Privacy Policy
Privacy Policy
At Bloomfield Financial, people trust us with sensitive personal and financial information. We take that responsibility seriously and aim to be clear about what information we collect, why we need it and how we protect it.
Who we are
Bloomfield Financial Limited is a company registered in England and Wales (company number 08564599).
Address: Evolve Business Centre, Cygnet Way, Houghton-le-Spring, DH4 5QY.
Email: Contact Page
Telephone: 0191 406 6453
Bloomfield Financial Limited is normally the data controller of the personal information we collect and use when providing financial advice and operating our business. This means we decide why and how that information is processed.
John Bloomfield is our designated data-protection contact.
What personal information we collect
Depending on our relationship with you and the services involved, we may collect:
Identity and contact details: Name, date of birth, address, contact details, nationality and identification documents.
Financial information: Income, expenditure, assets, liabilities, investments, pensions, mortgages, insurance arrangements, tax information and financial objectives.
Employment and family details: Information relevant to your financial planning and any employer-sponsored benefits.
Health and personal circumstances: Information relevant to protection advice, retirement planning, vulnerability or other services where appropriate.
Verification information: Identity-check results, sanctions and politically exposed person (PEP) screening results, and relevant anti-money laundering information.
Communications and records: Correspondence, meeting notes, instructions, agreements, records of advice and your communication preferences.
Website and marketing information: Information you submit through our website and, where applicable, information about your interactions with our communications.
We aim to collect only information reasonably necessary for the relevant purpose.
Where we obtain information
Most information comes directly from you.
Where appropriate and lawful, we may also obtain information from your authorised representatives, employers or payroll departments, pension and investment providers, insurers, lenders, professional advisers, public registers and identity-verification services.
Why we use your information
We use personal information to:
Understand your circumstances and provide appropriate financial advice.
Arrange, administer and review financial products and services.
Communicate with you and respond to enquiries.
Verify identity and comply with anti-money laundering and financial sanctions requirements.
Meet legal, tax and FCA regulatory obligations.
Maintain records and respond to complaints or potential legal claims.
Prevent fraud, maintain information security and operate our business.
Send optional marketing communications where permitted and in accordance with your preferences.
Our lawful reasons for processing information
UK data protection law requires us to have a valid lawful basis for each purpose.
Depending on the circumstances, we may rely on:
Contract: Where processing is necessary to provide services under our agreement with you or to take steps you request before entering an agreement.
Legal obligation: Where we must process or retain information to comply with legislation or regulatory requirements, including anti-money laundering and financial services obligations.
Legitimate interests: Where processing is reasonably necessary for legitimate business purposes, such as security, fraud prevention, administration or the establishment, exercise or defence of legal claims, provided those interests are appropriately balanced against your rights.
Consent: Where we ask you to make a genuine choice, including for optional marketing communications or particular uses of sensitive information where consent is the appropriate legal condition.
Other lawful bases may apply in particular circumstances.
We do not rely on your consent for every aspect of providing financial advice. Where processing is necessary for a contract or legal obligation, withdrawal of consent for another purpose does not prevent us from meeting those obligations.
Sensitive personal information
Some advice services require information about health or other sensitive personal circumstances.
Information classified as special category data receives additional protection under UK data protection law. We will only use it where we have an appropriate lawful basis and a relevant additional legal condition.
Where explicit consent is required, we will explain the purpose and seek that consent separately.
Information relating to criminal offences is handled subject to the additional protections required by law.
Who we share information with
Where appropriate, we may share relevant information with:
Pension, investment, insurance and mortgage providers.
Investment platforms and other financial service providers.
Authorised professional advisers and representatives.
Employers or payroll departments involved in relevant corporate services.
Identity verification, fraud prevention and sanctions screening services.
Approved technology, administration and service suppliers.
Our professional compliance, legal and insurance advisers.
The Financial Conduct Authority, law enforcement, HMRC and other authorities where required or lawfully permitted.
We limit disclosures to what is appropriate for the relevant purpose.
Some recipients act as independent data controllers; others process information on our behalf under appropriate contractual arrangements.
We do not sell your personal information to advertisers.
Transfers outside the UK
Some suppliers or service arrangements may involve access to or storage of personal information outside the UK.
Where UK international-transfer rules apply, we use a valid legal transfer mechanism, such as applicable UK adequacy regulations or appropriate contractual safeguards and assessments.
We take account of the destination, recipient and safeguards required by UK law.
You can contact us for further information about applicable transfer safeguards.
How long we retain information
We keep information for as long as necessary to meet the purpose for which it was collected, including applicable legal and regulatory obligations.
Financial advice may give rise to potential liability for many years. We therefore retain relevant records where reasonably necessary to evidence advice, respond to complaints or defend potential legal claims.
Certain records, including specified pension transfer suitability records, are subject to FCA requirements for indefinite retention.
Anti-money laundering customer due diligence information is subject to separate statutory retention rules. The normal period is five years after the relevant business relationship ends or an occasional transaction is completed, subject to applicable legal exceptions.
We do not automatically delete historic advice files when a client relationship ends. We consider the type of information, relevant obligations and continuing justification for retention.
Where information is no longer required for a lawful purpose, we will securely delete or anonymise it as appropriate.
How we protect your information
We use appropriate organisational and technical security measures to protect personal information against unauthorised access, disclosure, alteration, loss or destruction.
These include controlled access to business systems, authentication measures, appropriate confidentiality procedures and secure record-handling arrangements.
No electronic system can be guaranteed completely risk-free, but we take reasonable steps to protect the information entrusted to us.
Marketing and communication preferences
We may send information about financial planning, our services and other topics we believe clients may find useful.
Our policy is to obtain appropriate permission before sending optional marketing communications to individual clients.
You can choose your preferred marketing channels and change or withdraw those preferences at any time.
We will respect your objection to direct marketing.
You may still receive communications necessary to administer your services, meet contractual obligations or provide important information about existing arrangements.
Where our email systems record message openings or link interactions, we will use that information only where permitted under applicable privacy and electronic communications requirements.
Cookies and website information
Our website may use cookies and similar technologies to support its operation and, where enabled, understand website use.
Where consent is required for non-essential technologies, those technologies must not be used unless the appropriate consent has been obtained.
Any separate cookie information or preference controls provided on the website should be read alongside this privacy policy.
Your rights
Depending on the circumstances, you have rights concerning:
Access to personal information we hold about you.
Correction of inaccurate or incomplete information.
Deletion of information where the legal conditions apply.
Restriction of certain processing.
Objection to certain processing, including direct marketing.
Data portability where applicable.
Rights relating to certain automated decisions.
Withdrawal of consent where processing relies on consent.
These rights are subject to applicable legal conditions and exemptions.
For example, requesting deletion does not automatically override regulatory record-keeping duties or a valid requirement to retain evidence for legal proceedings.
To exercise your rights, contact us using the details above. You do not need to use a particular form.
We normally respond to subject access requests within one month, subject to applicable rules on extensions, exemptions and verification.
We do not normally charge for exercising data protection rights, although the law permits fees or refusal in certain circumstances involving manifestly unfounded or excessive requests.
Data protection complaints
If you believe we have mishandled your personal information, please contact us.
We will acknowledge a data protection complaint within 30 days, investigate it appropriately and explain our findings and any relevant actions without undue delay.
You may also raise concerns with the Information Commissioner’s Office (ICO):
We would welcome the opportunity to consider and resolve your concern directly.
Changes to this policy
We may update this policy to reflect changes to our services, systems, practices or legal obligations.
The current version will be available on our website. Where appropriate, we will bring significant changes to your attention.
Contact us
For privacy questions, individual rights requests or data protection complaints, contact:
Bloomfield Financial Limited
Evolve Business Centre
Cygnet Way
Houghton-le-Spring
DH4 5QY
Email: Contact Page
Telephone: 0191 406 6453
