Capital Plans Limited - Pension Management Consultants

Tel.01794 522 821

Privacy Policy

Capital Plans Limited Data Privacy Statement 

This Data Privacy Statement informs customers about why we collect personal data, what personal data we collect and how we use it. Persons conducting business with us consent and agree to these terms. It is important that you read and understand this Privacy Policy so that you are fully aware of how and why we use your data. If you have questions, please contact us.

Name:           Simon Spencer
Address:       Capital Plans Limited 
                     The Old Brewery House
                      Portersbridge Street
                      SO51 8DJ

Telephone:    01794 522 821


If you feel we are not handling or processing your data correctly you have the right to make a complaint at any time to the Information Commissioner’s Office. 

The Information Commissioner’s Office
Wycliffe House
Water Lane
Telephone: 0303 123 1113 

Using your personal data?

We will treat your data with the care and respect it deserves and ensure it is:

  • Used lawfully, fairly and in a transparent way;
  • Collected only for valid purposes that we have clearly explained to you and not used in a way that is
    incompatible with those purposes;
  • Relevant to the purposes we have told you about and limited only to those purposes;
  • Accurate and kept up to date;
  • Kept secure and confidential;
  • Kept only if necessary for the purposes we have told you about. 

The kind of personal data may we hold about you?

Personal data, or personal information, means any information about a living individual from which that person can be identified. We may collect the following types of personal data about you: 

  • name, address(es), telephone number(s), email address(es); 
  • signature, date of birth, gender, nationality, residency, national insurance number or other 
    national identity number such as a passport number, driving licence, tax identification numbers 
    and tax rate, income and financial details, bank or building society account details, policy details, 
    marital status, occupation, benefits and entitlements, employment status, employer and job title;
  • and
  • investment goals, assets, income protection and care needs, lifestyle (for advice services).

Please keep us informed if your personal data changes. We may also collect, store and use the following special or sensitive personal data: information about your physical (height, weight, smoker status, alcohol intake, medication, etc) or mental health, racial or ethnic group or sexual orientation. We may also collect, store and use information concerning criminal proceedings and offences. We must have an additional legal ground to use this type of sensitive personal data and this is explained below. We also collect, store and use personal data, where you have provided this to us, in respect of third parties, such as beneficiaries, spouses, civil partners or dependants. If you do so you are responsible for and confirm you are entitled to provide us with this information and that you have informed those third parties of our identity and the purposes for which their personal data (including sensitive personal data) will be processed. You should draw their attention to this Privacy Statement.

We only use such information except for the purpose for which you have provided it or where we have a legal obligation to do so.

How do we collect your personal data?

You may give us your personal data during a fact-finding meeting face to face, over the telephone or by electronic means. 

  • We may receive information from third parties, such as an accountant, lawyer, tax adviser,
    another financial services provider such as a pension provider or insurance company, health
    professional or your employer;
  • We may receive information from companies we use to verify your identity and/or to prevent fraud
    such as credit reference agencies (please note such companies may record the details of the 
    search) including the electoral register and credit information, in accordance with our legal
  • We may also receive information from third parties who contact us such as Her Majesty’s
    Revenue & Customs (HMRC), the Department for Work and Pensions (DWP) or the police or
    other government agencies;
  • We may obtain personal data from public sources such as Companies House.

Please note telephone calls may be recorded to monitor the quality of customer service, for training purposes or where we are legally required to do so. 

How will we use your personal data? 

The main reasons why we process your personal data and the applicable circumstances are detailed below: 

  • to give you financial planning advice and service i.e. to perform the contract we have          entered with you, such as: 
    provide an investment proposal or financial advice;
    manage your investments;
    provide other related services in respect of which you have contracted with Capital Plans Limited;
    confirm your identity and to communicate with you; and exercise our rights in our agreements;
  • to comply with a legal obligation, for example:where we are required to use your personal data and maintain records of our dealing with you by our regulators such as the Financial Conduct Authority (FCA), Information Commissioner’s Office (ICO) and HMRC;to respond to complaints and data subject requests; and
    to investigate, prevent or detect crime;
  • where it is necessary for our legitimate interests (provided your interests and fundamental rights do not override those interests) for example:
    to establish, exercise or defend our legal rights, where we are faced with any legal claims or
    where we want to pursue legal claims ourselves;
    to prevent, investigate and detect fraud and carry out fraud, credit and anti-money laundering checks;
    to respond to and manage ad hoc enquiries and complaints;
    to provide management information to enable us to monitor our performance and understand our business, to maintain our business records, to manage our financial position and business capability, to receive professional advice, to improve our products and services and for training purposes;
    for accounting, auditing purposes and corporate governance purposes;
    to assist with debt recovery;
    to provide and improve customer support; and
    to manage risk for both ourselves and our customers; 
  • where we have obtained your explicit written consent to do so for example: 
    to process your sensitive personal data or criminal offences information;
    to provide you with marketing services.

On rare occasions we may also use your personal data where we need to protect your interests (or someone else’s interests) or where it is needed in the public interest, for example for the investigation, detection and prevention of crime. 

To administer your contract and comply with our legal and regulatory obligations we will send you reports, valuations and related communications in respect of your engagement with us, which are not marketing communications. 

How will we use sensitive personal data? 

We may on occasion process your sensitive personal data, and any criminal offences information, for example to provide appropriate financial advice and in other limited circumstances: 

  • where we need to carry out our legal obligations as explained in this Privacy Statement; and
  • where it is in the public interest, such as for equal opportunities reporting or the prevention and detection of unlawful activity such as fraud. 

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. 

If we ask for your consent to collect and use this type of information we will explain why it is necessary. 

If you provide this type of information on behalf of a third party, we will ask you to confirm that the third party has provided his or her consent for you to act on their behalf. 

Who may we share your personal data with? 

We may have to share your data with third parties, including third-party service providers (such as contractors with whom we deal as part of the operation of our services). Where we are under a legal duty to do so we may share your personal data with HMRC and other tax authorities, the FCA, the PRA, the Financial or Pensions Ombudsman services, the DWP, the courts, the police and other law enforcement agencies. We will always require those third parties to respect the security of your data and to treat it in accordance with the law and only for the purpose for which we obtained it. These third parties may also be data controllers and have their own privacy policies. We will not sell your details to any third party. We will not use your personal data for marketing purposes without your explicit written consent. We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. 

How long will we hold your information for? 

We will keep your personal data for as long as you are a client of ours. Thereafter we may keep your data for up to 7 years or more to enable us to respond to any questions or complaints and to maintain records where we are required to do so. We may keep your data for longer than 7 years if we cannot delete it for legal, regulatory or technical reasons, for example in relation to a pension contract.

Your personal data and your rights 

You have rights under data protection laws in relation to your personal data for example to: 

  •          Request access to your personal data (commonly known as a “data subject access request”).
  •          Request correction of the personal data that we hold about you.
  •          Request erasure of your personal data.Object to processing of your personal data
  •          Request restriction of processing of your personal data.
  •          Request the transfer of your personal data to you or to a third party.
  •          Withdraw consent

If you wish to exercise any of the rights set out above, please use the contact details above. How your rights apply to a situation will depend upon the full facts and circumstances. 

We will ask you to confirm your request in writing. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within 30 days.  

Capital Plans reserves the right to update this Privacy Statement at any time.

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