Adviser Home – Data Management
This document describes the Adviser Home policy on data with specific reference to the General Data Protection Regulations (GDPR) - in force from May 25th 2018.
Nature of data held
For financial advisers we hold basic personal data - name and email address, business name, address, post code, role and FCA reference number.
Purpose of data
The sole purpose is to allow us to communicate with advisers to help them run, develop or market their business.
Legitimate Interest and Consent
The purpose of Adviser Home is to communicate with financial advisers on subjects relevant to their practice. This might include content related to their client dealings: - product information, technical updates, investment or market news or views. It may also include information related to the advisers own practice and business – ideas for attracting new clients or new ways to organize IT for example. Since 2011 we have been working with advisers this way and consider that this demonstrates a legitimate interest between Adviser Home and its financial adviser community.
Unless we have asked and been granted consent for a particular instance the adviser data we hold is not shared with any third party, other than the organisation we use to issue e communication (Mail Chimp).
We do provide aggregated information to third parties – specifically providers to the adviser market. For example we may advise providers that a defined number of advisers downloaded a document or visited a section of our website. Or we may advise providers that a number of advisers completed a research exercise. Individual data is however, not disclosed.
There are a limited number of defined circumstances where we would seek advisers consent to share their data with third parties – specifically organisations with an interest in marketing products or services to advisers. These circumstances are:-
· Where an adviser registers for a provider event – face to face or webinar – the provider will be passed the registration details
· Where an adviser registers to receive a particular document – a guide for example
· Where an adviser has engaged with a CPD assessment and has consented that a provider be in touch subsequently
In both of the above circumstances we would seek adviser consent for the relevant provider to receive adviser data – which would be likely to comprise name, company name, and e mail and possibly telephone contact.
Validating legitimate interest
We assess the reaction to our e comms each week and adjust our content and focus continuously. This helps us to be confident that our adviser community is interested in our communications.
In addition from time to time we ask advisers what information they would like from us, and again adjust the balance and emphasis accordingly. Note that this research aggregates information from advisers. We do not report on the views or information given by an individual adviser.
Where we seek consent to share data with providers we do so via a consent form which describes the consent expressed by the adviser.
Adviser’s right to unsubscribe
We offer the right to unsubscribe at any time. Our process is simple and quick. If an adviser clicks to unsubscribe then no further dialogue is involved. The adviser will simply receive an email from us confirming that they will no longer receive communications from us.
The directors of Adviser Home may from time to time have interests or controlling interests in otherorganisations. Data used in connection with Adviser Home will not be used with these other organisations.
If you have any questions relating to our data practices, please get in touch with us at [email protected]