PLEASE READ THIS PRIVACY POLICY IF YOU’RE AN ADVISER OR AN ADVISER REPRESENTATIVE

If you’re a customer, please read our customer privacy policy.

Privacy policy

Protecting your personal information

The Data Protection Act requires us to manage personal information in line with the data protection principles. In particular, we need to process your personal information fairly and lawfully. We collect, hold and use your personal data, and you’re entitled to know how we intend to use any information you give us.

As employees, we're personally responsible for keeping your information confidential. We're all given training and education to remind us about our obligations. Our policies and procedures are also regularly audited and reviewed.

Please read this privacy policy carefully as you'll be legally bound by it. We reserve the right to amend it at any time and to let you know by posting an updated version on our website. You'll be deemed to have accepted the amendments by continuing to sell our products, use our websites and submit your information to us.

Any reference to ‘we', ‘us' or ‘our' means Guardian Financial Services Limited as an appointed representative of Scottish Friendly Assurance Society Limited.


Who we are

Guardian Financial Services Limited is an appointed representative of Scottish Friendly Assurance Society Limited which is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and Prudential Regulation Authority. Registered office: Scottish Friendly House, 16 Blythswood Square, Glasgow G2 4HJ. Registration number 110002.

Guardian Financial Services Limited is registered in England and Wales under number 11115769. Registered office: 11 Strand, London WC2N 5HR.


Where we get your information and how we use it

We'll hold your personal information securely in our systems so that we, either now or in the future, can manage your relationship with us.

We’ll collect information that you, your firm or your network give us as part of the process of developing and maintaining our business relationship with you. This includes:

  1. Information we receive from you and your firm or network during and following the establishment of our terms of business or working relationship.
  2. Information we receive from or through other organisations (such as other insurance companies, credit reference agencies, anti-money laundering and fraud prevention agencies) whether in the course of providing or receiving products and services, and from information we gather from your use of and interaction with our internet and mobile services and the devices you use to access them.
  3. Information available to us from open sources and other data providers that we have legitimate interest in using to initiate or develop our business relationships.

We may use and share the personal information we hold about you for the following administrative activities:

  1. Providing you with products and services, and letting you know about important changes or developments to the features and operation of those products and services.
  2. Responding to your enquiries and complaints.
  3. Administering offers, competitions and promotions.
  4. Facilitating secure access to our online platforms.
  5. Providing information about how our products and services change.

And also for the following activities:

  1. Updating, consolidating and improving the accuracy of our records.
  2. Testing new systems and checking upgrades to existing systems.
  3. Detecting, preventing and prosecuting crime.
  4. Evaluating the effectiveness of marketing, and for market research and training.
  5. Customer modelling and statistical and trend analysis with the aim of developing and improving products and services.
  6. Assessing insurance risks.
  7. Managing your relationship with us.

We won't keep your personal information for longer than necessary for conducting our business relationship, or for legal or regulatory requirements.


When we may share your information

We'll treat your personal information as private and confidential, but may share it with each other and disclose it outside Guardian if:

  1. Allowed by this agreement.
  2. You consent.
  3. Needed by our agents, advisers or others involved in running products and services for you or collecting what you owe.
  4. Needed by subcontractors to help us manage your records.
  5. HM Revenue & Customs or other authorities require it.
  6. The law, regulatory bodies (including for research purposes), or the public interest permits or requires it.
  7. Required by us or others to investigate or prevent crime.

We'll always make sure your information remains safe and secure.


Sharing your information with other companies

So that we can provide you with services and carry out the activities described above, your data may be processed by the following organisations:

  • Equifax
  • Experian
  • Genesys Inc
  • GenRe Reinsurance
  • Hannover Re Reinsurance
  • Infor UK Ltd
  • LISS Systems Ltd
  • Make Positive Ltd
  • Medical Screening Solutions Ltd
  • Microsoft Inc
  • Red Arc Assured Ltd
  • Salesforce Inc
  • Scottish Friendly Assurance Society Limited
  • Space01 (MBPA) Ltd
  • TIG Ltd
  • Xalient Ltd

This list may be updated from time to time.


Sharing your information to help with asset buying or selling

We may in the future wish to sell, transfer or merge part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, we may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyer, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.


Using your details to contact you

Making sure we deliver great customer service is very important to us. To do this, we use various methods of communication when sending you information. Most of the time we'll contact you by email. We may also send updates by letter when we believe it to be appropriate.

If you send us emails from your personal account, please remember that the information may not be secure and there's a risk that it could be intercepted. We can't provide the same levels of protection to information provided in an email to that submitted through recommended channels such as your secure online account. So if you choose to send an ‘insecure' email, you should keep the amount of confidential information you include to a minimum.


Recording phone calls and webchat sessions

We may monitor or record our phone calls and webchat sessions with you. We do this in case we need to check we've carried out your instructions correctly, to answer questions or resolve issues, for regulatory purposes, to help improve the quality of our service, and to help detect or prevent fraud or other crimes. We may also monitor conversations for training purposes.


Getting a copy of your information

Under the Data Protection Act you have the right of access to your personal data. If anything is inaccurate or incorrect, please let us know and we'll fix it. For details on how to request a copy of your information, please contact us on:


Using your personal information to contact you about products and services

We'll use your personal information to give you product details and offers that are more relevant to you. We may carry on doing this after your relationship with us ends.

We might contact you by mail, phone, email, or text message unless you've asked us not to. We may also display personalised messages when you use our internet and mobile services. You can change your preferences at any time by calling us or emailing us.

You can opt out of receiving this information at any time contacting us on:


Passing your information to other companies for their own direct marketing

Unless you've given us your consent, we won't give information about you to other companies to use for their marketing purposes.


Viewing notifications

Organisations must lodge a notification with their regulator describing what they process personal information for. The details are publicly available from the regulator's office and you can view ours at ico.org.uk/esdwebpages/search


Updates

We keep our privacy policy under regular review and we'll reflect any updates in this notice. It was last updated in May 2018.