Privacy Policy

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.