transferred outside Europe
- To find out more about how we use personal data
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.
We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
To access personal data
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.
To rectify / erase personal data
You can ask that we rectify any information about you which is incorrect. We will rectify such information but would need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
To restrict our use of personal data
You can ask that we restrict our use of your personal data in certain circumstances, for example
- where you think the information is inaccurate and we need to verify it;
- where our use of your personal data is not lawful but you do not want us to erase it;
- where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
- where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.
We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
To object to how we use personal data
You can object to any use of your personal data which we have justified on the basis of our legitimate interest or prior consent, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
To request a transfer of personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).
You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
To transfer your information out of the EEA
You have a right to ask us for more information about the safeguards we have put in place. You can ask for a copy of, or reference to, the safeguards we have put in place when your personal data is transferred outside of the EEA. We are not required to share details of these safeguards where sharing such details would affect our commercial position, or create a security risk.
You can contact us for more information
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint and where we got your data from.
If you would like to exercise any of the above rights please contact our Data Protection Controller Hannah Goldsmith:
By phone: 01235 375595
By email: info@goldsmithfs.co.uk
By Post: Harwell Innovation Centre, 173 Curie Avenue, Harwell, Oxon, OX11 0QG.
In order to process your query or right, we will require you to give us:
- enough information to identify you, e.g. name, address, date of birth
- proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- the information to which your request relates.
Keeping your personal data secure
We take personal data seriously and as such have appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
Breach Notification
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach without delay and where we are legally required to do so.
Our supervisory authority
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us, before the ICO.
How to contact us
Please contact our Data Protection Controller, Hannah Goldsmith, if you have any questions about this privacy notice or the information we hold about you.
By phone: 01235 375595
By email: info@goldsmithfs.co.uk
By Post: Harwell Innovation Centre, 173 Curie Avenue, Harwell, Oxon, OX11 0QG.
Glossary of Terms
| GFS, we, us or our | Hannah Goldsmith trading as ‘Goldsmith Invest’ a trading style of Goldsmith Financial Solutions an individual whose business address is at Harwell Innovation Centre, 173 Curie Avenue, Harwell, Oxon, OX11 0QG. |
| contact information | these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode or city of residence. This may also include work contact information such as work telephone number, fax, work email and work address |
| data controller | means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services |
| data protection regulation | applicable data privacy and protection laws |
| employment status | this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance |
| EEA | European Economic Area |
| FCA | the Financial Conduct Authority, being the independent watchdog that regulates financial services |
| financial information | this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60 |
| health information | this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history |
| ICO Identity information | Information Commissioner’s Office(enforcement agency) this is any information that can be used to distinguish a person or verify their identity, such as name, date of birth, place of birth, gender, marital status, national identity card/number, passport, drivers licence and national insurance number |
| intermediary services | these are the services we provide to you in relation to the recommended products. |
| lifestyle information | this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits |
| product | this is an investment, pension, or protection product in respect of which we provide intermediary services to you |
| product provider | a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us – see How to contact us above) |
| sanction check information | this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering |
| vulnerability | a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence) |
