1. Introduction & Scope
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data, and on how to contact us and supervisory authorities in the event you have a complaint.
2. Who We Are
Scottsdale IFA LLP collects, uses, and is responsible for certain personal data about you. When we do so, we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention "Scottsdale IFA", "we", "us" or "our" we are referring to Scottsdale IFA LLP. Scottsdale IFA is a limited liability partnership registered in England and Wales under company number OC372558, whose registered office is at:
Scottsdale IFA LLP
Rex House, 4–12 Regent Street
London, SW1Y 4PE
Telephone: 020 7306 3160
Email: advice@scottsdaleifa.co.uk
Scottsdale IFA LLP is authorised and regulated by the Financial Conduct Authority (FCA). Scottsdale IFA LLP’s Financial Services Register number is 577082. We provide you with independent financial advice and planning services.
3. The Personal Data We Collect and Use
In the course of providing our advisory services to you, we may collect the following categories of personal data when you provide it to us:
- Contact Information: Names, residential addresses, telephone numbers, and email addresses.
- Identity Information: Dates of birth, National Insurance numbers, passport details, and driving licence credentials.
- Financial Information: Bank statements, income details, expenditure, tax status, P60s, existing investment, mortgage, and pension assets.
- Employment Status: Current occupation, employer details, and remuneration structures.
- Lifestyle Patterns: Smoker status, retirement horizons, and financial goals.
- Health & Medical Information: Relevant medical histories, diagnoses, and occupational health data required for underwriting protection and life assurance policies.
- Criminal Convictions: Disclosures where required for underwriting or compliance suitability.
- Vulnerability Indicators: Considerations regarding health, life events, resilience, or financial capability to ensure tailored support.
- Dependants & Beneficiaries: Family members, spouses, or nominees under trusts and pension schemes. (If you provide information about another individual, you must ensure they are informed and content for their details to be shared with us).
- Sanction Check Information: Verification against Politically Exposed Persons (PEP) registers and HM Treasury financial sanctions lists.
4. Information Collected From Other Sources
We also obtain personal data from external sources in the course of providing intermediary services:
- From Lenders and Product Providers: Policy values, transfer values, terms, and underlying fund balances.
- From Identity and Verification Agencies: Electronic identity verification, anti-money laundering checks, and credit background records.
- From Professional Advisers: Accountants, solicitors, and trust administrators where authorized by you.
5. Lawful Bases for Processing Personal Data
Under UK data protection laws, we must establish a valid lawful basis for every processing activity:
| Purpose / Activity | Lawful Basis | Third-Party Recipients Link |
|---|---|---|
| Researching investment contracts, mortgages, pensions, or insurance quotations and executing applications on your behalf | Performance of a contract | Lenders, investment platforms, life offices, and product providers |
| Referring you to specialist third-party advisers for Defined Benefit (Final Salary) Pension Scheme transfers | Consent | Specialist Defined Benefit transfer consultants |
| Referring you to specialist third-party advisers for commercial mortgages or overseas property finance | Consent | Specialist commercial mortgage brokers |
| Retaining records of advice and transaction histories to defend potential legal claims or complaints | Legitimate interests | Regulatory authorities, legal representatives, and external secure data hosting providers |
| Complying with Financial Conduct Authority regulatory rules, anti-money laundering regulations, and statutory tax reporting | Legal obligation | Financial Conduct Authority (FCA), HMRC, National Crime Agency (NCA) |
6. Data Retention Schedules
We retain your personal data for as long as is necessary to provide you with financial advice and planning services, and subsequently for statutory limitation periods required by the Financial Conduct Authority and English law to resolve any subsequent queries, complaints, or disputes.
7. International Data Transfers
We do not routinely transfer personal data outside the United Kingdom or European Economic Area (EEA). If a third-party service provider or software hosting vendor processes data overseas, transfers are strictly protected by UK Adequacy Regulations or standard contractual safeguards ensuring equivalent data protection levels.
8. Your Legal Rights Under UK GDPR
Under the Data Protection Act 2018 and UK GDPR, you have the following statutory rights regarding your personal information:
- Right of Access: The right to request copies of the personal data we hold about you (Subject Access Request).
- Right to Rectification: The right to require us to correct any inaccurate or incomplete personal information.
- Right to Erasure ('Right to be Forgotten'): The right to require us to delete personal data in certain circumstances, subject to our statutory FCA record-keeping obligations.
- Right to Restriction of Processing: The right to restrict the processing of your data while a dispute or accuracy check is ongoing.
- Right to Data Portability: The right to receive personal data you provided to us in a structured, machine-readable format.
- Right to Object: The right to object at any time to processing based on legitimate interests or direct marketing.
9. Data Protection Officer & Contact Details
If you have any questions about this privacy notice, wish to exercise any of your legal rights, or have a concern about how your data is handled, please contact our Data Privacy Lead:
Bruce Buchanan FPFS, TEP
Scottsdale IFA LLP
Rex House, 4–12 Regent Street, London, SW1Y 4PE
Email: advice@scottsdaleifa.co.uk
Telephone: 020 7306 3160
10. Right to Complain to the ICO
You also have the right to lodge a formal complaint with the UK supervisory authority for data protection:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk