Data Protection Notice

The purpose of this Notice  

When we provide our services to you, we will collect personal information about you [and others]  and we want to be open and transparent with you as to the types of information we collect about  you, why we collect it, how we use it and who we may share it with.  

The data controller of your personal information is Thomas Anthony Financial Services Ltd t/a VK  Financial operating at Cornwall Buildings, 45-51 Newhall Street, Birmingham B3 3QR [Company  Registration No. 0565805].  

If you have any questions or concerns about our use of your personal information, then please  contact us using the contact details provided at the bottom of this Notice in the ‘How to contact  us’ section.  

What type of personal information will be processed and why?  

We may ask you to provide personal information by filling in hard copy forms and documents or  by corresponding with us by phone, e-mail, letter or otherwise or during our meetings with you. 

Types of personal information  Why we collect it
Identity details including your name and date of  birth.  

We may ask for copies of identity documents in  which case we may collect details including  your place of birth and residential address.

To carry out money laundering and financial  checks and for fraud and crime prevention  and detection purposes.  

We will only ever use copies of identity  documents for this purpose.  

We collect and process this personal  information to comply with our legal and  regulatory requirements. 

Your contact details including your name,  postal address, phone number and email  address(es) and other personal details about  you including your title, job title, marital status  and date of birth.  To contact you for us to manage, administer  and provide our services to you.  

To respond to any correspondence and  service-related enquiries you send to us in  respect of our services.  

To discuss products or services for which  you apply or may be interested in applying  for.  

To manage any applications that we make on  your behalf for products or services.  

To communicate any updates to you  including any changes to our services, the  terms and conditions of any services which  we have provided to you, any changes to this  notice and to our websites.  

To contact you to receive your feedback on  our services and to participate in related  surveys. 

Financial information relating to you, including  pension contributions and current value, salary,  bank account balances, credit card balances  details of investments and payment card  details.  To evaluate your eligibility for products,  including making credit searches with credit  reference agencies and fraud searches with  fraud prevention agencies.  

To enable us to advise you on your financial  circumstances and the appropriateness of  specific courses of action and products.  

We collect and process this personal  information for our legitimate business  interests.  

To enable you to make payments for our  services.  

We collect and process this personal  information as is necessary for the entry into  and performance of any agreements  between us (i.e., to assess whether you are  eligible for products, and once an agreement  has been entered into between you and us,  so that we can collect payments from your  payment card). 

Details of your dependents (name, address,  and date of birth)  To enable us to provide you with services  that you have requested that would involve,  or have an impact on, your dependents (who  may be adults or minors). Where those  dependents are adults, please make sure  that you have their permission to provide us  with their personal information. 
Details of contact that we have had with you  such as meetings with you, fact-finding  discussions and documentation,  recommendations, referrals, and quotes.  To allow us to provide a professional service  to you and to contact you with information  about other services of ours that we think you  may be interested in.  

We collect and process this personal  information for our legitimate business  interests. 

Details of services you have received. 
Client experience and other feedback and  information you provide to us.  To review your feedback and experience  with us so that we can improve our products  and services for you and for our other clients.  

We collect and process this personal  information for our legitimate business  interests.

Information about complaints and incidents. 
Recordings of calls we receive or make. 
All of the personal information described above.  We may disclose your personal information  to third parties where we are required to do  so to comply with applicable laws and  regulatory requirements including in  circumstances where we are required to do  so by a court Order, regulatory authority or  any other third party with the lawful right to  request and receive the personal information  we hold about you (including law  enforcement agencies and tax authorities).  

We may also use your personal information  where it is necessary for us to take legal  advice to establish our legal rights, to bring a  claim against you or any related parties or to  defend a claim from you or any related  parties.  

We collect and process this personal  information for our legitimate business  interests including to carry out our own  internal business planning, compliance,  training, audit and quality assurance  purposes. 

Depending upon the types of products and services you require, we may also need to collect  information from and about you which the law considers to be sensitive, such as data about your  physical or mental health, which we refer to as “special category personal data”. The special  category personal data that we may ask you to provide, and the reasons why we ask you to  provide it, are as follows: 

Types of special category personal data  Why we collect it
Information about your physical or mental  health or condition.  Certain products and services that you  request may require this information.  Specifically, for us to advise you on and to  submit applications for health or life insurance  products and services, we will need to collect  information relating to your physical and  mental health in order to obtain accurate  quotes and to advise on the suitability of  products (as insurance premiums and  eligibility for products will in part depend on  your physical and mental health). We will  usually collect this information during  meetings with you, on specific questionnaires  or in the process of completing an application  form for such products and services. 
Information about your sex life or sexual  orientation.  Some providers may ask for this information  during your application for their products or  services. We will never ask for this information  for our own purposes. 
Information about your racial or ethnic origin  Some providers may ask for this information  during your application for their products or  services. We will never ask for this information  for our own purposes. 

We will only process the special category personal data listed above with your explicit consent.  We ask for your consent to the processing of this data at the end of this Notice. You may choose  not to provide us with this consent. However, please note that if you do not provide us with  your consent to collect and process the information listed in the table above:  

we may not be able to advise you fully in respect of certain products and services  which require this information (in particular those relating to health or life  insurance).; 

your application may be rejected by the providers of products and services which  require this information; or 

the quotes for such products and services may be higher than would be the case  if this information were provided.  

In some circumstances, we may receive information about you from third parties. In particular, we  will receive information about you from Credit Reference Agencies and Fraud Prevention  Agencies. This may include details of the products and services you have applied for, those  lenders, finance and credit organisations with whom you have (and have had) an agreement with,  the amounts advanced, the amount and frequency of repayments and whether you have made  your repayments on time and in full. This will help us make the best possible assessment of your  financial situation before we decide whether we can provide you with our services and/or  recommend any specific products and services. It is in our legitimate interests to process your  personal information for this purpose. We may also ask you to provide Letters of Authority to allow  us to receive information about you from providers.  

When we record communications

We, and persons acting on our behalf, may record and/or monitor communications (including  telephone conversations over landlines and mobile phones, emails, instant messaging, and other  electronic communications) between our staff and you. We only record communications between  us to comply with our legal and regulatory requirements – as a regulated financial adviser, the law  requires us to record these communications.  

We may also record and/or monitor communications for training and quality assurance purposes  but will always ask for your consent before recording communications for these purposes. If  you choose not to provide your consent in these circumstances, we will still be entitled to record  and/or monitor communications if we are under a legal obligation to do so (but will only be able  to use the recordings for those purposes).  

Who might my personal information be shared with?

We may disclose your personal information to the following categories of recipients:  

to providers of financial services, insurance and investment products and services  in respect of whom you request us to submit applications on your behalf and to receive  updates from such providers for us to provide our services to you throughout the lifetime  of our relationship with you.  

to our suppliers and partners for them to help us provide our services to you, this  includes:  

o our IT systems providers to assist us with providing you with an efficient,  modern, and professional service.  

o our suppliers of audit and regulatory compliance support services who may  review our records containing your personal information in order to audit and  report to us on our compliance with applicable laws and regulatory requirements;  

o our accountants, solicitors, insurer(s) and insurance broker(s) and any other  provider of professional services to us.  

to Credit Reference Agencies and Fraud Prevention Agencies to help us make the  best possible assessment of your financial situation before we decide whether we can  provide you with services. We are also required to provide information to such agencies 

so that they can update the information which they hold about you and which they may  share with other organisations.  

to other financial institutions or regulatory bodies with whom information is shared  for money laundering checks, credit risk reduction and other fraud and crime prevention  purposes.  

to a prospective buyer (and its agents and advisers) in the event we intend to sell any  part of our business or its assets or if substantially all of our assets are acquired by a third  party, in which case your personal information could form part of one of the assets we  sell, provided that we inform the buyer it must use your personal information only for the  purposes described in this Notice. We will never rent or sell your personal information  other than as part of a sale of our business.  

to any national and/or international regulatory, enforcement body, government  agency or court where we believe disclosure is necessary:  

(i) as a matter of applicable law or regulation (including where we are required by  law to provide information to organisations such as HMRC),  

(ii) to exercise, establish or defend our legal rights, or  

(iii) to protect your vital interests of those of any other person; and  

to any other person with your consent to the disclosure or where we are permitted to  do so by law.  

Our legal basis for processing personal information 

Our legal basis for collecting and using your personal information will depend on the personal  information concerned and the specific context in which we collect it. In respect of the personal  information and the purposes for which we may process your personal information which are set  out in this Notice, we have confirmed the legal basis upon which we collect and process your  personal information in the ‘What type of personal information will be processed and why?’ section  above. 

If we ask you to provide personal information to comply with a legal requirement or to perform a  contract with you or with your explicit consent, we will make this clear at the relevant time and  advise you whether the provision of your personal information is mandatory or not (as well as of  the possible consequences if you do not provide your personal information).  

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or  those of any third party), we will make clear to you at the relevant time what those legitimate  interests are.  

If you have questions about or need further information concerning the legal basis on which we  collect and use your personal information, please contact us using the contact details provided  under the “How to contact us” heading below.  

International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the  country in which you are resident. These countries may have data protection laws that are  different to the laws of your country (and, in some cases, may not be as protective). 

Your data protection rights

You have the following data protection rights:  

If you wish to access, correct, update or request deletion of your personal information,  you can do so at any time by contacting us using the contact details provided under the  “How to contact us” heading below.  

In addition, you can object to processing of your personal information, ask us to restrict  processing of your personal information or request portability of your personal  information. Again, you can exercise these rights by contacting us using the contact  details provided under the “How to contact us” heading below.  

You have the right to opt-out of marketing communications we send you at any time.  You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the  marketing e-mails we send you. To opt-out of other forms of marketing (such as postal  marketing or telemarketing), then please contact us using the contact details provided  under the “How to contact us” heading below.  

Similarly, if we have collected and process your personal information with your consent,  then you can withdraw your consent at any time. Withdrawing your consent will not  affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it  affect processing of your personal information conducted in reliance on lawful processing  grounds other than consent. For specific information about our processing of your  sensitive category personal data with your consent, please see the “Your consent to us  processing your special category personal data” heading below.  

You have the right to complain to a data protection authority about our collection and  use of your personal information. For more information, please contact your local data  protection authority. (Contact details for data protection authorities in the European  Economic Area, Switzerland and certain non-European countries (including the US and  Canada) are available at  

We respond to all requests we receive from individuals wishing to exercise their data protection  rights in accordance with applicable data protection laws. 

Data retention 

We retain personal information we collect from you where we have an ongoing legitimate need to  do so, for example:  

to provide you with a product or service you have requested us to provide,  to perform our contractual obligations to you.  

to comply with applicable legal, tax or accounting requirements.  

to defend or manage any claims or complaints between us, you and any relevant third  party including taking legal advice in respect of such claims to establish, exercise or  defend our legal rights or such claims. This would include complaints and claims which  you may bring against us or which are submitted to a court, regulatory authority, or  ombudsman.  

When we have no ongoing legitimate need to process your personal information, we will either  delete or anonymise it or, if this is not possible (for example, because your personal information  has been stored in backup archives), then we will securely store your personal information and  isolate it from any further processing until deletion is possible.  

Updates to this Notice

We may change or update this Notice to maintain our compliance with applicable law and  regulation or following an update to our internal practices. When we update our Notice, we will  take appropriate measures to inform you, consistent with the significance of the changes we  make. 

How to contact us

If you would like to contact us in relation to this Notice or if you have any other questions in respect  of our processing of your personal information, please contact Vassos Koni  [[email protected]].