DATA PRIVACY STATEMENT – USING YOUR PERSONAL INFORMATION 

Personal information which you supply to us is important to us, and we take your privacy very seriously. Your personal information may be used, both manually and electronically, in a number of ways. 

The lawful basis upon which we collect and use your personal data will be to allow us to provide financial and/or mortgage advice and to intermediate with providers, thereby assisting in the performance of a contract. We will also seek your consent to obtain and process your personal information as special category personal data may be collected (see (ii) below). This will allow us, for example: 

• To assist us in providing you with investment and insurance advice 
• For investment or insurance product processing and administration 
• For fraud prevention 

We may also have a legitimate interest in processing and holding data other than detailed above, for example when retaining your personal data even if we have been asked to erase that data (see ‘Your Rights’ below). 

We will endeavour to take all due care to protect this information. We highlight below matters relating to your information that you should be aware of: 

(i) The information we ask you to provide to us includes your name, email address, phone number, date of birth, gender, identity information (such as passport details, driving licence and utility bills), financial information including income and expenditure, credit card and other debt information, details of any assets such as property and investments, information about your investment strategies and objectives, details of any existing insurance products, and employment status and any further personal information required as part of a product or service application. 

(ii) The information we collect may also include ‘special categories of data’ as defined by the data protection legislation, which is considered to be more sensitive and so is subject to additional levels of protection under the data protection legislation. This includes data relating to your physical or mental health, data regarding any vulnerability, racial or ethnic origin, sexual orientation and lifestyle. Data relating to criminal convictions or offences is also subject to additional levels of protection. 

(iii) The information we collect may also include details of dependents and beneficiaries (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with the information being provided to us. You might find it helpful to show them this Data Privacy Statement and if they have any concerns then please contact us). Helix Structured Finance registered address 5-9 Eden Street, Kingston Upon Thames, Surrey KT1 1BQ. Company registered in England and Wales No. 13437022. 

(iv) We may share your information with, and obtain information from, investment product and platform providers, insurers, lenders, credit reference agencies, accountants and solicitors, solely for the purposes of providing you with investment or insurance advice. Where we obtain this information from a third party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing that information with us. 

(v) We will not disclose any information to any company not associated with Helix Structured Finance Limited except to prevent fraud, or other parties such as our auditors, lawyers or compliance consultants and any other organisation requiring access under the regulations or exercising their legal entitlement to such access or in accordance with requirements to disclose, or if required to do so by our regulator, the Financial Conduct Authority. 

(vi) You may be assured that we and any company associated with us will treat all personal data as confidential and will not process it other than for legitimate purposes. We will take steps to ensure that the information is accurate, kept up to date and not kept longer than is necessary. Measures will also be taken to safeguard against unauthorised or unlawful processing and accidental loss or destruction or damage to your data. 

(vii) We will not transfer your personal data outside of the European Economic Area. However, product providers and lenders may administer your policy, any existing policies you may have with them and provide other services, from centres in countries outside Europe (such as India and the USA) that do not always have the same standard of Data Protection laws as the UK. However, they are required to put a contract in place to ensure that your information is adequately protected, and they will remain bound by their obligations under the Data Protection legislation even when your personal information is processed outside Europe. 

(viii) We may make checks with credit rating agencies to authenticate and verify your identity and credit status. We also make checks with Institutions with whom you have policies of insurance and investments and with your mortgage provider. These checks are to help us with our obligations at law and generally to ensure that we provide you with advice that suits your circumstances. The scope and extent of the gathering of information from third parties depends on what type of service you are taking from us. 

How is your information used? 

Primarily, we use your data and data about your family’s circumstances to provide advice to you and complete transactions on your behalf. We analyse and assess your data to maintain and develop our relationships 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 local 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, of course, pass your data to Institutions if you agree to purchase or amend policies and products as part of the sales and advice process. Helix Structured Finance registered address 5-9 Eden Street, Kingston Upon Thames, Surrey KT1 1BQ. Company registered in England and Wales No. 13437022. 

We only retain your data for so long as it is necessary to fulfil the purpose for which it was collected. There are regulatory and legislative requirements which oblige us to keep certain data for longer, and in order to comply with those regulatory requirements we keep that data for seven years. In very limited circumstances, we may be required to keep some specific information for longer, but we regularly review our retention obligations to ensure we don’t keep personal information longer than we’re legally obliged to. If you want details of the statutory retention periods for various product types please contact us and we will obtain the latest legal position on your behalf. 

Your data is held in our offices in computer-based back-office filing systems. 

Your Rights 

You have legal rights under the Data Protection Regulations in relation to your personal data. These are set out below. 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, or where the request is complex or you ask for multiple copies of the same information. 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 be happy to rectify such information but would need to verify the accuracy of the information first. 

You can ask that we erase your personal data (also known as the “right to be forgotten”) 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, 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. Helix Structured Finance registered address 5-9 Eden Street, Kingston Upon Thames, Surrey KT1 1BQ. Company registered in England and Wales No. 13437022. 

Unless we have legitimate grounds to refuse to erase your personal data, 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, all requests for erasure shall be complied with. 

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 use of personal data 

You can object to any use of your personal data which we have justified on the basis of our legitimate interest, 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. 

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, where we got your data from and whether we have carried out any automated decision making using your personal data. 

If you would like to exercise any of the above rights, please contact us: 

In writing: Data Protection Officer, Helix Structured Finance Limited, 6 Bevis Marks, London, EC3A 7BA. 

By phone: 0203 488 4911 

By e-mail: info@helixsf.co.uk 

let us have enough information to identify you, e.g. name, address, date of birth; 

Helix Structured Finance registered address 5-9 Eden Street, Kingston Upon Thames, Surrey KT1 1BQ. Company registered in England and Wales No. 13437022. 

let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and 

let us know the information to which your request relates. 

Our Supervisory Authority 

If you are not happy with the way we have processed your personal data, or in the way we have handled any requests from you with regards to your personal data, then please let us know so we can try to resolve any issues. If you are still not happy then you have the 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). 

Keeping your personal data secure 

We have appropriate security measures in place to prevent personal data from being accidentally lost, or 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. 

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 where we are legally required to do so.