Privacy Policy
Access Financial Services Limited including any authorised trading styles and its Appointed
Representative Accessible Insurance Services Limited take the privacy and protection of
personal data seriously – we therefore ask you to read the following important information
which explains how we collect, store and use your personal data.
- Who are we?
Access Financial Services Limited is registered in England under company number
04427489, and our office address is Unit 1 Furtho Court, Towcester Road, Old Stratford,
Milton Keynes, MK19 6AN.
Access Financial Services Limited is authorised and regulated by the Financial Conduct
Authority under Firm Reference Number 301173. - Introduction
Under the Data (Use and Access) Act 2025 (DUAA), UK General Data Protection Regulation
(UK GDPR) and the Data Protection Act 2018, we are required to provide you with clear
information about how your personal data is collected, used, stored and shared. This
includes explaining the lawful basis on which we process your information and your rights in
relation to that processing.
This notice (together with our Statutory disclosures and any other documents referred to in
it) (“Privacy Notice”) sets out the basis on how any personal information we collect from you,
or that you provide to us, will be processed by us. - What do we mean by Personal Data?
By personal data (or personal information), we mean information that relates to you and is
used to identify you, either directly or in conjunction with other material we may hold.
Some Personal Data may identify you directly, for example your name, address, date of
birth, national insurance number. Other 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 Access Financial Services Limited including any authorised trading styles
and its Appointed Representative Accessible Insurance Services Limited providing you with
advice and guidance in relation to your requirements your Personal Data may include:
● Name, Date of Birth, Gender, Nationality, Civil/Marital Status, Contact Details, Addresses
and any documents that are necessary to verify your identity
● Employment and remuneration information
● Bank account details, tax information, commitments for liabilities such as loans and credit
cards, personal credit history, sources of income and expenditure
● 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 Category Data.
In addition, when you visit our sites or use our services, we may automatically collect the
following information.
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Technical information, including information obtained cookies, the Internet Protocol (IP)
address used to connect your computer to the internet, your login information, your
geographic location, browser type and version, browser plug-in types and versions,
operating system and platform.
We may also receive personal information from third parties that we work with including:
● Companies that introduce you to us Financial Advisers
● Insurers
● Comparison websites
● Fraud prevention and/or Credit reference agencies
● Payroll service providers (In relation to Auto-Enrolment Pension products)
● Public information sources such as Companies House
● Agents working on our behalf
● Market researchers
● Regulatory bodies
● Government and law enforcement agencies.
- Digital Identity Verification (DVS)
We use approved Digital Verification Services (DVS) to confirm your identity. This involves
secure digital checks of your identity documents and biometric information. These checks
help protect you from fraud and ensure we meet our legal obligations under the Data (Use
and Access) Act 2025.
Open Finance Data Access
With your permission, we may access your financial information such as pensions,
investments, savings and insurance through regulated Open Finance services. This ensures
we use accurate, up-to-date information when providing advice and carrying out anti-money
laundering checks.
How Your Data Is Shared
We only share your data with regulated third parties where required by law or where
necessary to deliver our services. All data sharing is carried out through secure, DUAA
compliant systems.
Your Rights Under DUAA
You have the right to access, correct, restrict or object to the processing of your data. You
may withdraw consent for marketing at any time. You may also request details of any Open
Finance data accessed on your behalf.
How We Use DUAA-Enabled Data
We use DUAA enabled data to:
● Verify your identity
● Assess the suitability of our advice
● Meet our anti-money laundering obligations
● Monitor your financial arrangements on an ongoing basis
● Ensure we deliver good outcomes under the FCA Consumer Duty - What is Special Category Data?
Certain types of personal data are considered more sensitive and so are subject to
additional levels of protection under data protection legislation. These are known as ‘special
categories of data’ such as:
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● Racial or ethnic origin
● Political opinions
● Religious or philosophical beliefs
● Trade union membership
● Genetic data
● Biometric data
● Health
● A person’s sex life
● Sexual orientation
There are further protections in relation to Criminal Offence data which can be found at
https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/a-guide-to-l
awful-basis/
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 relates to insurance related activities such as underwriting, claims and
fraud management.
We will use Special Category Data and any Criminal Disclosures in the same way as Your
Personal Data generally, as set out in this Privacy Notice. In order to process your Special
Category Data however, we do require explicit consent.
- Why do we collect information from you?
In order to undertake our services for you, we have the right to use your Personal Data
provided it is in our legitimate business interest. We may be required to share this data with
third parties such as providers, Insurance Companies and Regulatory and Legal bodies etc.
We use your personal information to enable us to:
● Provide services and advice or to provide you with the information, products and services
you have requested from us under ‘Legitimate Interest’.
● Retain records of any services or advice we provide to you in order to defend potential
legal claims or complaints and to comply with our Legal and Regulatory obligations.
● Provide you with details of products and services we may feel be of interest to you in
accordance with your preferences. - How do we collect information?
Most information we obtain will be directly from you during our meetings and discussions or
this may be in writing, including via email.
We may also need to obtain information from third parties in relation to verifying your identity.
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. - How do we protect your personal information?
We have strict safeguarding processes to ensure that we meet our obligations under the
Data Protection Regulations 2018. 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.
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We will:
● Record and store your Personal Data in our paper files and electronic files on our
computer systems, which can only be accessed by our staff 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 providers both electronically or via paper-based forms to
allow us to advise you or process your application for a product, or to obtain information
as required as part of our services
● Use your Personal Data to respond to any queries you have on your policies under our
Agency.
We also expect you to take reasonable steps to safeguard your own privacy when
transferring information to us.
Your Personal Data will be retained by us either electronically or in paper format for a
minimum of three years or in instances whereby we have a Regulatory or Legal obligation to
hold such information indefinitely.
- What are your rights surrounding your personal information?
Your enhanced rights under the GDPR and the Data (Use and Access) Act 2025 (DUAA)
include:
The Right to be Informed: Organizations must provide clear, transparent, and concise
information about how they use personal data, typically through a privacy notice.
The Right of Access (SARs): Individuals can request a copy of their personal data (a Subject
Access Request or SAR), which must generally be provided within one month for free where
this is reasonable and proportionate. In instances where this is considered to be complex or
excessive, this may take up to an additional two months, however individuals would be
informed of this at the time.
The Right to Rectification: Individuals can ask to have inaccurate personal data corrected or
incomplete data completed.
The Right to Erasure (“Right to be Forgotten”): Individuals can request the deletion or
removal of personal data in certain circumstances, such as when it is no longer necessary.
The Right to Restrict Processing: Individuals can ask to suppress or block the processing of
their data in specific scenarios, allowing for storage but not usage.
The Right to Data Portability: Allows individuals to obtain and reuse their personal data for
their own purposes across different services in a secure, machine-readable format.
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The Right to Object: Individuals can object to processing based on legitimate interests, direct
marketing (including profiling), or research/statistics.
The Right to request details of Open Finance Data accessed: You can request access to the
data we have obtained via the Open Finance system
Rights Related to Automated Decision-Making and Profiling: Individuals have protections
against decisions made solely on automated processing that produce legal or similarly
significant effects.
The Right to withdraw marketing consent at any time: If you have provided consent to
marketing materials, not including ongoing servicing, you can withdraw this consent at any
time.
Please note; the Legal and Regulatory obligation can, in some circumstances, limit the
amount of personal or special category data that can be removed from our records.
Who to contact in relation to your Personal Data?
Our Senior Responsible Individual (SRI) is a member of our senior management team and is
responsible for UK data protection compliance. If you have any questions or comments
about this document, or wish to contact us in order to exercise any of your rights or notify us
of an unauthorised disclosure, please contact:
Jeremy Lock Compliance Director by email on compliance@accessfs.co.uk by telephone on
0800 999 3939 or by writing to Access Financial Services Limited, Unit 1 Furtho Court,
Towcester Road, Old Stratford, Milton Keynes, MK19 6AN
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 accordingly.
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 writing to
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF.
By Clicking the Consent Button, you are consenting to us retaining your data for the
purposes outlined above and I have read the Privacy Notice, including my rights to raise
complaints.
Who do we share your personal information with?
We will only share your personal data with third parties when it is necessary to facilitate the
service you have asked us to provide, or if we are required to do so as a legal or regulatory
obligation. We have contracts/safeguards in place to ensure that they comply with the
GDPR and treat the privacy of your personal data with the same importance as we do.
Your Data may be transferred outside of the EEA as part of the normal processing of Data,
but this will only be where necessary and where there are sufficient safeguards in place.