Privacy Policy

The Penny Group are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Your privacy is important to us.

This leaflet tells you how Openwork and The Penny Group Limited (“The Penny Group”) use the information you give us and how we protect your privacy. It also explains your rights under the UK General Data Protection Regulation.

Collecting information and protecting your privacy

Openwork and The Penny Group are both Data Controllers and Data Processors of the information you provide to us.

Our aim is to offer advice that helps you plan your financial future. To provide such advice, we need to know about your personal situation and you may be requested to provide sensitive and private information, for example, your income, current financial arrangements, health, family commitments and any legal proceedings you may be involved in. Much of the information you provide will, as part of your application, be passed to the company whose products you apply for and details of how they use your information are included in their data protection literature.

If you are unable or unwilling to provide some, or all, of this information, The Penny Group will be unable to provide you with advice suitable for your circumstances. We do not collect personal information from third parties.

Openwork and The Penny Group are committed to protecting your privacy. As we would like you to be a lifetime client, we need to earn your trust and assure you that we will keep your personal information confidential and secure and only for as long as is necessary. The criteria we use to determine how long this period can be obtained from Openwork’s Data Protection Officer or from The Penny Group at the addresses below.

Openwork and The Penny Group will use your personal data with care and it will only be shared in the ways explained in this leaflet, or if we are required to by Law or the Financial Conduct Authority (FCA).

Your personal information will only be held for as long as necessary and collected for the purposes of providing advice in respect of the range of products and services outlined in the Initial Disclosure Document or Client Proposition Brochure provided by The Penny Group. In addition, we will make every effort to ensure that the information you provide is recorded accurately and that it is only passed to companies who comply with the Data Protection Act 2018 or the General Data Protection Regulation (GDPR). If it is required to send your information abroad, we will only do so to countries within the European Union (EU) or to a third country that the EU has determined provides an adequate level of protection and where you are able to exercise your rights to access your personal information under the GDPR.

Controlling and using your personal information.

A Data Controller is someone who determines the purposes for and the manner in which your personal data should be processed. Openwork and The Penny Group and the companies whose products you buy are all Data Controllers. Openwork’s and The Penny Group’s contact details are shown at the end of this document.

We use your information in a variety of ways:

  • To introduce you to a range of products and services offered by the companies we are associated with(or may be associated with in the future).
  • To help with administration.
  • To contact you with details of changes to products you have bought.
  • For business analysis and research.
  • For marketing products and services The Penny Group think may be suitable for you (if you opt into this service).
  • To comply with the Law and/or FCA requirements.
  • To verify your identity by searching publicly available records held by credit reference agencies.
  • To prevent fraud and money laundering we may pass your details to other companies, public bodies including the police or to an insurer’s database. Insurance companies can search databases for any relevant information that exists about you.

We therefore process your data because it is necessary for:

  • the performance of a contract to which you are a party.
  • compliance with legal obligations to which Openwork and The Penny Group as the controller are subject.

None of the information gathered about you will be used in automatic decision making.

Your health details

If you apply for some types of insurance (e.g., life insurance, pensions, sickness etc.) you will be required to provide details of your health. Under the GDPR and the Data Protection Act 2018, this is regarded as sensitive personal data.

The Penny Group will have access to your medical details unless you prefer to complete a medical statement of health in private. If this is the case, please send it with your application marked for the attention of the “Consultant Medical Officer” in a sealed envelope.

The Penny Group needs your explicit consent to collect and process your health details, which of course you may withdraw at any time. To provide this consent, please sign below and provide one copy of this form to The Penny Group. Signing this form will also indicate that you have read and understood the provisions set out.

Mortgage credit checking

If you apply for a mortgage your information will be passed to the lender, who will carry out a credit check. You will also have to provide details of any criminal convictions you may have had. These details will be passed to the lender to carry out any necessary checks.

Marketing and sharing your information

The information you give us will be added to any other details we hold about you. Openwork and The Penny Group will never sell your details to a third party, but we will share your information with any product provider whose products are recommended to you. The Penny Group will collect your marketing preferences from you as part of providing you with advice.

If The Penny Group leaves Openwork, Openwork will not pass your details to another Openwork Adviser. The Penny Group will keep your details so that they can continue to provide you with a high standard of service.

We may send your information to third parties that are carrying out work on our behalf. However, if we do so, we will ensure that there are legally compliant agreements in place and that the recipient of your personal data complies with the UK GDPR.

Your Data Protection rights

You have certain rights under the UK GDPR. These include the right to:

  • Ask for a free copy of your personal information in a portable format.
  • Request that we stop sending you marketing material about products and services.
  • Have any incorrect information we hold about you corrected.
  • Ask us to restrict processing of your personal data.
  • Ask to be forgotten but we may not be able to do that as it is not an absolute right but if we are not able to erase your personal data, we will tell you why.

As the processing of your personal information is necessary for a legal obligation placed upon us by the FCA and may be required for the establishment, exercise or defence of legal claims, we will not be able to permanently delete your personal information until the end of the period we have deemed necessary.

How to get more information

If you would like further details on how we use your personal information or if you have any data protection queries, please write to:

The Data Protection Officer, Openwork Limited, Auckland House, Lydiard Fields, Swindon, SN5 8UB

The Penny Group Limited:

You may receive more information about data protection from the companies that The Penny Group have introduced you to.

We may record telephone calls so we can check we have acted on your instructions correctly and to ensure we are giving you appropriate service. We may also monitor calls for security and training purposes.


If you have any complaints about the way Openwork or The Penny Group have handled your personal information, please contact the Data Protection Officer at the addresses given above.

You also have the right to refer your complaint to the Information Commissioner.