last updated 26 Feb 2020
DATA PROTECTION AND DISCLOSURE OF INFORMATION
As part of our day to day business we may collect personal data from our clients and potential clients to ensure that we can meet their needs and provide them with information about our services.
Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This notice outlines how we manage your personal data and details your rights in respect of our processing of your personal data.
Who are we?
This Privacy Notice applies to the processing activities The Morning Porridge. The Morning Porridge is the data controller for the processing of your personal data. Any reference to ‘us’, ‘our’, ‘we’ in this Privacy Notice is a reference Morning Porridge. Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this Privacy Notice is a reference to any of our clients and potential clients.
Our Privacy Notice will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
What kind of personal data do we collect?
We collect information necessary to fulfil our obligations to our clients in the course of providing a range of financial services. We may collect the following types of information about you: Name, address and contact details, date of birth and gender, education and qualifications, employment details including employment history, family details, lifestyle and social circumstance, location data, any other similar information. We will only obtain and process this information with your express consent. If you chose not to provide the information required, we may not be able to provide you with the requested product or service.
If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained their consent.
How is the personal data obtained?
We obtain this information in a number of ways, for example through your use of our services or other dealings with us including through the subscription opening process, and from information provided in the course of ongoing customer service correspondence. We may also collect personal data about you from third parties through publicly available sources.
Additionally, we may obtain personal data about you through your use of our websites, apps, or using cookies on our websites, in particular by recording your activity and which pages you look at on our website.
We may record any communications with you including electronic, by telephone, in person or otherwise, which will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further notice. Further, if you visit any of our offices or premises, we may have CCTV which may record your image.
What Lawful Basis do we rely on?
We may be required to collect and use certain types of personal information to comply with the requirements of the law and/or regulations, however we are committed to processing all personal information in accordance with the General Data Protection Regulation (“GDPR”), UK data protection laws and any other relevant data protection laws and codes of conduct (herein collectively referred to as “the data protection laws”).
Where our use of your personal data requires consent, such consent will be provided explicitly by you. If we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this Privacy Notice.
What we do with the personal data we obtain?
We may use information held about you in the following ways:
- to notify you about changes to our services;
- to provide you with information by post, email, telephone or otherwise about products and services. You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by contacting us by phone, post or email using the details n the ‘Contact us’ section below. You can unsubscribe from emails by following the unsubscribe instructions on the website.
- to administer our sites and for internal operations, including troubleshooting, data analysis, load management, testing, research, statistical and survey purposes;
- to improve our sites to ensure that content is presented in the most effective manner for you and for your computer;
- to measure or understand the effectiveness of content we serve to you and others, and to deliver relevant content to you;
Disclosure of your personal data
Your personal data may also be used by the The Morning Porridge for customer modelling, statistical and trend analysis, with the aim of developing and improving our products and services. We will never sell, trade, or rent your personal data to others, however, we may share your information with selected third parties including:
- our service providers, suppliers and sub-contractors for the performance of any contract we have entered into with them. They may then process this data on our behalf to help run some of our internal business operations for example IT services.
- governmentalor judicial bodies or agencies to comply with our legal and regulatory obligations;
Where we share your data with third parties we ensure that your data is held securely and in line with GDPR requirements.
Do we make automated decisions concerning you?
We do not carry out automated profiling on you.
How we store personal data
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or any other electronic medium. We hold personal data in a combination of secure computer storage facilities and paper-based files and other records, and take steps to protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure.
When we consider that personal data is no longer needed, we will remove any details that will identify you or we will securely destroy the records. However, we may need to maintain records for a significant period of time in line with any regulatory obligations.
If we hold any personal data in the form of a recorded communication, by telephone, electronic, in person or otherwise in relation to our regulatory obligations as detailed above, this information will be held in line with local regulatory requirements which will generally be 5 years after our business relationship with you has ended.
Where you have opted out of receiving marketing communications we will hold your details on our suppression list so that we know you do not want to receive these communications.
Management and Safeguarding of personal data
We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle personal data to respect the confidentiality of customer information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary.
The internet is an open medium and we cannot guarantee that any information you send to us by email or via our sites will not be intercepted or tampered with; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights as a data subject
The data protection laws give you certain rights in relation to the data we hold on you. These are:
- the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this Privacy Notice
- the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- the right to portability. You may transfer the data that we hold on you for your own purposes
- the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to store and use the data where so permitted by having a legitimate reason for doing so or where required by law, regulation or by any other competent authorities.
You can read more about these rights
Links to external websites
Our sites may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and external media. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or how such websites collect and use your data. Please check these policies before you submit any personal data to these websites.
Access to personal data about you
You have the right to request a copy of the personal data we hold about you. If you would like a copy of some or all of this information you may contact us by email. If any of the information we hold is inaccurate, you can ask us to make any necessary amendments.
Updates to the Privacy Notice
We reserve the right to update this Notice to reflect any legal changes or changes to the way in which we process your personal data. The updated Notice will be published on our website and comes into effect at the time of publication on the website.
If you have any queries regarding privacy issues or the content of this Privacy Notice, you can email us on email@example.com.
What if you have a complaint?
If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via one of the methods set above. If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.