Trust Will Plan Ltd is committed to protecting your personal information.
Who we are
We are Trust Will Plan Ltd, part of TWP Global Group.
Trust Will Plan Ltd its subsidiaries, including I2Day Ltd; Total Wealth Planning ltd; HTW Ltd, TWP Legal Services Ltd and Eulogie Ltd
How to contact us
FAO Data Protection Officer
Trust Will Plan Ltd Limited,
2nd Floor, Reigate Hill House
28 Reigate Hill, Reigate,
Information we collect and use
Information about you that we collect and use includes:
Information about who you are e.g. your name, date of birth and contact details
Information connected to your product or service with us e.g. your bank account details
Information about your contact with us e.g. meetings, phone calls, emails / letters
Information that is automatically collected e.g. via cookies when you visit one of our websites
Information if you visit one of our offices e.g. visual images collected via closed circuit television (CCTV)
Information classified as ‘sensitive’ personal information e.g. relating to your health, marital or civil partnership status. This information will only be collected and used where it’s needed to provide the product or service you have requested or to comply with our legal obligations
Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
Information on children e.g. where a child is named as a beneficiary on the policy taken out by a parent or guardian on their behalf. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)
A cookie is a small file – it’s saved onto your computer or other device when you visit our website.
Cookies store small pieces of information. For example - they will remember you've visited our website or performed a certain action.
Cookies also let us know which pages of our website you visited; they help us develop and market our products and services. They also help us track sales.
- Persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)
- Session cookies - these expire when you close your web browser
Where we collect your information
We may collect your personal information directly from you, from a variety of sources, including:
- an application form for a product or service
- phone conversations with us
- emails or letters you send to us
- meetings with one of our financial advisers
- registering for one of our events e.g. retirement events or webinars
- participating in research surveys to help us understand you better and improve our products and services
- our online services such as websites, social media and mobile device application ('Apps')
If you have a financial adviser the information we collect and use will most likely have been provided by them on your behalf.
We may also collect personal information on you from places such as business directories and other commercially or publicly available sources e.g. to check or improve the information we hold (like your address) or to give better contact information if we are unable to contact you directly.
What we collect and use your information for
We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:
- you have given us your permission [consent] to send you information about products and services offered by other parts of Trust Will Plan Ltd or selected third parties we have chosen to work with which we believe may be of interest and benefit to you
- it’s necessary to provide the product or service you have requested e.g. if you wish to receive financial advice or invest in recommended product, we will require some personal information including your name, address, date of birth, bank account details
- it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, tell you about changes to Terms and Conditions or for the detection and prevention of fraud
- it’s in the legitimate interests of Trust Will Plan Ltd e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from your product or investment; where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services; where we use artificial intelligence or computer algorithms to improve the products and services offered to you
If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.
We sometimes use systems to make automated decisions based on personal information we have - or are allowed to collect and use from others – about you. These automated decisions can affect the products, services or features we offer you now or in the future. We use automated decisions in the following ways:
- When designing and enhancing our online services to help meet your requirements for ongoing guidance and support
Who we may share your information with
We may share your information with third parties for the reasons outlined in 'What we collect and use your information for.'
These third parties include:
- Companies within Trust Will Plan Ltd
- Your adviser
- Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers e.g. research, consultancy or technology companies; or companies who can help us in our contact with you, for example an internet service provider
- Our regulators and Supervisory Authority e.g. the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO)
- Law enforcement, credit and identity check agencies for the prevention and detection of crime
- HM Revenue & Customs (HMRC) e.g. for the processing of tax relief on pension payments or the prevention of tax avoidance
We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.
Where your information is processed
The majority of your information is processed in the UK and European Economic Area (EEA).
However, some of your information may be processed by us or the third parties we work with outside of the EEA, including countries such as Australia or United States
Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws e.g. we will put in place legal agreements with our third party suppliers and do regular checks to ensure they meet these obligations.
How we protect your information
We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake annual training on this.
Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.
How long we keep your information
We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer.
We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet.
Your individual rights
You have several rights in relation to how Trust Will Plan Ltd uses your information. They are:
Right to be informed
Right of access
Individuals have the right to access their personal data and supplementary information, and the right of access allows individuals to be aware of and verify the lawfulness of the processing. A copy of this information will be provided free of charge
Right to request that your personal information be rectified
If your personal information is inaccurate or incomplete, you can request that it is corrected.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for Trust Will Plan Ltd to continue to have it.
Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal information for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.
Right to object
You can object to Trust Will Plan Ltd processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics.
Rights related to automatic decision making including profiling
You have the right to ask Trust Will Plan Ltd to:
- give you information about its processing of your personal information
- request human intervention or challenge a decision where processing is done solely by automated processes
- carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.
How to make a complaint
If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are: