- Our contact details
- How does Data Protection apply to The Fry Group?
- The type of information we have
- How we get this information
- Why do we have this information
- What we do with the information we have
- Direct Marketing
- How we store your information
- How to contact us
Our contact details
Name: The Fry Group
Name of Data Protection Officer for The Fry Group: Charlotte Thomas
Head Office Address: Crescent House, Crescent Road, Worthing, West Sussex, BN11 1RN, UK.
Head Office Phone Number: +44 (0)1903 231545
All data protection is overseen by our Head Office, situated in Worthing, UK. However, we are governed and abide by local data protection rules in all of our local offices’ jurisdictions.
This Privacy Notice is issued under the ‘right to be informed’, so that we are clear and transparent with all who engage with our company or group of companies regarding our processing of data.
How does Data Protection apply to The Fry Group?
We are proud to be a global presence, and each jurisdiction that we operate in has different requirements for processing your personal data. We are governed by and follow the rules of the following data protection regulations and its regulators:
|UK||General Data Protection Regulations (GDPR) and ‘Privacy and Electronic Communications Regulation (PECR)’||Information Commissioners Office (ICO)|
|Belgium||General Data Protection Regulations (GDPR) ‘Regulation on Privacy and Electronic Communications (ePR)’||Autorité de Protection des Données (APD)|
|Dubai||Data Protection Law DIFC Law No. 5 of 2020||Commissioner of Data Protection (DIFC)|
|Hong Kong||Personal Data (Privacy) Ordinance (PDPO) (Cap. 486) ’ and ‘Personal Data (Privacy) (Amendment) Ordinance’.||Privacy Commissioner for Personal Data (PCPD) Hong Kong|
|Singapore||Personal Data Protection Act 2012 and ‘Personal Data Protection (Amendment) Act 2020’||Personal Data Protection Commission (PDPC) Singapore|
The type of information we have:
We currently collect and process the following information, where necessary:
- Date of Birth
- Residential address
- Email address
- Telephone number
- Details about and information relating to your investments, finances and any other assets that you hold.
- Details about your income, expenditure, and taxes.
- Information about your circumstances and lifestyle.
- Details about your company or business.
- Copies of identity verification documents (such as passports, driving licence, utility bill, etc, including those with photographs).
- Video and/or audio recordings of online video client meetings
- Client satisfaction/review submissions
- Cookies through our website, to track visit use and compile anonymous statistical reports on website activity.
- Information and electronic checks about previous or current criminal convictions.
On occasion we may also need to process ‘special category data’, such as information about your health, race, ethnicity, and/or biometric data. For more information about ‘consent’ please read the section ‘Why do we have this information?’.
Sometimes, we may need to process data about, or on behalf of, a child. In these instances, we ensure that we stick to our high standard for processing data, as well as taking extra precautions. For further information, please refer to our specific policy ‘Privacy Notice for Children’s Data’, which can be provided upon request in either electronic or paper format.
How we get this information:
Most of the personal information we process is provided to us directly by you, for one of the following reasons:
- We require the information to ensure that we can provide you with any contracted services, as agreed to in our Service Charters and/or Terms of Engagement.
- We are required to by law, to meet certain regulations or legal requirements e.g. Anti-Money Laundering, local tax office reporting, etc.
- You wish to attend or have attended one of our seminars or webinars.
- You have given us express consent to record certain information, as is relevant to your required services.
- You use our website and accept the use of additional, non-functional cookies.
- You have completed an optional online review or contact form.
- We have a legitimate interest and business need to record this information, for example, recording your online video meeting with one of our advisers, where we may use the recording for internal training and development of our advisory team.
We also receive personal information indirectly, from the following sources in the following scenarios:
- We may receive data about you from another person if it is relevant. For example, a client may tell us their child’s name and age if they wish for investments to be earmarked for them, or a client might tell us information about their family so that we can recommend a suitable protection product.
- Our Estates team may ask for information about family members, friends, or acquaintances in order to prepare your Will or Power of Attorney documents.
- You may have appointed someone to act on your behalf, or to provide information to us on your behalf e.g. an Attorney or given signed and written authority to a spouse.
- We may receive data from a provider when we take over or become the servicing agent on a product that you have with them.
- We may receive information from government, regulatory bodies or other professional agencies (such as tax offices, etc).
- We have conducted an electronic identity verification and anti-money laundering check, which may provide us with additional information in it’s results.
From time to time, a client may choose to share information about another person (the data subject) with us. If a client chooses to share information about another person (the data subject), it is deemed that they have consent from the data subject to share this information. In these instances, it is the client that is responsible for sharing this information, and it is not The Fry Groups responsibility to ensure that this data is accurate or to obtain consent from the data subject.
Why do we have this information
Under data protection regulation, the lawful bases we rely on for processing this information are always one of the following:
Your consent. Some information (such as ‘special category data’) we can only process with your explicit consent. At The Fry Group, we will always ask for your express consent to do so for any health data. You can withdraw your consent at any time by contacting your executive, or the data protection officer on the contact details given in this document.
We have a contractual obligation. This is so that we can provide you with the services that you have agreed to when engaging with us for business. These terms can be found in our Service Charters or Terms of Engagement.
We have a legal obligation. For example, reporting to regulatory bodies, local authorities, or governments. We may also need to retain your data if we believe that we may need to rely on it to defend ourselves in any future legal disputes or regulatory investigations.
We have a legitimate interest. This is when it is either in our, or your, best interests to do so, and is often on a case-by-case basis. We will only rely on this basis when we believe there is minimal or no impact on you.
What we do with the information we have:
We use the information that you have given us in order to:
- Set up and provide ongoing servicing of investment products with third-party companies or providers on your behalf.
- Write and register/set up a Will, Power of Attorney or Trust on your behalf.
- Complete and submit a tax return for you or your business.
- Fulfil any other services for which you have requested or entered into a contract with us for.
- Provide you with specific updates on your investments, products, or accounts.
- Provide you with general sector and market updates.
- To review and improve the services we provide, based on client feedback.
- Contact you with specific marketing communications based on your interests, feedback, and communication with us.
- Comply with regulatory or legal requirements, such as reporting to local tax or money laundering services.
- Ensure that we are providing you with a suitable service and appropriate advice.
|Reason for Processing||Lawful Basis for Processing||Third Party Recipient Linked to that activity|
|To provide you with intermediary services for financial products.||To fulfil a contractual obligation||Product providers|
|To apply for quotes and products on your behalf.||To fulfil a contractual obligation||Product providers|
|To submit tax returns on your behalf||To fulfil a contractual obligation||Government or local authorities.|
|To produce and register wills and power of attorney documents on your behalf.||To fulfil a contractual obligation||Government or local authorities.|
|To establish trusts and other legal entities on your behalf.||To fulfil a contractual obligation||Providers and Trust Companies.|
|Setting up company formations.||To fulfil a contractual obligation||Government or local authorities.|
|Booking review and ad-hoc meetings via online booking systems.||To fulfil a contractual obligation||Calendly, Teams, Zoom and Skype.|
|Recording an online client meeting with your adviser, to assess the competency of the adviser and provide them with suitable training.||In our legitimate interest||Online meeting/video providers (e.g., Teams, Zoom and Skype, etc.)|
|To establish client satisfaction levels and understand areas for service improvement and to identify individuals for direct marketing purposes.||In our legitimate interest||Working Feedback (review platform)|
|To send marketing communication to you.||Consent||None.|
We may be required to share your information with third parties, such as (but not limited to) other legal entities within The Fry Group family of companies, different providers of financial and investment products, local tax offices and agencies as well as governments and regulatory bodies (for legal reporting) and will only ever do so to either fulfil a contractual obligation or to meet a legal requirement. We have contracts in place with our data processors and this means that they cannot do anything with your personal information unless we have instructed them to do it. They will hold it securely and retain it for the period we instruct. They will not share your personal information with any organisation that does not have a legitimate need to process your data.
We will only ever send you direct marketing emails if we have consent from you to do so, or we are permitted to under ‘soft opt-in’ rules.
We will never sell your data to third parties or for marketing purposes.
From time to time, we may use personal data that you have provided to us to ensure that the marketing you receive is relevant or of interest to you, and to build a suitable profile of you (for marketing reasons). For example, we may use your comments from Working Feedback to consider if you should receive relevant and specific communications about certain events, offers or webinars that are likely to be of interest to you.
You have the right to object to your data being processed in order for us to build an individual direct marketing profile about you, and this does not affect your right to services or other communications. If you wish to object to your data being used in this way, please contact us.
How we store your information
Your information is securely stored electronically on our servers that are located in the UK. Our back-up servers are also located in the UK. We do not back up to any cloud storages.
In the UK we store paper files securely in our offices, and also in a secured warehouse where they are reviewed regularly to see if we are required to retain them, or if they can be safely and securely destroyed. For all other offices, our paper files are stored securely in our offices.
We are also subject to regulatory requirements to retain your data for specified minimum periods. These are, for example:
- Three years for mortgage business and insurance business.
- Five years for investment business and self-assessment tax returns.
- Forty years for any records in Belgium
- Indefinitely for pension transfers and opt-outs
These are minimum periods, during which we have a legal obligation to retain your records.
We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us or assist with a regulatory enquiry. With the exception of any estate planning services, advice or investments, we won’t retain your personal data for longer than past the time of your death.
We will then dispose of your data by deleting it from our systems (if electronic) or safely disposing of paper files by sending the documents to a third-party secure shredding company who will then confirm disposal.
As we are a group of companies, it may be necessary under the above-mentioned lawful bases for any member of one of the Fry Group of companies to access and/or process your data. Your data will remain protected under the specific company to which you gave this information, but to fulfil our contractual and legal obligations, this data may (from time to time) be accessed by any employee of The Fry Group. All employees are held to the same high standard of data protection, so you can be assured that your data will be treated with the same care and precision no matter where in the world you are.
Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. However, if the request is excessive or will require a substantial amount of work, we are allowed to request a small fee to cover this. If you make a request, we have one month to respond to you. Please note that under certain lawful bases, not all rights will apply. However, we will gladly discuss this with you, and explain any reasons why we may not be able to meet your expectations at this time. Please contact us at firstname.lastname@example.org if you wish to make a request.
How to contact us
We have a specified Data Protection Officer of The Fry Group, Charlotte Thomas. If you have any specific concerns about your data or this Privacy Notice, please contact them directly via:
Telephone: +44 (0)1903 231545
Or you can write to them at any of our office addresses.
How to complain
If you are unhappy with how we have used your data, please do contact us first to see if we can resolve the issue. However, you always have the right to complain directly to your local data protection authority, and to contact them for any further information on the regulations in the countries that we operate in. If you wish to do this, please contact the applicable authority, as listed below.
If you are a client of any of our UK offices, you can contact the ICO:
Address: Information Commissioner’s Office,
Telephone number: +44 (0)303 123 1113
If you are a client of our Belgium office, you can contact the Autorité de Protection des données:
Address: Autorité de Protection des données
Rue de la Presse 35
Telephone: +32 (0) 2 274 48 00
If you are a client of our Dubai office, you can also contact the DIFC:
Address: DIFC Commissioner of Data Protection
PO Box 74777
Telephone: +971 (0)4 362 2222
If you are a client of our Hong Kong office, you can contact the Privacy Commissioner for Personal Data, Hong Kong:
Address: Privacy Commissioner for Personal Data
Room 1303, 13/F, Sunlight Tower
248 Queen’s Road East
Telephone: +852 2827 2827
If you are a client of our Singapore office, you can contact the Personal Data Protection Commission:
Address: Personal Data Protection Commission
10 Pasir Panjang Road
#03-01 Mapletree Business City
Telephone: +65 6377 3131
Section 172(1) Statement
The directors of the group have acted in accordance with their duties codified in law, which include their duty to act in the way in which they consider, in good faith, would be likely to promote the success of the Group for the benefit of its members as a whole, having regard to the stakeholders and matters set out in section 172(1) of the Companies Act 2006.
The regulatory requirements the Group has to meet provide a framework to demonstrate how the board makes decisions for the long term success of the Group including having regard to how the board makes sure the business complies with the requirements of section 172 of the Companies Act 2006. The business depends upon long terms relationships with clients and suppliers. Decision making and forward planning of the directors takes into consideration the following long-terms factors:
- Anticipating client needs
- Anticipating changes to laws and regulation
- Investing in IT and security infrastructure
- Retaining key staff
- Incorporating sustainability as a core value
DFM Regulatory Disclosure
This statement is directed at clients that use a discretionary fund management service to manage all or part of their investment portfolios. As you will be aware financial markets have taken a downturn in the midst of the Covid19 pandemic and some of you will have received letters informing you of the general losses incurred to date.
In light of this, The Fry Group would like to make it clear that our message in relation to any as yet unrealised losses is to remain calm and focus on the long-term nature of the investment in relation to your stated personal goals. Our aim is to ensure that losses are not consolidated and that you can enjoy the results of the eventual recovery.
If you would like to view the current value of your portfolio please go to The Fry Group Wealth Platform client portal – access to which can be found on this website under “Client Portal”. If you currently don’t have an account set up in the client portal please contact your financial planner who will be happy to assist.
Additionally if you would like to read more about market conditions and issues in the current climate please go to the News section of this website.
Of course if you have any concerns about market falls or the value of your portfolio please contact your financial planner. We are here to support you so please feel free to get in touch.