Last Updated: December 2025
1. Who We Are
This Privacy Policy explains how Cathedral Independent Financial Planning Ltd (“we”, “us”, or “our”) collects, uses, stores, and protects your personal information.
Legal Entity: Cathedral Independent Financial Planning Ltd
Registered Office: 11 Mill Road, Cranfield, Bedfordshire
Regulator: Financial Conduct Authority (FCA)
ICO Registration: Z8603756
Website: www.cathedral-ifa.co.uk
Document Reference: CIFP-PP-2025-V1
We act as the Data Controller for the personal data we collect.
2. What Personal Data We Collect
We may collect and process the following categories of data:
| Category | Examples |
|---|---|
| Identity data | Full name, date of birth, national insurance number, marital status |
| Contact data | Address, telephone number, email address |
| Financial data | Income, assets, liabilities, bank details, investment history, pension details |
| Special category data | Health information relevant to insurance or retirement planning (only where necessary and only with explicit consent) |
| Regulatory/Compliance data | Fact-finds, risk assessments, KYC/AML information, suitability letters, advice records |
| Technical data | IP addresses, browser type, cookies, website analytics |
| Communication data | Call recordings (if applicable), email correspondence, meeting notes |
3. How We Collect Your Data
We may collect personal data:
- Directly from you (meetings, forms, calls, email, online submissions)
- Via our website (cookies, contact forms)
- From third parties, such as:
o Product providers and platforms
o Credit reference agencies
o Professional introducers
o Regulators (e.g., HMRC, FCA)
4. Why We Process Your Data and Lawful Basis
We process your data for the following purposes under lawful bases:
| Purpose | Legal Basis |
|---|---|
| Providing financial planning and advice services | Contractual necessity |
| Regulatory compliance (e.g., FCA rules, KYC, AML, HMRC reporting) | Legal obligation |
| Managing and maintaining client files and relationships | Legitimate interests |
| Marketing communications (email, newsletters, event invitations) | Consent (you may withdraw at any time) |
| Processing special category (health) data | Explicit consent |
| Improving website performance and analytics | Legitimate interests / Consent (for optional cookies) |
We also rely on legitimate interests to ensure operational continuity of our services and records. This includes the ability to securely transfer client records to a successor firm in the event of a business sale, merger, or acquisition.
This processing is carried out solely to maintain regulated financial advice records and ongoing client servicing obligations.
Under the Data (Use and Access) Act 2025, we may rely on legitimate interests for certain operational and fraud-prevention purposes where appropriate safeguards are in place.
5. Sharing Your Personal Data
We may share your data with trusted third parties, including:
- Investment and pension providers
- Insurance companies
- Professional advisers (e.g., accountants, solicitors)
- IT, compliance, and secure cloud service providers
- Regulators (FCA, HMRC)
- Financial crime and fraud-prevention bodies
We do not sell or trade your data.
If Cathedral Independent Financial Planning Ltd enters into a merger, acquisition, restructuring, or transfer of business ownership, your personal data may be shared with the acquiring or successor firm as part of our legitimate business interests.
This ensures continuity of regulated financial planning services and preservation of legally required advice records.
Any successor organisation will be required to uphold this Privacy Policy or notify you of any material changes in accordance with UK data protection legislation.
If data is transferred outside the UK, we ensure appropriate safeguards are in place (adequacy decision or International Data Transfer Agreement).
6. How Long We Keep Your Data
We retain data in line with FCA and legal regulatory requirements:
- Advice and suitability records: Minimum 5 years
- Pension transfer, annuity or retirement advice records: Indefinitely
- General client files: Typically 6 years after the end of the client relationship
- Marketing records: Until consent is withdrawn
We may retain certain information longer if required for legal defence, audit, fraud-prevention, or regulatory obligations.
7. Automated Processing or Profiling
If we use any automated systems (e.g., risk-profiling tools), they will not replace human decision-making.
You have the right to request human review under the UK GDPR and the Data (Use and Access) Act 2025.
8. Cookies and Website Tracking
Our website uses essential and optional cookies.
On your first visit, you will be asked whether you wish to accept optional cookies. You may change your cookie preferences at any time in your browser settings.
9. Your Rights
You have the following rights under the UK GDPR and Data Protection Act 2018:
- Right to access your personal data
- Right to rectification of inaccurate data
- Right to erasure (in certain circumstances)
- Right to restrict or object to processing
- Right to portability of certain data
- Right to withdraw consent (where processing relies on consent)
- Right to challenge automated decision-making or profiling
- Right to complain to the Information Commissioner’s Office (ICO)
10. How to Contact Us About Your Data
If you have questions or wish to exercise any rights, please contact:
Data Protection Contact:
Mark Chapman
Email: markchapman@cathedral-ifa.co.uk
Telephone: 01234 752502
11. Complaints
You also have the right to raise a complaint with the Information Commissioner’s Office:
Website: www.ico.org.uk
Telephone: 0303 123 1113
Under the Data (Use and Access) Act 2025, we will acknowledge complaints within 30 days.
12. Updates to This Policy
We may update this policy periodically. Any changes will be posted on our website with an updated revision date.
