Data Protection for Retirement Advice

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Liverpool Victoria Financial Advice Services Limited is the data controller of your personal information and is part of the LV= group of companies.

For more information visit www.lv.com/retirement-planning/terms/lv-companies.

If you have any questions about how we process your personal information please get in touch with us at: Life Customer Support, LV=, County Gates, Bournemouth, BH1 2NF or email us at: [email protected].

You can also contact our Data Protection Officer: Data Protection Officer, LV= County Gates, Bournemouth, BH1 2NF or via email at [email protected]. 

We can only talk to you or someone we’re satisfied that you’ve authorised to talk to us, on your behalf.

We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:

✔ the length of time we have an on-going relationship with you and provide services to you;
✔ whether there is a legal obligation to which we are subject; and
✔ whether retention is advisable in light of our legal position (such as in regard to complaints, litigation, or regulatory investigations.

If you have a complaint about the way we process your personal data please contact us.

You can also raise your complaint with the Information Commissioner’s Office on 0303 123 1113 or visit ico.org.uk/concerns.

We only ask for information that we need, and have strict controls to keep it safe. We collect personal information to provide our quotes, products and services. Without the information we ask for, we can’t provide you with the products or services you have requested. Personal information we collect will be held in digital and / or paper files. We collect personal information such as name, address and date of birth.

To help us understand your needs and the types of product and service that we can offer you, we collect information about your lifestyle, hobbies and leisure activities along with family history, occupation, earnings, and other incomes and assets.

We collect personal information when you:

✔ ask for a quote or apply for a product
✔ buy and / or use a product or service
✔ ask us a question
✔ get advice about retirement
✔ review your investments
✔ make or receive a payment
✔ update your personal details
✔ register a complaint
✔ take part in market research (for example, customer satisfaction surveys)
✔ update how we contact you with marketing

The personal information we ask for will be used by us and third parties who process information on our behalf. This includes organisations who administer or assist us in administering policies, servicing claims and reinsurers.

Legal ground for processing personal information

We collect personal information to provide our services to you and so we are able to get a quote that best suits your needs.

As a regulated financial services organisation we’re required to comply with legal and regulatory obligations such as the prevention, detection and reporting of fraud and other financial crime.

We’ll process personal information for our legitimate interests, when we have a business reason to do so. For example, to:

✔ develop, improve, and personalise our, pricing and services
✔ enhance our customer service, experience, and relationship (for example, customer and market research, business analysis, provide relevant product and service information)
✔ improve the relevance of our advertising and marketing campaigns
✔ help detect and prevent fraud and financial crime
✔ develop and improve our administration, security systems and insurance applications
✔ help prevent over-indebtedness
✔ share it with third parties in the event of organisational change (for example, if we bought or merged with another organisation)
✔ share personal information with other LV= companies
✔ If we need your consent to process personal information we’ll ask for this first. You can withdraw your consent at any time.

Regulatory bodies

Your personal information will be used or disclosed as required to regulators to monitor and enforce our compliance with any regulation. In order to meet our legal obligations as a Company Limited by Guarantee we are required to share personal information relating to our members with Companies House who will publish a list of our members on its website. A person/organisation may request to inspect or request a copy of all or part of the member register.

Payment card details

We use the payment card or bank details provided to enable money to be paid to us and for us to pay money out. We use a secure payment processor for all card payments. When a payment is processed we receive a unique transaction code and an extract of your card number, which we store as a record of the transaction.

If we intend to make a change to a payment, we’ll always get in touch in advance to tell you if and when we intend to change payments in any way.

Automated decision making and profiling

We use automated decision making to help determine the prices, policy terms, relevant products / services, when you research or ask for a quote, use our services, or make any changes. We may also profile you based on your personal information and that provided by third parties. Profiling may be used to help determine the likelihood of a claim or policy transaction being fraudulent.

Profiling will also be used to enhance our understanding of you and to help us make our business decisions (for example, customer journeys or marketing strategy). If you’ve chosen to receive marketing information from us, profiling will be used to make our marketing more relevant, for example to personalise the channels used to market to you, the marketing messages used and the offers you’re sent.

Please see the ‘Your personal information rights’ section below.

International transfers

In the event that we process personal information outside the UK, the processing in those locations is protected by UK and European data standards.

Where a claim occurs abroad we will also send data to the necessary service providers and agencies as required to service your claim.

Financial crime & fraud prevention agencies

The personal information we have collected will be shared with crime prevention agencies who will use it to prevent financial crime and fraud and to verify your identity. If financial crime or fraud is detected, you could be refused certain services, finance or employment. Where we suspect financial crime or fraud, we may cancel any policies you have with us, not be able to pay any claim or offer you the requested product or service. We may share relevant information with crime and fraud prevention agencies, law enforcement agencies and other relevant organisations.

Terrorist Financing

We use your information to make sure we comply with any financial sanctions that apply in the UK and overseas. This includes;

• Checking your information against sanctions lists.

• Sharing your information with HM Treasury and international regulators if required.

LV= will contact you if more information is needed to comply with any financial sanctions.

Credit search and identity check

In order to process the product or service you have applied for, we may supply your personal information to credit reference agencies (CRAs) and they’ll give us information about you, such as about your financial history. We do this to assess creditworthiness, check your identity, manage your account, trace and recover debts and prevent fraud and other financial crime.

We’ll also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your personal information with other organisations. Your data will also be linked to the data of any joint applicants or other financial associates you have.

The identities of the CRAs and the ways in which they use and share personal information are explained in more detail at experian.co.uk/crain, callcredit.co.uk/crain and equifax.co.uk/crain.

Intermediaries or brokers

If we get your details from a financial intermediary or broker, personal information (for example, policy details, claims, payment, suspected fraud and other financial crime information) will be shared with them.

Partner or affinity associations

If you get a quote or buy through one of our partner or affinity associations, we may pass some of your personal information back to them (for example, policy details, claims, membership and suspected fraud and other financial crime information).

Price comparison or other introductory services

If you get a quote on a price comparison website or other introductory service, the information you give them is passed to us so you don’t need to re-enter your details. We’ll also pass your personal information (for example, policy details, and suspected fraud and other financial crime information) back to them.

Public information

We may use public information such as electoral roll, county court judgements and social media.

Specialist services we use

We use other companies to provide some services, for example banks and building societies, legal service providers, communication services, debt recovery agencies, marketing, fraud and other financial crime investigation services , and companies to help us find customers we have lost contact with. We’ll give them the personal information they (or their sub-contractors) need to manage their service.

Market research agencies

We may share your personal information with market research agencies who will conduct market research and business analysis on our behalf.

Other insured parties

An insured party on your policy or product may notify us of an incident or claim against your policy.

Law enforcement and government agencies

Information may be given to us by law enforcement agencies (for example, the police) which may affect a policy or ongoing claim.

You have a right in certain circumstances to:

• Access the personal information we hold about you.
• Correct personal information.
• Have your personal information deleted.
• Restrict us processing your personal information.
• Receive your personal information in a portable format, and
• Object to us processing your personal information.
• You can also ask for a person to review an automated decision.

If you want to find out more or to exercise these rights please contact us: Life Customer Support, LV=, County Gates, Bournemouth, BH1 2NF or email us at: [email protected]

We’ll only send you marketing information about our products and services if you’ve given us permission. You can withdraw your consent at any time.

When you contact us, personal information that you give us will be recorded. This helps us improve our customer service, train our staff, respond to complaints and prevent fraud and other financial crime.

All communications will be in English. You can get this document from us in writing, Braille, large print or an audible format by contacting us.