We are Oxford Risk Research & Analysis Ltd, a company based in the UK that builds software for wealth managers and financial advisers, to help investors to make better decisions. We were founded by academics at the University of Oxford, but now we run largely independently. Our company number is 04571309, and our registered address is 57 Woodstock Road, Oxford, OX2 6HJ.
If you would like to get in touch about anything in this notice, please email firstname.lastname@example.org and we will be happy to help you.
Purpose and legal basis for processing
When you receive financial advice, your adviser needs to make sure that they are telling you to do something suitable and appropriate for your personal circumstances. This is true whether your adviser is one person you meet with face to face, various people who work for a company like a bank, or a digital service or app. In many places around the world, measuring suitability of financial advice is a legal requirement.
Our company, Oxford Risk, makes tools that help your adviser and/or investment provider comply with this requirement. Our products can help find the right thing to do with your money, and they can help your adviser understand how you approach financial decisions.
We have entered into a contract with your adviser (or their employer) to provide our tools to them, and our legal basis for processing your data is to fulfil our contractual obligations. We also process your data for our legitimate interests in providing and developing tools that help guide you and people like you to make decisions that improve your financial wellbeing.
What data do we need?
When you use one of our tools, we collect the information you or your adviser provide to us, which may include information about your personality, your attitudes, your decision-making style, your financial situation, and your understanding of investing. Your adviser may also send us your full name, email address and other contact information, your date of birth, and your sex/gender.
Why do we need it?
Information about your personality, attitudes and decision-making style help us identify the level of risk you are willing to take with your money, your financial wellbeing, and other important traits that will help your adviser serve you better. Information about your financial situation help us figure out what you should do with your money. Information about your attitudes and your understanding of investing help us determine what financial products might be suitable (or unsuitable) for you.
What do we do with it?
We use the information you provide about your personality and attitudes to score you on various traits, and then present these results to your adviser to help them understand and predict your behaviour.
We use the financial information you provide to estimate your total net wealth, how affordable your future plans are, and what you should do with your savings and investments. We might also use your sex/gender and your date of birth when making these calculations.
We use the information about your knowledge and understanding to identify any areas where you might need more advice or guidance before making a decision.
Altogether, this data helps your adviser make a personalised recommendation to you.
If you (or your adviser) provide us with your name, email address, phone number or mailing address, we store this information to make it easier for your adviser to use our website (for example, by displaying your name instead of an ID number). We may also use your name and email address to send personalised invitations to update your details on our system.
We do not make any automated decisions on the basis of the data you provide, though your adviser may use our tools to make an automated decision about you. If you’re concerned about this aspect of profiling, you should speak with your adviser.
Depending on our contract with your adviser, we may also use the data your provide to put you into a group of similar people (such as, ‘women with at least £5000 in savings’ or ‘people who own more than one home’), and then look at general trends that might help us develop new tools for financial advisers.
How long do we keep it?
Your adviser is the controller of your data, and we process it according to their instructions. This means we keep your data until your adviser tells us to delete it. Usually this means we will hold onto your data for as long as you keep seeing your adviser, and then for 7 years after you end your relationship with them (because they have a legal obligation to preserve your records for that long).
What are your rights?
If you are a citizen of the European Union (including citizens of the UK until 31/12/2020), you have several rights guaranteed under the General Data Protection Regulation. If you would like to discuss any of the rights below, we ask that you first contact your adviser because they have the ultimate responsibility in deciding what information we process about you.
In certain cases, we may only hold “pseudonymised” data about you, which means that we have your personality and financial data, but we don’t have any information that personally identifies you. Therefore, it may not be possible for us to locate your data even with the help of your adviser.
If you would like to get in touch with us directly, please email email@example.com.
You have the right to see the data we hold about you. Please contact your adviser and ask them to initiate a “subject access request” on your behalf.
You have the right to correct or augment any data that is inaccurate or incomplete. You can ask your adviser to rectify any of the information we hold, or you may be able to rectify errors yourself while completing our questionnaires.
You have the right to ask us to erase the information we hold about you, however this right may be overridden by your adviser’s legal obligations to maintain complete records.
You have the right to ask us to restrict the processing of your personal data under certain circumstances. For example, you may elect to submit only pseudonymised data to our service, and not include any personal or contact information.
You have the right to object to our processing of your data; however, objecting may limit the services that your adviser can offer you, so you should discuss this with them.
Do we use any data processors?
No. The data you or your adviser provides to us is kept secret and safe on our systems, and we won’t send it to anyone without permission from you or your adviser.
Do we transfer any data overseas?
For most people, our data processing and storage takes place in the European Economic Area (including the UK and the EU). If your adviser is not based in the EEA, there is a good chance that we set up operations closer to them. If you are concerned about international data transfers, you should talk to your adviser.
What if you have concerns or want to make a complaint?
If you have concerns about how we process your data, we recommend you get in touch with your adviser first, because they are the ultimate controller of what we can do with your data. If you would like to get in touch with us directly, we will be happy to hear from you at firstname.lastname@example.org.
If you have a serious concern or you would like to make a complaint, please get in touch with the UK Information Commissioners Office (ICO).
Phone: 0303 123 1113