Privacy Policy


At Watson Financial Ltd we respect your privacy and the confidentiality of your personal


Watson Financial Ltd is an appointed representative of Quilter Financial Limited

who is part of the Quilter Group of companies.

For further details on the companies in our group, please visit


This Privacy Notice explains:
• Who we are
• What personal information we collect
• How we use your personal information
• Who we share your information with and why
• How we keep your information secure
• Your rights
• How to contact us


Watson Financial Ltd provide financial planning solutions and advice through experienced and

qualified advisers based in the UK. Currently, Watson Financial Ltd and Quilter Financial Planning

(Quilter) jointly determine the purposes and means of processing personal client data relating to

giving advice. This means we’re joint data controllers for these core advice giving activities and are,

therefore, responsible for managing this client data and ensuring compliance.

However, Watson Financial Ltd is solely responsible for some activities, for example any direct
marketing that we undertake.


Personal information includes your name, address, or phone number and other information that
isn’t otherwise publicly available. We collect personal information about you when you contact us
about products and services, visit a financial advisor, visit a website we may have or register to
receive one of our newsletters (if applicable).

The type of personal information we collect will depend on the purpose for which it’s collected
and includes:
• Contact details
• Information to verify your identity
• Family, lifestyle, health and financial information
• Payment details

We collect personal information directly from you.  For example, we ask for personal information at

the start of our relationship and in subsequent communications, in order to check your identity and

protect you from fraud. This is a legal requirement and is important to help safeguard you against
potential crime.

Special category information

In some instances, it’s necessary to collect more sensitive information (such as health or lifestyle
information) which is called special category data. This is to allow us to provide our financial
advice service to you. We’ll always obtain your consent during the advice process to gather this
data and explain what information we require and why it’s needed. Sensitive personal information
will always be processed and stored securely. You can withdraw your consent at any time to us
processing this data, however, this may mean that you can no longer access the service or
product the information was gathered for.


We also collect information about you from other sources. For example, our website automatically
collects information from your computer using “cookies” which provides us with limited personal
information. Cookies are small text files that are placed on your computer by websites that you
visit. They’re widely used in order to make websites work, or work more efficiently, as well as to
provide information to the website owners. For further information visit or

You can set your browser not to accept cookies and the above websites tell you how to remove
cookies from your browser. However, in a few cases, some of our website features may not function
as a result.

Data retention

We keep your personal information only as long as is necessary for the purpose for which it was
collected and to meet regulatory or legislative requirements. Personal information will be securely
disposed of when it’s no longer required, in accordance with our Data Retention and Disposal
Schedule. A copy of this is available from the How to Contact Us address, below.


The processing of your personal data is allowed under a number of lawful basis. The data required
for the provision of products and services is processed on the basis there’s a contract with you to
do so. Any relevant marketing activity we undertake is done because as a firm, we have a
legitimate interest to do so. However, you have rights, as listed below, which impact how we can
use and process your data.


We process your information in order to support and maintain our contractual relationship with you
and to comply with legal and regulatory requirements. This includes the following:
• Providing our advice, products or services to you
• Carrying out transactions you have requested
• Confirming and verifying your identity for security purposes
• Credit scoring and assessment, and credit management (where applicable)
• Detecting and preventing fraud, crime, money laundering or other malpractice.

We also process your data for specific business purposes to enable us to give you the best products
and services and the best and most secure experience. For example, we process your information
to send you marketing that is tailored to your interests.

Our business purposes include the following:
• Enhancing, modifying, and personalizing our services for the benefit of our customers
• Providing communications which we think will be of interest to you
• Market or customer satisfaction research or statistical analysis
• Audit and record keeping purposes
• Enhancing the security of our network and information systems.

You have the right to object to this processing if you wish, please see “YOUR RIGHTS” section below.
Please bear in mind that if you object, this may affect our ability to carry out the tasks above for
your benefit.

We may also process your personal data as part of an acquisition or sale. Should this happen,
you’ll be notified about any change to processing or data controller arising as a result of this


We share your information with trusted third parties who perform tasks for us and help us to provide
the services you require these include:
• Quilter Financial Planning Limited
• Other adviser firms in the network for the purpose of providing you with advice (with your
• The Quilter Group of companies to enhance the services and products we can offer you
• Third parties to verify your identity, in line with money laundering or other requirements (this
may involve carrying out checks with credit reference databases)
• Third parties who perform tasks for us to help us set up or service your plan (these third
parties may be based in countries outside the European Economic Area (EEA) but where
they are, we’ll undertake an assessment of safeguards in place)
• Other organisations, including regulatory bodies, the police and fraud prevention agencies,
to prevent and detect fraud
• Third parties where required by law, court order or regulation
• Third parties as part of an acquisition or sale.


We’re committed to ensuring the confidentiality of the personal information that we hold and we
continue to review our security controls and related policies and procedures to ensure that your
personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality
obligations on them to ensure that personal information is kept secure.
If we work with third parties in countries outside the EU, we ensure these are countries that the
European Commission has confirmed have an adequate level of protection for personal
information, or the organisation receiving the personal data has provided adequate safeguards.
In limited circumstances, data may be accessed outside of the EEA i.e. by employees when they
travel. In these circumstances, we ensure there are appropriate information security measures in
place to safeguard your information.

Your rights

Watson Financial Ltd tries to be as open as it can be in terms of giving people access to their
personal information and, therefore, have outlined your rights below. This privacy notice was
drafted with brevity and clarity in mind, therefore further information can be gathered by
contacting us using the details below, or more information about your data protection rights can

be found here:



You have the right to opt out of marketing information and tell us what your communication
preferences are by contacting Quilter Financial Planning using the details provided at the end of
this notice, or by using the opt out option below or on any email marketing. You may opt out at
any time if you don’t want to receive any further communications of this nature.

Individual data rights and requests
• The right to be informed – You can request that we provide ‘fair processing information’,
typically through this privacy notice
• The right of access – You may request a copy of the personal information we hold about
you using the contact details found on the end of this policy
• The right to rectification – The accuracy of your personal information is important to us. You
have the right to ask us to update or correct your personal information
• The right to erasure – You may request the deletion or removal of personal data where
there’s no compelling reason for its continued processing
• The right to object – You may object to the processing of your data based on legitimate
• The right to restrict processing – You have a right to request we ‘block’ or suppress
processing of your personal data
• The right to data portability – You may request to obtain and reuse your data
• The right not to be subject to automated decision-making including profiling.
If you wish to correct, restrict, delete or make changes to your personal information, or any of the
data subject rights listed above, please contact us at the number/address listed below.


If you have questions about this notice, need further information about our privacy practices, or
wish to give or withdraw consent, exercise preferences or correct your personal information, please
contact us using the following details. Quilter will liaise with Watson Financial Ltd on your behalf to
affect your requests.

The Office of Data Protection
Quilter Financial Planning Limited
Wiltshire Court
Farnsby Street
Swindon SN1 5AH
Telephone: 0161 488 3559


If you wish to raise a complaint about how we have handled your personal data, you can contact
The Office of Data Protection who will investigate the matter.
If you’re not satisfied with our response, or believe we’re not processing your personal data in
accordance with the law, you can complain to our regulator:

Information Governance department
Information Commissioner’s Office
Wycliffe House
Water Lane
0303 123 1113