Introduction
Clockswood Wealth Management Limited (“we”, “us”, “our”) recognises and respects your right to privacy and is committed to protecting your personal data. We have implemented systems and procedures to safeguard your rights and freedoms in relation to your personal information.
We will comply with applicable data protection laws (for example, the UK Data Protection Act, GDPR, and relevant electronic communications regulations).
1. What Personal Data Do We Collect?
Depending on the nature of the services we provide, we may collect (but are not limited to) the following categories of personal data:
- Name, address, telephone number(s), email address
- Financial information (e.g. bank statements, assets and liabilities)
- Identification documentation (e.g. passport, driver’s licence)
- Utility / council tax / billing documents as proof of residence
- Health or life/lifestyle information (e.g. for life policies or long‑term care)
- Pension, investment, insurance policy details
- Income information (e.g. payslips, benefits statements)
- Criminal record / background checks (where legally permitted)
- Any other relevant data necessary to provide your requested services
2. How We Collect Your Personal Data
We collect personal data in several ways, including:
- Directly from you (e.g. when you complete application forms or provide documents)
- Scanned or certified copies of documents (email or postal)
- From third parties (e.g. reference agencies or identity verification services)
- From public or legally permitted sources
3. Who Will Process Your Personal Data?
Your personal data may be processed by:
- Our employees who need access to fulfil their roles
- Affiliates, partners, or service providers who assist us in providing services
- Any regulatory, supervisory or governmental bodies to which we are obliged to report
4. Purposes and Legal Basis for Processing
Purposes:
- Performing or preparing to perform a contract with you
- Fulfilling legal or regulatory obligations
- Pursuing our legitimate interests (e.g. system improvements, risk management, direct marketing, fraud prevention)
- Communicating with you regarding updates, queries, or changes
- Statistical or research analysis
- Direct marketing (subject to your consent or right to object)
- Debt recovery, auditing, or evidence of business practices
Legal Bases:
- Consent (which you may withdraw at any time)
- Necessary for performance of a contract or pre-contractual steps
- Compliance with a legal obligation
- Legitimate interests pursued by us or a third party (provided your rights do not override those interests)
5. Consequences of Not Providing Your Personal Data
If you do not provide the personal data we request, we may be unable to:
- Enter into or perform a contract with you
- Proceed with providing you with certain services
- Comply with legal or regulatory obligations
6. Keeping Your Personal Data Up to Date
You should notify us if any of your personal information changes. We will update our records and notify relevant third parties where appropriate.
7. Sensitive (Special Category) Personal Data
Certain categories of personal data are considered sensitive by their nature. These include information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, and data concerning health.
Depending on the products or services you ask us to provide, it may be necessary for us to collect limited amounts of such information. This will arise only in specific circumstances—for example, where you request portfolio management aligned to Shariah principles or other ethical considerations, which may involve your religious or philosophical beliefs.
In addition, the FCA’s Consumer Duty places a high standard on firms in how they identify and support customers who may be vulnerable. Vulnerability can arise for a wide range of reasons, including physical or mental health, and may be temporary or change over time. For this reason, we ask for your consent to hold relevant information (below) so that we can continue to act appropriately should your circumstances change.
Our policy is to collect special category personal data only where necessary and only with your explicit consent. Given the long-term nature of Financial Advice relationships, we may periodically ask you to reconfirm that consent. You may withdraw your consent at any time by notifying us at our main business address.
8. How Will We Use Your Personal Data (Legitimate Interests)
Examples:
- Contacting you to confirm and update your details
- Responding to questions or complaints
- Sending you updates or changes in our services
- Analysing, reviewing, improving or developing our services
- Recovering fees or debts
- Evidence of our business practices or compliance
- Direct marketing (subject to your rights to opt out)
- Risk management or protecting our business
9. What Personal Data Is Required?
We only collect personal data that is necessary for the purposes stated above. Where lawful and practical to do so, we will inform you if we acquire personal data about you from third parties.
10. Security of Personal Data
We take appropriate technical and organisational measures to protect your personal data against unauthorized or unlawful processing, loss, alteration, disclosure or destruction.
11. Disclosure / Sharing of Personal Data
We may share your personal data with:
- Internal staff (financial, compliance, advisory, IT, administrative)
- Regulators, courts, law enforcement bodies or other authorities as required by law
- Credit reference or identity verification agencies
- Specialist firms or third‑party service providers assisting in service delivery
- Product providers or third parties (for marketing or service purposes)
- In the event of a sale, merger or reorganisation of our business, the buyer or successor entity
12. Direct Marketing
We may use your personal data for direct marketing (subject to legal conditions). You may choose how you wish to be contacted (email, post, phone, SMS) and may opt out or withdraw consent at any time.
13. Automated Decision-Making / Profiling
We may use automated processes in certain decisions, but you will not be subject to a decision based solely on automated processing that produces legal or significant effects, unless explicitly agreed or permitted by law.
14. Telephone Call Recording
We may record incoming or outgoing telephone calls for the following purposes:
- Establishing facts and evidence
- Compliance with legal or regulatory requirements
- Ensuring standards and performance
- Preventing or detecting crime or misuse
15. Data Retention
We will retain your personal data only for as long as is necessary to fulfil our legitimate business purposes and to comply with legal, regulatory or contractual obligations.
16. Access, Correction, Deletion & Other Rights
You have the following rights (subject to applicable exceptions):
- Request access to the personal data we hold about you
- Request correction / rectification of inaccurate data
- Request erasure (i.e. 'right to be forgotten')
- Request restriction of processing
- Object to processing (especially for direct marketing)
- Request data portability
- Withdraw consent (if processing is based on consent)
- Lodge a complaint with the relevant supervisory authority
17. Contacting Our Data Protection Representative
If you have any questions about this Privacy Notice or how we process your personal data, please contact our Data Protection Representative:
- Postal address: Suite 2.05, 6-9 Snow Hill, London, EC1A 2AY
- Telephone: 07786372145
- Email: owen@clockswood.com
18. Complaints to the Regulator
You have the right to lodge a complaint with the relevant data protection authority (for example, the Information Commissioner’s Office in the UK).
- Regulator contact details:
- Postal address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
- Telephone: 0303 123 1113
- Email: icocasework@ico.org.uk
19. Changes to this Privacy Notice
We may update this Privacy Notice from time to time. We encourage you to review it periodically. We will notify you of significant changes via our usual communication channels.
20. Legal / Regulatory Disclaimers
Clockswood Wealth Management Ltd offers independent financial advice to individuals, families, business owners and directors and is aimed at UK Residents only.
Clockswood Wealth Management Limited trading as Clockswood Wealth is an appointed representative of Prydis Wealth Limited which is authorised and regulated by the Financial Conduct Authority.
Clockswood Wealth Management Limited | Registered Office: Suite 106, The Pinnacle 170 Midsummer Boulevard, Milton Keynes, United Kingdom, MK9 1BP.
FCA registration number: 1040319. Registered in England & Wales. Company number: 16342978
