Before using this site, you should read the following important information relating to it. This information governs your use of this site and, by using it, you agree to be bound by our terms. If you do not agree please exit this website immediately. The contents of this website, including these terms, are subject to change by us without notice.
The products and services are not offered to any person or entity in any jurisdiction where the advertisement, offer or sale of such products and services is restricted or prohibited by law or regulation or where any Firco office would be subjected to any registration or licensing requirement.
This website is designed to be accessed through its principal product home pages and such other pages as we may decide. If you access the site through individual pages directly, which are not designed for this purpose, you may not see important information which is relevant to a full understanding of our products and services. In addition to this Important Information page, you will be referred on certain site pages to read “Regulatory Statement”. These will contain important product details and relevant legal or regulatory information and must be read together with the relevant site pages.
All references on this website to Firco unless stated to the contrary.
While Firco Group uses reasonable efforts to ensure that the information contained on its website is current and accurate at the date of publication, no warranties are made, either expressed or implied, as to reliability, accuracy or completeness of the information. Firco Group accepts no liability for any loss arising directly or indirectly from the use of or action taken in reliance on such information. These documents should not be copied, reproduced or redistributed, in whole or in part.
No warranty is given as to the freedom of this website from errors, defects, viruses, malicious programs or macros.
Registered Office: 75 Derwent Road, Bebington, Wirral CH63 2LF
Client Classification Levels For Your Protection
The FCA has rules which affect the rights you have as a customer. In our dealings with you we will be representing you as the customer, rather than acting on behalf of an insurer.
We classify all our individual customers as ‘retail’ customers. The range of financial products we recommend are tailored to meet the needs of retail customers. You will have rights under the Financial Ombudsman Service (FOS) and the Financial Services Compensation Scheme (FSCS). These rights will apply to the provision of the advice we provide.
There are other classifications of customer that don’t have these rights. These are “professional” customers and “eligible counterparties”.
You have the right to be classified as a professional client and revoke this status on request. Should you feel you have the skills knowledge and experience to be a professional client and don’t wish to have the same protection afforded to retail clients, please let me know and we will complete the forms necessary to reclassify you.
If you have any questions regarding your classification (e.g. if you are a large company), please write to Firco Compliance Department, 62 Dunbabin Road, Childwall, Liverpool L16 7QH or to the Financial Ombudsman Service and FSCS.
The information in the Firco blogs is not intended as an offer or solicitation to buy or sell securities or any other investment or banking product, nor does it constitute a recommendation to buy or sell such products. Nothing in this material constitutes investment, legal, credit, accounting or tax advice or a representation on that any investment or strategy is suitable or appropriate to your individual circumstances.
The value of investments, and the income from them, can go down as well as up, and you may not recover the amount of your original investment. Past performance should not be taken as a guide to future performance. Where an investment involves exposure to a foreign currency, changes in rates of exchange may cause the value of the investment, and the income from it, to go up or down. For some investments, there is no recognised market. Therefore it may be difficult to deal in them or obtain reliable information about their value or the extent of the risks to which they are exposed. Investments in emerging markets are subject to certain special risks, e.g. the risk of political instability, unpredictable financial market trends and economic growth patterns, a financial market that is still in the development stage and a weak economy.
The information in these blogs is believed to be correct but cannot be guaranteed. Any opinion or forecast constitutes our judgment as at the date of issue and is subject to change without notice.
The analysis contained in the Firco blogs has been procured, and may have been acted upon, by Firco and connected companies for their own purposes, and the results are being made available to you on this understanding. To the extent permitted by law and without being inconsistent with any applicable regulation, neither Firco nor any connected company accepts responsibility for any direct or indirect or consequential loss suffered by you or any other person as a result of your acting, or deciding not to act, in reliance upon such information, opinions and analysis.
Neither any blog post nor any copy thereof may be sent to or taken into jurisdictions where the distribution may be restricted by local law or regulation. The reproduction, publication and/or distribution of any of Firco blog posts in whole or part without prior permission of Firco is prohibited.
Posting on Firco Blogs
By submitting comments or any other material for publication on the Firco blogs, you grant Firco a worldwide, royalty-free, non-exclusive and perpetual licence to use in any way whatsoever any comments or material submitted to us in any format. This licence includes, but is not limited to, the right to develop, reproduce, modify, adapt, implement, publish, distribute and display the comments or material in any medium.
In addition, by posting a comment or any other material on the Firco blogs, you warrant that this material belongs to you and that your submission of it does not infringe the intellectual property rights of any third party.
We will attempt to check every comment submitted before it is published on any of the Firco blogs to ensure it complies with our standards but we cannot guarantee the same. We reserve the right to refuse, in our absolute discretion, to allow or to delay posting of all or any part of any comments or other material and to edit or remove any comments or other material posted to the blog. We reserve the right to preserve any content you may post to the extent required by law or the rules of any regulatory authority to protect the rights, property or personal safety of the blog, its users, the public, and Firco.
Nonetheless, we assume no responsibility for monitoring the blog for inappropriate content or conduct, no obligation to modify or remove any inappropriate content and no responsibility for the conduct of the user of submitting any such content.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter. While your email address remains within the MailChimp database, you will receive periodic emails from us.
Any references in these House Rules to ‘you’, ‘your’ or ‘yours’ are references to the person(s) using our social media accounts.
We have designed these House Rules so you can interact with us in a safe and appropriate way. If you do not accept these House Rules, please do not use our social media accounts.
The basic rule for using our social media accounts is:
Only post information you are happy for everyone to see
Do’s and don’ts
- Do keep your comments or messages succinct.
- Do keep comments or messages on-topic.
- Do only comment or message us with your own opinions.
- Don’t comment or message personal or confidential information.
- Don’t use offensive, indecent or obscene language that could be discriminatory or promotes discrimination of any kind, or that may be considered as bullying or harassment;
- Don’t use our social media accounts to incite, condone or encourage conduct which could result in a criminal offence, civil liability or otherwise breach any laws or regulations including any laws regarding competition.
- Don’t comment or message anything that could be considered defamatory or embarrassing, or damaging to an individual, company or entity’s reputation.
- Don’t use our social media accounts in any way which is anti-competitive or could be expected to give rise to anti-competitive behaviour.
Management of our social media accounts
Our social media accounts may be managed by Firco employees and / or third parties appointed by the Firco. We cannot moderate what others post about Firco before it is posted, but we may (if we are able) remove posts which don’t comply with our House Rules.
Views and opinions
Social media platforms are independent third party websites and are not associated with Firco; we can’t control what they do.
With the exception of our own comments and messages, the views and opinions expressed on our social media accounts are the views and opinions of the person posting the information and are not our views or those of Firco. While we try to ensure that the information on our site is current, we cannot guarantee that the information provided on our social media accounts will be complete, accurate or up-to-date.
If you would like to make a formal complaint about the financial or other services we provide, please follow our complaints procedure. If you do make a complaint through our social media accounts, we will try to collect details of the complaint, using secure communication. We will attempt to resolve your complaint through our standard customer complaint procedure.
Using your comments, ideas and images
Our materials and intellectual property
Our names, images, trade marks and other materials contained on our social media accounts are protected by intellectual property rights. You must not use these materials for any reason without our express consent.
Where there are links to third party websites or resources, whether posted by us or a third party, you access these at your sole discretion and at your own risk. We are not responsible or liable for any damage caused by third party websites or resources.
Our comments or messages are not intended to provide any financial, investment or professional advice and shall not be deemed to constitute the offer or provision of financial, investment or other professional advice in any way. You should obtain advice from a qualified financial advisor before making any investment decision.
We reserve the right to amend these House Rules at any time without prior notice. We will notify you on our social media account when there has been a change to these House Rules. You should make sure you are complying with the current House Rules.
We reserve the right to close our social media accounts at any time, without prior written notice.
Please do not issue any formal notices to us through our social media accounts. These should be sent to our office address which is indicated below within the ‘Contact Us’ page.
We normally require our clients to give us instructions in writing, to avoid possible disputes, but we shall be entitled, at our sole discretion, to act upon your oral instructions. We can refuse your instructions at our discretion.
We may vary the terms of this agreement by writing to you at your last know address. Proof of delivery to this address will constitute proof of notice being served.
The information on this website is provided “as is” and has been compiled in good faith to provide information about Firco and its products and services. It is believed to be correct, but we cannot guarantee the accuracy, timeliness, or completeness of any such information. Firco shall not be liable for any loss or damage whatsoever and howsoever arising as a result of your use of or reliance on the information contained on this website.
Before acting on any information obtained from this website you should check it by calling Firco.
Nothing contained on this website constitutes investment, legal, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.
Firco reserve the right to modify, suspend, or discontinue this website or any part of it, with or without notice, at any time, and shall not be liable to you or to any third party for any such modification, suspension or discontinuance of this website.
Firco shall not be liable for any losses or damages of any kind arising out of your use or inability to use this website, or in connection with any error, omission, or defect contained on this website. Furthermore, Firco accepts no liability in respect of losses or damages arising out of changes made to the content of this website by unauthorised third parties.
Access to and use of this website is at your sole risk and Firco does not warrant that the use of this website or any material downloaded from it will not cause damage to any property, including but not limited to loss of data or computer virus infection.
There is no exclusion of duties or liabilities, or any conduct of business rules which Firco are bound to comply with. There is no attempt to exclude liability for death, personal injury, or fraudulent misrepresentation.
Nothing on this website should be construed as a solicitation or offer, or recommendation, to buy or sell securities or any other investment or banking product, or to provide any investment advice or service.
We provide independent investment advice. We will consider a range of regulated products from the available market that can meet the investment objectives of a retail client but we will only provide a recommendation to you when we know the product is suitable for your personal circumstances.
We will inform you if any investment we recommend restricts future access to your capital.
We are independent mortgage advisers and we will advise & recommend a mortgage product that is suitable for you following an assessment of your personal needs and circumstances. This will include a detailed assessment of affordability.
We will consider all products and lenders that we have access to, representative of the whole of the market. This means we will not consider those lenders that are only available by you going direct to them.
Where you are increasing your borrowing, we will consider the merits of both a new first charge mortgage and securing this by an additional mortgage on a second charge basis. You may also have the option of a further advance from your existing lender or borrowing through an unsecured loan but whilst these may be more appropriate for you, we will not consider these when making our recommendation to you.
Where we have quoted mortgage rates, the actual rate available will depend on your circumstances. Ask for a personalised illustration.
As a mortgage is secured against your home, it could be repossessed if you do not keep up the mortgage repayments.
For Non-investment protection contracts we are an intermediary and will act on your behalf when providing advice and making our personal recommendation(s) to you. We will do this based on a fair and personal analysis of insurers for term assurance, income protection, critical illness from a range of insurers. We will provide you with advice and arrange the contract on your behalf after an assessment of your personal needs and circumstances.
For general insurance contracts we are an intermediary and will act on your behalf when recommending an insurer based on your demands and needs from a fair analysis of the market. The insurers we consider will be listed to you when we carry out our research. It will be your responsibility to ensure the policy meets your demands and needs for building and/or contents, private medical insurance, accident sickness and unemployment.
Full details of the products we recommend will be confirmed in the product literature you will receive before it is arranged.
Links from this website exist for information only and Firco Group accepts no responsibility or liability for the information contained on any such site. The existence of a link to another website does not imply or express endorsement of its provider, product or services by Firco Group. Links to this website are not permitted without the prior written consent of Firco Group. Please note that clicking on links to external websites will cause you to leave the Firco Group website.
Past performance should not be taken as a guide to future performance. The underlying value of investments, and the income from them, can go down as well as up, and you may not recover the full amount of your original investment.
Whenever we carry out any investment business services for you, we shall point out to you our understanding of the advantages and disadvantages involved and the degree of investment risk to which you will be subject. You, the client, will ultimately take full responsibility for the final selection and choice of any investments made.
In the case of some investments, you should be aware that there is no recognised market for them and that it may therefore be difficult for you to deal in them or to obtain reliable information about their value or the extent of the risks to which they are exposed.
Certain investments carry a higher degree of risk than others and are, therefore, unsuitable for some investors. Before contemplating any transaction, you should consider whether you require financial advice, which we would be pleased to provide upon request.
Whilst a portfolio of investments specially selected to meet your requirements can be expected to perform in a broadly similar way to the market as a whole, some divergence will be experienced, especially over the short to medium term.
Before contemplating any transaction in an investment programme, you should have read the prospectus relating to the relevant investment programme and consulted your Firco wealth manager.
If you choose to use our execution only dealing service we will not provide investment recommendations to you. Accordingly, when giving orders or instructions to us, you must rely upon your own judgement and in every case the transaction will be your responsibility.
Where you select your own investments or protection policies and are not receiving any recommendation from us as to their suitability or merit, then you take responsibility for those investments’ or policies’ suitability to your circumstances and requirements.
If we agree to arrange such self-selected investments or policies for you, we may do so subject to an ‘appropriate-ness test’ to confirm your understanding of the nature of the investments or protection policies and the risks involved.
Where an investment involves exposure to a foreign currency, changes in rates of exchange may cause the value of the investment, and the income from it, to go up or down.
If applicable, you must also be aware that offshore investments may be subject to an additional risk in terms of exchange rate fluctuations between the currency of the original funds and the currency of a chosen investment.
You also acknowledge that as the client, you should ensure that you understand any exchange control, tax, insurance legislation that may exist in your country and how it affects any investments.
Where we place or transmit orders for such investments on behalf of our clients, we may utilise the services of a third party broker and base our decision to place or transmit an order on the price and cost of execution of the order. For orders in collective investment schemes (e.g. unit trust), however, the price of units or shares in the scheme is normally set by the scheme operator or manager and as such we have little influence over the price available.
The Discretionary Fund Manager Service offers you direct access to investment expertise through a diversified investment portfolio. The DFM will build the initial asset allocation in line with your investment objectives and risk profile. A dedicated portfolio manager will work alongside your Firco private wealth manager to make tactical adjustments throughout the life of your investment, adapting your portfolio as financial markets change. Working closely with you and your Firco private wealth manager, the DFM Investments Solutions will ensure that your portfolio strategy complements your overarching wealth circumstances and, as always with Firco, will be delivered with a high touch, proactive and personal service.
Firco referral to a DFM Service seeks to balance income-generating assets with those offering compelling medium-term growth potential. Controlled through effective portfolio construction and diversification, risk management is central to our approach as we draw on extensive tools and analytics from the DFM to ensure alignment with your individual risk profile.
Firco DFM Service provides access to a range of active and passive investments, including collective investment schemes, index funds and exchange traded funds (ETFs). Structured products may also be used to take advantage of tactical views and strategies. The portfolio focuses on a range of global government bonds, corporate and high yield debt, with a significant proportion allocated to equities in the UK, and in the wider developed and emerging markets. Assets will be owned within your portfolio, and held by the DFM – or an appointed custodian – on your behalf.
If, once having assessed your needs and objectives, we consider that a DFM service is an appropriate solution for you we will:
- Undertake appropriate due diligence and recommend a DFM service/provider that we believe best meets your needs and objectives.
- Attend initial meetings with you and the DFM
- Ensure that your relationship with the DFM is established correctly
- Review the DFM’s performance on a six monthly/annual basis
- Attend annual review meetings to ensure the DFM service continues to meet your agreed needs, objectives and mandate
However, we recognise that occasionally we do make mistakes. In these instances, we encourage our clients to advise us of their complaints so that we have the opportunity to put matters right.
We aim to get your complaint resolved as quickly as possible by staff with the right experience, knowledge and authority.
We want to:
- make it easy for you to raise your complaint;
- listen to your complaint;
- consider your suggestions for how we can put matters right;
- make sure you are satisfied with how your complaint was handled and resolved;
- be polite, efficient and fair in all of our dealings with you.
How and where to complain
If you are not satisfied with any aspect of our service or products, please advise your private wealth manager in person, in writing, by telephone or email.
How long will it take?
Our aim is to address any concerns as soon as possible and within the regulatory guidelines. The timescales we will adhere to are detailed below;
If we have been unable to resolve your complaint with you by the end of the fourth business day, we will write to you within five business days to:
- acknowledge receipt of your complaint;
- tell you who is dealing with your complaint;
- tell you how long we expect to take to resolve it.
Should your concerns take us longer to resolve than we initially anticipated, we will contact you to update you on progress.
Within eight weeks
We will generally send you a ‘final response’ letter. This will clearly set out Firco position with regard to your complaint.
After eight weeks
In exceptional circumstances, where your complaint is particularly complex, matters may take longer than eight weeks to resolve. If this occurs, you will be advised in writing what investigation has taken place and you will be provided with a reason as to why the complaint has not been resolved.
Additionally, you will be provided with a realistic timescale as to when a final response can be expected.
Financial Services Compensation Scheme
If you make a valid claim against us in respect of anything we arrange for you, and we are unable to meet our liabilities in full, you may be entitled to redress from the Financial Services Compensation Scheme; details of the cover provided by the Scheme are available on request. Further information is available from the FCA and the Financial Services Compensation Scheme.
A summary of our internal complaints handling procedures for the reasonable and prompt handling of complaints is available on request and if you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman or by contacting them on 0800 0234 567.
We always strive to give the highest possible standards of service and recommendation.
If you wish to register a complaint, please write to Firco:
Or post to:
62 Dunbabin Road
Firco undertakes investment research in respect of investments primarily for internal use in the portfolio management process. Upon request, some of this research material may be made available to existing private wealth management clients at the discretion of the relevant private wealth manager. Firco has in place a Conflicts Management Policy in respect of the research process. To view the conflict management policy please select the Conflict Management Policy from the drop down above or contact your private wealth manager.
You can receive any documentation from us in the following ways, free of charge:
- Moon: this is a recognised system of raised shapes, similar to the print alphabet.
- Audio documents: CD, MP3, cassette or WAV, which is an uncompressed audio file for your PC.
- Translated: into any language.
- Clear and large print.
- Coloured text and/or paper: with text in any colour and on any colour paper.
If you would like to receive your correspondence in any of these formats, please let us know using the contact details shown.
We prefer our clients to give us instructions in writing, to aid clarification and avoid future misunderstandings. We will, however, accept oral instructions provided they are confirmed in writing.
Our responsibilities include but are not limited to verifying the identity and address of our clients and any third party making payments on their behalf. If required you must supply proof of your identity in accordance of the above Regulations. Identity verification checks may include electronic searches of the electoral roll and the use of credit reference agencies, which will result in a soft ‘foot-print’ on your credit records.
This foot-print is not visible to other financial service providers and does not affect your credit rating in anyway. In accordance with the Data Protection Act 2018 acceptance of these terms and conditions represents your permission for us to access this information.
We are required by the anti-money laundering regulations to verify the identity of our clients, to obtain information as to the purpose and nature of the business which we conduct on their behalf, and to ensure that the information we hold is up-to-date. For this purpose we may use electronic identity verification systems and we may conduct these checks from time to time throughout our relationship, not just at the beginning.
In most cases you can exercise a right to cancel by withdrawing from the contract. In general terms you will normally have a 30 day cancellation period for a life, pure protection, payment protection or pension policy and a 14 day cancellation period for all other policies.
For pure protection policies the start of the cancellation period will normally begin when you are informed that the contract has been concluded or, if later, when you have received the contractual terms and conditions. In other cases, the cancellation period will begin on the day the contract is concluded or, if later, the day on which you receive the contractual terms and conditions. Instructions for exercising the right to cancel, if applicable, will be contained in the relevant product disclosure information which will be issued to you.
If you cancel a single premium contract, you may be required to pay for any loss you might reasonably incur in cancelling it which is caused by market movements. This means that, in certain circumstances, you might not get back the full amount you invested if you cancel the policy.
The ongoing service fee or our authority to act on your behalf can be cancelled at any time without any penalty, by email or post, using contact details provided. These methods ensure we have an audit trail for your instruction. You will be responsible for cancelling any instructions from your bank. If the fee is being taken from your investments we will endeavour to instruct the provider, platform or Discretionary Fund Manager to stop the fee within 5 working days of receiving your instructions and refund any overpayment if we are unable to meet this commitment.
You may ask us for an updated estimate of your advice fee at any time and you may ask us not to exceed a given amount without checking with you first.
We keep records of all our business transactions for six years and indefinitely for UK Pension Transfers. You may inspect copies of all documents on your client file. We treat all clients’ records as confidential so we reserve the right to give you copies of your particular records rather than allow access to files containing records about other clients. We maintain the highest standards of confidentiality with regard to information we hold about our clients. We shall, however, regard ourselves as authorised by you to provide information to your professional advisers and any other parties in the conduct of their business with you, unless we are notified to the contrary by you.
1.1 Firco business model is limited to the extent described in 1.2 and 1.3 below. Accordingly it is Firco view that the research material described below in 1.3 is offered on an independent and objective basis and such conflicts as may arise are effectively managed by the policies set out in 1.4 – 1.8.
1.2 The nature of the Firco business model is such that that the Firco does not:
- trade for its own account
- engage in corporate finance activities, or
- act as a Retail Service Provider/Market Maker.
1.4 Firco operates policies of Chinese Walls and independence, which are designed to restrict the flow of information and ensure the impartiality of the research analysts e.g.
- equity research material is produced within the Research Department, which is physically, separate from, and has a separate reporting line from the private wealth management area and the portfolio advisors which are responsible for client relationships.
- equity research is produced solely from approved brokers’ research and available market information.
- staff are required to be independent when advising clients, i.e. to disregard any relationship or competing interest of which they are aware, and which could conflict with the Firco responsibility to its clients.
- research analysts are free to express their own views in research material, free from the influence or editorial control by subject companies, or by staff in any other area of Firco.
1.5 Firco has strict policies in respect of receiving gifts and inducements from suppliers of services and also in respect of personal account share dealing by members of staff.
1.6 The remuneration policy in respect of Research staff is such that there is no link between pay and reward of such staff and the volume of business transacted by Firco.
1.7 It is one of Firco objectives that all communication with clients is conducted in a manner, which is clear, fair and not misleading.
1.8 Firco has in place a clear code of conduct for staff, which outlines the principles that staff are required to adhere to in their dealings and relationships with clients.
interest of our clients is paramount to us and to achieve this we have designed our systems and
procedures to place you at the heart of our business. In doing so, we will:
- be open, honest and transparent in the way we deal with you;
- not place our interests above yours;
- communicate clearly, promptly and without jargon;
- seek your views and perception of our dealings with you to ensure it meets your expectations
- or to identify any improvements required.
We will act honestly, fairly and professionally known as conducting business in ‘Client’s best interest’ regulations. Occasionally situations may arise where we or one of our other clients have some form of interest in business transacted for you. If this happens or we become aware that our interests or those of one of our other clients conflict with your interest, we will write to you and obtain your consent before we carry out your instructions, and detail the steps we will take to ensure fair treatment. Where this cannot be achieved, we will not conduct the business.
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This part is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your investments, savings, pensions, mortgage, finance and/or insurance requirements Your Personal Data may include:
- Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
- Any pre-existing mortgage, finance and/or insurance products and the terms and conditions relating to these
The basis upon which our firm will deal with Your Personal Data
When we speak with you about your investments, savings, pensions, mortgage, finance and/or insurance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance or ethical investments, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you information about your ethnic origin, your health and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries of insurance / investment providers in relation to insurance products that may meet your needs and to provide you with advice & guidance regarding the suitability of any product that may be available to you.
If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investments, savings, pensions, mortgages, finance and insurance. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to Product Providers, Mortgage Lenders, Commercial Lenders and/or Insurance Product providers, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage, finance product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Investment or pension providers Mortgage lenders, Finance lenders and/or Insurance providers
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
- We would also like to keep you informed of pension, mortgage, insurance, investment and any other services provided by us or associated companies with which we have a formal business arrangement; which we think may be of interest to you. We would like to contact you by way of letter, email or telephone call. If you do not wish to receive such marketing information, please tick the box on Firco Service & Costs Agreement.
In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your investments, savings, pensions, mortgage, finance and/or insurance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
Transferring information overseas
We may transfer your information to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area. However, in the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway).
We will only do so where:
- the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
- the transfer has been authorised by the relevant data protection authority; and/or
- we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us by writing to:
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this section, or wish to make contact in order to exercise any of your rights set out within it please contact:
in writing: The Data Protection Officer, Firco, 62 Dunbabin Road, Childwall, Liverpool L16 7QH
Telephone: 0151 372 0388
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by contacting in writing: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Please click on ‘Become a Client’ at the bottom of the page and complete the enquiry form and we will normally contact you within the same working day during business hours or if you would prefer us to contact you outside normal business hours then please advise and we will quite happily do so. Alternatively you can email us with details about your requirements to email@example.com or call us on 0151 372 0388