General
The controller is Jessica Cook Wealth.
If you are a data subject whose data is controlled and/or processed by Jessica Cook Wealth, you can contact Jessica Cook Wealth via the contact details published on www.jessicacookwealth.com.
The purpose of the controlling and processing in relation to clients is to enable Jessica Cook Wealth to perform and improve its business of advising on financial services for clients. This includes carrying out due diligence on clients for anti-money laundering, anti-terrorist financing and anti-fraud purposes; auditing and assessing risk in our services; complying with statutory and regulatory obligations; and marketing services to those who may wish to receive them (and in relation to potential clients, to consider whether to take them on).
Where a data subject is a Jessica Cook client, UK statutory obligations require that records are generally retained for five years and indefinitely in respect of clients who perform defined benefit pension scheme transfers. Jessica Cook Wealth also retains client data for legitimate interest purposes for up to fifteen years after the last date on which business is performed for a client or there has been a communication exchange, in order to resolve disputes or demonstrate that clients have been treated fairly.
Where a data subject is an employee benefits client, Jessica Cook Wealth retains client data for legitimate interest purposes to provide services:
• for eighteen months following the lapse of an annual policy to provide annual data to insurance providers
• for three years from the conclusion of a medical claim to assist in medical claims
We may also use data for direct marketing purposes. If we market to you and you are not already a client, our further legitimate interest is to provide you with information as a potential client for a reasonable period. We regard one year as a reasonable period after your last interaction with us as a data subject who is not a client. After this period, we will delete your data unless we have other legitimate interests to retain it (such as you becoming a client). See below regarding your option to opt out of direct marketing.
Jessica Cook Wealth does not intentionally process special categories of personal data (for example genetic data) unless such information is necessary for the provision of services (for example, a general overview of a data subject’s health may be relevant in a medical claim). Jessica Cook Wealth does not use systems to make automated decisions based on client data.
Provision of personal data by a client is necessary for the purpose of contracting services. If such data is not provided, Jessica Cook Wealth may not be able to provide services.
Sharing Personal Data With Others
Jessica Cook Wealth may share clients’ personal data with auditors and professional advisers, and those who provide professional services in support of client work, such as those providing client money handling services, email storage services, cloud storage and processing systems, and similar support services.
Client data may also be shared with regulators where required by relevant regulations and law, and/or administrative requirements. This may include HMRC, the Financial Conduct Authority (FCA), the Financial Ombudsman Service, and other relevant regulatory authorities.
Transfers of Data Outside the UK or EU
Where personal data is transferred outside the UK or European Economic Area, Jessica Cook Wealth ensures appropriate safeguards are in place in accordance with applicable data protection laws. This may include the use of standard contractual clauses or reliance on adequacy regulations where applicable. Further information about such safeguards is available on request.
Consent and Data Subject Rights
Where Jessica Cook Wealth has obtained a data subject’s consent to processing and other lawful bases do not apply, consent may be withdrawn at any time. Withdrawal of consent will not be retroactive.
Data subjects have the right to access their personal data, request rectification, request erasure, request restriction of processing, request data portability, and object to processing (subject to Jessica Cook Wealth being able to comply with legal obligations and legitimate interests such as resolving disputes).
Data subjects may lodge a complaint with the Information Commissioner’s Office (ICO).
Direct Marketing – Option to Opt Out
All those in receipt of direct marketing material from Jessica Cook Wealth may opt out at any time by contacting Jessica Cook Wealth via the contact details published on the website. If this occurs, processing for direct marketing purposes will cease.
This notice may be updated from time to time.
