Privacy Policy

Website: pwsfinancialsouthport.co.uk
Effective date: 27 July 2026
Last reviewed: 27 July 2026

Privacy Policy Details

1. Introduction to our Privacy Policy

PWS Financial Consulting Limited is committed to protecting your personal information and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share and protect personal information when you:

visit pwsfinancialsouthport.co.uk;
contact us by telephone, email or through an online form;
arrange an initial meeting;
become or apply to become a client;
use our financial planning and advice services;
communicate with us through the PWS Portal or another agreed secure system; or
subscribe to financial news or marketing communications.

We process personal information in accordance with applicable UK data-protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.

The Information Commissioner’s Office requires privacy information to explain, among other things, why personal data is used, the lawful basis relied upon, retention periods, individual rights and how to complain.

2. Who We Are

For the purposes of UK data-protection law, the data controller is:

PWS Financial Consulting Limited
4th Floor, Exchange Station
Tithebarn Street
Liverpool
L2 2QP

Telephone: 01704 827403
Email: stevemilford@pwsfc.co.uk

PWS Financial Consulting Limited is registered in England and Wales under company number 00518502.

Registered office:
Butterworth Barlow House
10 Derby Street
Prescot
L34 3LG

Companies House records PWS Financial Consulting Limited as an active private limited company registered at the above address.

PWS Financial Consulting Limited is authorised and regulated by the Financial Conduct Authority.

3. Personal Information We May Collect

The information we collect will depend on your relationship with us and the services you request.

Information you provide directly

This may include:

your name, title and contact details;
postal address, email address and telephone number;
date of birth and National Insurance number;
marital status and family circumstances;
identity-verification documents;
employment and business information;
income, expenditure, assets and liabilities;
pension, investment, savings and protection details;
bank-account information;
tax status and tax-related information;
financial objectives and priorities;
investment knowledge and experience;
attitude to investment risk and capacity for loss;
details of beneficiaries, dependants, attorneys or representatives;
correspondence, meeting notes and telephone records;
complaints, enquiries and service requests;
information submitted through our website, forms or secure portal; and
marketing preferences.

Financial-services customer information may include identifiable details such as dates of birth, addresses, National Insurance records, bank details, family circumstances and medical information.

Information obtained from other sources

Where appropriate, we may receive information from:

pension, investment and insurance providers;
platforms and product providers;
your employer or pension-scheme administrator;
solicitors, accountants and tax advisers;
trustees, attorneys, executors or family representatives;
credit-reference or electronic identity-verification services;
fraud-prevention and anti-money-laundering databases;
publicly available registers and records;
professional introducers;
the Financial Conduct Authority or other regulatory bodies; and
other organisations where you have authorised disclosure.

Website and technical information

When you use our website, we may collect:

your Internet Protocol address;
browser and device type;
operating system;
referring website;
pages viewed;
the date and time of your visit;
approximate location derived from your IP address;
cookie identifiers;
website interaction and performance information; and
security and diagnostic information.

Further details about cookies should be provided in our separate Cookie Policy.

4. Special Category and Sensitive Information

Financial advice may require us to understand information that is particularly sensitive.

This could include information about:

physical or mental health;
disabilities or accessibility requirements;
bereavement;
cognitive or communication difficulties;
vulnerability or additional support needs;
religious beliefs where relevant to ethical investment preferences;
biometric information used for identity verification; or
criminal allegations or convictions where relevant to legal or regulatory checks.

We will only collect sensitive information where it is relevant and necessary.

We may process information about vulnerable circumstances to understand a client’s needs, provide appropriate support and help achieve fair outcomes. The FCA and ICO have stated that firms should clearly explain this purpose in their privacy information and take reasonable steps to ensure such information remains accurate.

Where required, we will rely on an appropriate condition under data-protection law, such as:

your explicit consent;
the establishment, exercise or defence of legal claims;
substantial public interest;
safeguarding economic wellbeing;
preventing fraud;
meeting regulatory obligations; or
protecting your vital interests.

You may withdraw explicit consent where consent is the lawful basis, although this will not affect processing that took place before withdrawal.

5. Why We Use Personal Information

We may use personal information to:

respond to enquiries;
arrange meetings;
identify and verify clients;
carry out anti-money-laundering and fraud-prevention checks;
understand your circumstances, objectives and financial needs;
assess investment knowledge, experience, risk and capacity for loss;
prepare financial plans and recommendations;
arrange pensions, investments, protection policies and other products;
communicate with product providers and professional advisers;
administer and review your financial arrangements;
provide ongoing advice and client support;
process withdrawals, contributions, transfers and other authorised instructions;
maintain accurate client and regulatory records;
meet legal, tax, regulatory and compliance obligations;
deal with complaints or legal claims;
identify and support clients in vulnerable circumstances;
protect our website, systems, staff and clients;
improve our services and website;
manage our business;
send marketing communications where permitted; and
establish, exercise or defend legal rights.

We will not use personal information for a purpose that is incompatible with the reason it was collected unless the law permits or requires us to do so.

6. Our Lawful Bases

We must identify a lawful basis before processing personal data and explain that basis in our privacy information.

Depending on the circumstances, we may rely on one or more of the following lawful bases.

Contract

Processing may be necessary to:

take steps at your request before entering into a contract;
provide agreed financial advice or planning services;
administer your client relationship; or
perform our obligations under our terms of business.

Legal obligation

We may process information to comply with obligations relating to:

financial-services regulation;
anti-money-laundering requirements;
fraud prevention;
financial sanctions;
record keeping;
taxation;
complaints handling;
regulatory reporting;
court orders; and
other applicable laws.

Legitimate interests

We may process information where it is necessary for our legitimate business interests, provided those interests are not overridden by your rights.

These interests may include:

managing and improving our business;
maintaining client relationships;
keeping appropriate records;
protecting against fraud and cybercrime;
securing our website and systems;
responding to enquiries;
ensuring service quality;
establishing or defending legal claims; and
sending limited business communications to existing clients where legally permitted.

We may rely on consent for activities such as:

certain electronic marketing communications;
non-essential website cookies;
recording sensitive information where explicit consent is appropriate; or
sharing information where no other lawful basis applies.

You may withdraw consent at any time.

Substantial public interest

Where permitted by law, we may process sensitive information for reasons such as:

preventing or detecting unlawful acts;
fraud prevention;
safeguarding economic wellbeing;
regulatory requirements; or
supporting people in vulnerable circumstances.

Vital interests

In rare circumstances, we may use personal information where necessary to protect someone’s life or physical safety.

7. What Happens if You Do Not Provide Information?

You are not generally required to provide personal information merely to browse our website.

However, if you ask us to provide regulated financial advice or another service, we may need information to:

verify your identity;
comply with anti-money-laundering rules;
understand your circumstances;
assess suitability;
provide an appropriate recommendation; and
fulfil legal and regulatory obligations.

If required information is not provided, we may be unable to advise you, arrange a financial product, act on an instruction or continue providing a service.

We may share personal information where necessary with:

PWS Financial Consulting staff and authorised representatives;
financial advisers and support staff;
pension, investment, platform and insurance providers;
custodians and investment managers;
paraplanning, administration or compliance providers;
identity-verification, fraud-prevention and anti-money-laundering services;
professional indemnity insurers;
technology, hosting and secure-portal providers;
document-storage and records-management providers;
solicitors, accountants, tax advisers and other professional advisers;
your appointed attorney, trustee, executor or authorised representative;
regulators, ombudsmen, courts and law-enforcement agencies;
HM Revenue & Customs and other public authorities;
prospective purchasers or successors in the event of a business transfer; and
other organisations where you have authorised us to share information.

We require service providers handling personal information on our behalf to protect it and use it only for authorised purposes.

We do not sell personal information to advertisers or unrelated third parties.

9. Fraud Prevention and Identity Verification

We may use personal information to:

confirm your identity;
prevent fraud;
meet anti-money-laundering obligations;
check financial sanctions;
protect clients and our business; and
investigate suspicious activity.

This may involve checking information against public records and databases maintained by fraud-prevention, identity-verification, sanctions or credit-reference organisations.

Where required by law, we may disclose information without first notifying you.

10. International Transfers

Some organisations supporting our website, communications, secure systems or financial services may process information outside the United Kingdom.

Where personal information is transferred internationally, we will take reasonable steps to ensure that appropriate safeguards are in place.

These may include:

transferring information to a country recognised as providing adequate protection;
using approved contractual safeguards;
applying the UK International Data Transfer Agreement;
using an approved UK addendum to standard contractual clauses; or
relying on another lawful transfer mechanism.

You may contact us for further information about safeguards used for relevant transfers.

11. Data Security

We use appropriate organisational and technical measures intended to protect personal information from:

accidental loss;
unauthorised access;
alteration;
disclosure;
destruction;
misuse; and
cyberattack.

Measures may include:

access controls;
password protection;
multifactor authentication;
encryption;
secure portals;
staff training;
system monitoring;
data backups;
supplier checks; and
incident-response procedures.

No internet or electronic-storage system can be guaranteed as completely secure.

Certain personal-data breaches must be reported to the ICO within 72 hours of an organisation becoming aware of them, where feasible. Individuals must also be informed without undue delay where a breach is likely to create a high risk to their rights and freedoms.

12. Secure Communications

Please do not send highly sensitive information through a general website form or ordinary email unless we have agreed that this is appropriate.

This includes:

passwords;
full bank-account information;
payment-card details;
National Insurance numbers;
identification documents;
medical documents; and
portal login credentials.

Existing clients should use the PWS Portal or another agreed secure communication method when submitting confidential documents or financial instructions.

We may contact you to confirm your identity before acting upon an instruction.

13. How Long We Keep Personal Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy legal, regulatory, accounting, tax, complaint-handling and reporting obligations.

Retention periods will vary according to the type of information and service involved.

When determining a retention period, we may consider:

the nature and sensitivity of the information;
the services provided;
FCA and other regulatory requirements;
anti-money-laundering obligations;
limitation periods for complaints or legal claims;
whether an ongoing client relationship exists;
the risk of harm from unauthorised use or disclosure; and
whether continued retention remains necessary.

Some financial-advice and transaction records may need to be retained for lengthy periods or indefinitely where required by regulation, the nature of the advice or potential future complaints.

Website enquiry information that does not lead to a client relationship will normally be retained for a shorter period.

When information is no longer required, it will be securely deleted, anonymised or destroyed.

14. Marketing Communications

We may send information about our services, financial updates, events or newsletters where:

you have consented;
you are an existing client and the law permits us to contact you; or
another lawful basis applies.

Marketing consent is optional and should be separate from consent needed for us to respond to an enquiry.

You can stop marketing communications at any time by:

using an unsubscribe link;
emailing stevemilford@pwsfc.co.uk;
telephoning 01704 827403; or
updating your communication preferences with us.

Opting out of marketing will not prevent us from sending necessary service, regulatory or administrative communications.

We do not sell personal information for third-party marketing.

15. Cookies and Website Analytics

Our website may use cookies and similar technologies to:

operate essential website features;
remember preferences;
maintain security;
understand website usage;
measure website performance; and
support marketing where consent has been given.

Non-essential cookies should not be used until you have provided consent where consent is legally required.

You can review or update your choices through the website’s cookie settings.

Please refer to our separate Cookie Policy for details of the cookies used, their providers, purposes and duration.

The ICO advises that privacy and cookie information should be easy to understand, transparent and readily accessible.

16. Links to Other Websites

Our website may contain links to third-party websites, including:

financial providers;
government bodies;
regulators;
professional organisations;
secure portals; and
other external services.

We do not control third-party websites and are not responsible for their privacy practices.

You should read the privacy information provided by each external website before submitting personal information.

17. Children’s Information

Our services and website are not generally directed at children.

We may process a child’s information where relevant to a parent’s, guardian’s, trustee’s or family’s financial planning. For example, this may relate to:

Junior ISAs;
trusts;
pensions;
investments;
protection;
school-fee planning; or
family estate planning.

Where children’s information is required, we will take reasonable steps to ensure it is collected and used lawfully and appropriately.

18. Automated Decision-Making

We do not normally make decisions that have legal or similarly significant effects upon individuals using solely automated processing.

We may use digital systems, risk questionnaires or provider tools to support:

identity verification;
fraud prevention;
risk assessment;
financial modelling; or
suitability analysis.

However, these tools do not replace the professional judgement and assessment required when providing personal financial advice.

We will explain where solely automated decision-making is used and where the law requires us to do so.

19. Your Data-Protection Rights

Depending on the circumstances, you may have the right to:

Be informed

You have the right to receive clear information about how your personal information is used.

Access your information

You may request a copy of the personal information we hold about you.

Correct inaccurate information

You may ask us to correct inaccurate or incomplete personal information.

Request erasure

You may ask us to delete personal information in certain circumstances.

This right does not apply where we must retain information to meet legal or regulatory obligations or to establish, exercise or defend legal claims.

Restrict processing

You may ask us to restrict how we use personal information in certain circumstances.

Object to processing

You may object to processing based on legitimate interests or to the use of personal information for direct marketing.

Data portability

In certain circumstances, you may ask us to provide information in a structured, commonly used and machine-readable format or transfer it to another organisation.

Where we rely on consent, you may withdraw it at any time.

Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.

Challenge automated decisions

You may have rights in relation to decisions based solely on automated processing that significantly affect you.

Complain

You may raise concerns with us or complain to the Information Commissioner’s Office.

A privacy notice should explain individual rights, including the right to withdraw consent where consent is relied upon, and how to make a complaint.

20. Exercising Your Rights

To exercise a data-protection right, contact:

Email: stevemilford@pwsfc.co.uk
Telephone: 01704 827403

Postal address:
PWS Financial Consulting Limited
4th Floor, Exchange Station
Tithebarn Street
Liverpool
L2 2QP

We may need to verify your identity before fulfilling a request.

Data-protection requests will normally be dealt with without charge. However, the law may permit a reasonable fee or allow us to refuse a request where it is manifestly unfounded or excessive.

We will respond within the legally required period and explain any permitted extension.

21. Complaints to the Information Commissioner

We would appreciate the opportunity to address your concerns first.

You also have the right to complain to the UK supervisory authority:

Information Commissioner’s Office

The ICO provides current contact and complaint information through its official website.

ICO guidance states that UK organisations should tell people that they can complain to the ICO and provide the regulator’s contact details.

Making a complaint to us does not affect your right to contact the ICO.

22. Changes to This Privacy Policy

We may amend this Privacy Policy to reflect changes in:

legislation or regulation;
our financial services;
business practices;
website functionality;
technology;
service providers; or
security arrangements.

The updated policy will be published on this page with a revised review date.

Material changes may also be communicated directly where appropriate.

23. Contact Us

Questions about this Privacy Policy or our use of personal information should be directed to: