MyRetirement is a trading style of Armstrong Watson Financial Planning, who are authorised and regulated by the Financial Conduct Authority. The Armstrong Watson (AW, us, we) group is committed to data security. This privacy notice describes how and why we collect and use personal data; it also provides information about individuals’ rights under current UK data protection laws.

• We define personal data as any information relating to an identified or identifiable living person that is held either electronically or on paper.  
• We use this personal data for various purposes, each purpose will differ in terms of the means of collection, lawful basis of processing, use, disclosure, and retention periods.
• We aim to be transparent about how and why we need to use this data and this privacy notice gives details about our specific process activities.  It applies to personal data provided to us, both by individuals themselves or by others.  
• We may use personal data provided to us for any of the purposes described in this privacy notice or as otherwise stated at the point of collection.

If, at any time, you have concerns or questions about how or why your personal data is being used by us or you wish to report a breach, please don’t hesitate to speak to your partner or relationship manager for more information. Alternatively, the firm has a Privacy team that is headed up by our Head of Privacy, details of how to contact them can be found below.

You have a number of rights regarding the personal data we hold about you, to exercise any of the rights simply email or write to the Privacy team with details of your request. For more information about these rights please visit the ICO (Information Commissioners Office) has a very detailed guide that explains these rights and can be found on their website

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including trackin

The Armstrong Watson group includes MyRetirement, Armstrong Watson LLP, Armstrong Watson Audit Ltd and Armstrong Watson Financial Planning Ltd; regardless of which company in the Armstrong Watson group your query concerns please contact:

Head of Privacy
Armstrong Watson LLP
James Watson House
Rosehill      
Carlisle
CA1 2UU

Email: privacy@armstrongwatson.co.uk
Phone: 01228 690100

Periodically we will review our privacy policy and update this notice to reflect any changes to our processing activities or UK law. This privacy notice was last updated on 22^nd May 2023.

Collection of personal data

We do not require you to provide any information to access the Armstrong Watson website. However, we do ask for some personal information if you wish to download any of the content or the various publications which we make available free of charge or subscribe to receive our online newsletter(s).

We ask that you do not provide sensitive information (such as race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and, criminal records) to us when using our website; if you choose to provide sensitive information to us for any reason, the act of doing so constitutes your explicit consent for us to collect and use that information in the ways described in this privacy notice or as described at the point where you choose to disclose this information.

Cookies

This website uses Google Analytics to help analyse how users use the site. The tool uses “cookies,” which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ us of the website and to compile statistical reports on website activity for Armstrong Watson.

Use of personal data

When a visitor provides personal data to us, we will use it for the purposes for which it was provided to us as stated at point of collection (or as obvious from the context of the collection).  Typically, personal data is collected to:

• subscribe to updates;  
• enquire for further information;
• express interest in an event or publication
• distribute requested reference materials;
• aggregate data for website analytics and improvements.

Unless we are asked not to, we may also use your data to contact you with information about AW’s business, services and events, and other information which may be of interest to you.  Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the appropriate webpage, in our communication to the individual, or the individual may contact us by email to privacy@armstrongwatson.co.uk.

Our websites do not collect or compile personal data for the dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.  If there is an instance where such information may be shared with a party that is not a AW member firm, the visitor will be asked for their consent beforehand.

Data retention

Personal data collected via our websites will be retained by us for as long as it is necessary (e.g. for as long as we have a relationship with the relevant individual)

Security

We take the security of all the data we hold very seriously. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business.  As a result, personal data may be transferred outside the countries where we and our clients are located.  This includes to countries outside the European Union (“EU”) and to countries that do not have laws that provide specific protection for personal data.   We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully.  Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU, such as the European Commission approved standard contractual clauses.  The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

• Other AW member firms
  For details of our member firm locations, please click here. We may share personal data with other AW member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from AW member firms in different territories).  Our business contacts are visible to and used by AW users from other AW member firms to learn more about a contact, client or opportunity they have an interest in (please see the Business contacts section of this privacy notice for more information about our processing of this type of data).

• Third party organisations that provide applications/functionality, data processing or IT services to us
  We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems.  For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services.  The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.

• Third party organisations that otherwise assist us in providing goods, services or information
• Auditors and other professional advisers
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
  Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Access to personal data

You have a right of access to your personal data which held by us as a data controller. This right may be exercised by emailing us at privacy@armstrongwatson.co.uk with details of the data you would like to see. We would usually provide a summary of data held free of charge, however may charge for a request for access in accordance with applicable law if the request is repetitive, manifestly unfounded or excessive. We will aim to respond to any requests for information promptly within 30 days.

Amendment of personal data

We want to keep your data up to date and accurate. Please let us know of any changes by either:

• Emailing us at privacy@armstrongwatson.co.uk
• Speak to your partner or relationship manger
• Via the relevant website registration page or by amending the personal details held on our website

We will make corrections (where appropriate) based on your updated information within 30 days.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  We do not generally process personal data based on consent (as we can usually rely on another legal basis), for example a contractual requirement to deliver a service.  To withdraw consent to our processing of your personal data either:

• Email us at privacy@armstrongwatson.co.uk
• Speak to your partner or relationship manager 
• To stop receiving an email from a AW marketing list, please click on the unsubscribe link in the email you receive from us.  

Other data subject rights

As well as rights of access and amendment referred to above, individuals have other rights in relation to the personal data we hold, such as:

• The right to erasure/deletion
• The right to restrict or object to our processing of personal data
• The right to data portability.  

If you wish to exercise any of these rights, please send an email to privacy@armstrongwatson.co.uk.  

Please note that we may not be able to fulfil a right to be forgotten request if we have other valid reasons for retaining it.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to privacy@armstrongwatson.co.uk.  We will look into and respond to any complaint we receive.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator).  For further information on your rights and how to complain to the ICO, please refer to the ICO website.