Privacy and data

Regulation and compliance

We are fully regulated by the FCA and take responsibility for our advice

Wealth Wizards Benefits Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference 596641. Registered Address: Wizards House, 8 Athena Court, Tachbrook Park, Leamington Spa, CV34 6RT.

Our registered address is:

Wealth Wizards Benefits Limited
Wizards House
8 Athena Court
Tachbrook Park
Leamington Spa
CV34 6RT


If you’re unhappy with the experience you have with Wealth Wizards Benefits Limited we’d like to put it right for you. Please let us know if you want to make a complaint by writing to us or dropping us an email.

If you’re still unhappy with the outcome of your complaint, you have the right to contact the Financial Ombudsman Service (FOS). The FOS is a statutory body established to provide consumers with a free, independent service for resolving disputes with financial firms. Their decisions are binding on us. You can visit the FOS website for further information.


You may be entitled to compensation from the Financial Services Compensation Scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. Further information is available from the FSCS.

Terms of use

This website is provided by Wealth Wizards Benefits Limited which is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference 596641, and registered in England & Wales Company No 06030782. Wealth Wizards® is registered as a trading style of Wealth Wizards Benefits Limited with the Financial Conduct Authority.

These terms should be read carefully. Access to this website is on the basis that you agree to these terms.

Our services are intended for customers in the United Kingdom. Services featured on the website do not amount to an invitation to customers outside the United Kingdom.

The website and these terms are governed by the law of England and Wales.

We try to ensure that our website is available for access 24 hours a day, 7 days a week. However it may, on occasions be necessary to close or suspend provision of any of the services on the website for the purposes of repair, maintenance or development. Access to the website or operation of any of the services may be interrupted by circumstances beyond our control.

Wealth Wizards Benefits Limited takes care to ensure that the contents of this website are as clear, accurate and as easy to use as possible, but cannot accept responsibility (to the extent permitted by law) for any interruption or delay in access to the website or for any inaccuracies, incompleteness of information, errors or omissions in respect of information on our website or on any to which our website may be linked. The information is subject to change at any time without notice and Wealth Wizards Benefits Limited does not warrant that any of the services mentioned on the website are available. No warranty is given as to the freedom of this website from errors, defects or viruses.

If you request one of our email services you acknowledge that email is not completely secure or confidential and agree to that risk. We do not routinely encrypt emails.  We do adhere to a rigorous Privacy Policy and we make all reasonable endeavours to keep your information confidential.

Parts of our website are provided by third parties. We try to ensure that our sources of information are reputable and that they take due care in preparing the information. However, we do not verify the information ourselves, and we do not guarantee that it is correct. We are also not responsible for any information on this site or any site linked to this site which is being marketed by a third party.

Wealth Wizards Benefits Limited cannot be held responsible for the accuracy of the contents or information contained within any linked sites accessible from this site.

This site and the material and brands on it are the intellectual property of Wealth Wizards Limited and Wealth Wizards Benefits Limited, and all resulting rights are reserved; no right or license is granted to use such intellectual property, save for the purposes of reviewing the website. Wealth Wizards®, Pension Wizard ®, Retirement Wizard ® and the wizard hat logo are registered trademarks; the trademarks, trade names, and logos on this website, and the copyright and pending patent applications are used by Wealth Wizards Benefits Limited under licence from Wealth Wizards Limited. Pension Tidy-up, Pension Predictor, Money Wizard, Advisor Wizard, Mortgage Wizard, Protection Wizard, Investor Wizard,  Investment Wizard, Insurance Wizard, and ISA Wizard are trademarks and logos of Wealth Wizards Limited. © 2016 Wealth Wizards Limited. Wealth Wizards Benefits Limited is a wholly owned subsidiary of Wealth Wizards Limited.

This page was last updated on 1st January 2019

Privacy policy

Wealth Wizards takes the protection of your data seriously and is committed to safeguarding your personal information.  This Privacy Policy explains the data processing practices relating to the websites: and and any further interactions you may have with our business development teams.  Should you provide information by which you can be identified when interacting with us, it will only be used in accordance with this Privacy Policy.

We ask that you read our Privacy Policy carefully as it contains important information about Wealth Wizards; how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and the supervisory authority in the event you have a problem or complaint. 

About Wealth Wizards

Wealth Wizards collects, uses and retains certain personal data about you.  Wealth Wizards is required to comply with data protection regulation, and we are responsible as a data controller of that personal data for the purposes of those laws.

When we mention “Wealth Wizards”, “Turo” “we”, “us” or “our” we are referring to Wealth Wizards Ltd. There are many ways you can contact us, including by telephone, email and post.

Registered Office:

Wizards House
8 Athena Court
Tachbrook Park
Leamington Spa
CV34 6RT

Helpline Number: 01926 671 469


Company No: 07014133, Data Protection Registration No: ZA547627.

What information may we collect from you?

We do not automatically capture or store personal information, other than logging your IP address and session information such as how long your visit lasted, and the type of browser used.  This is recognised by the web server and is only used for system administration purposes and to provide statistics, which we use to evaluate how the site is used, we also use Google Analytics.  Please read our Cookie Policy for more information.  Our Cookie Policy describes what information we gather, how we use them and why we sometimes need to store these cookies.  We will also share how you can prevent these cookies from being stored, however this may downgrade or disrupt certain elements of the website’s functionality.

Wealth Wizards collects personally identifiable information about you through:

  • The use of enquiry and registration forms.
  • The provision of your details to us either online or offline.
  • The provision of your details supplied to us by your organisation.

In the course of providing our services to you we may collect the following personal data when you provide it:

  • Contact information
  • Identity information
  • Demographic information
  • Information relevant to customer surveys

 The elements of your data that we collect may include:

  • Name
  • Job title
  • Company name
  • Company address, telephone and email address
  • Mobile telephone number

How Wealth Wizards uses and shares your personal data

We will only ask you to provide us with a limited amount of personal information needed to provide the service you are interested in, for example where you:

  • decide that you would like to book a meeting/demonstration with one of our sales team.
  • sign up to receive our latest newsletters or publications.
  • complete a survey on our website.
  • attend an event.

We require this information to understand the latest needs and provide you with a better service, and for the following reasons:

  • for internal record keeping.
  • to use the information internally to improve our products, services and communications.
  • to periodically send emails about new developments or other information which we think you may find interesting using the email address which you have provided.
  • to contact you for market research purposes from time to time, we may contact you by email, phone, or mail.  We may use the information to customise our contact with you according to your interests.
  • to extract certain information from your data for the purpose of generating statistics, however, it is not possible to identify you from these statistics.

In order to deliver our services effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy or legal services as well as the use of Client Relationship Management systems.  

Please note, where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.

We may also use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you would like us to do so.  We may need to disclose your details to our trusted partners and service providers for these purposes.  

We reserve the right to fully co-operate with any law enforcement authorities or court order requiring or requesting us to disclose the identity or other usage details of any user of our site.

How long will Wealth Wizards hold your personal data?

We will not hold your personal data for longer than is required under the terms of our contract for our services with you.  Wealth Wizards is subject to regulatory requirements to retain data for specified minimum periods.  In addition, we are obliged to treat our customers fairly in the event of a future complaint and therefore we reserve the right to retain data for longer than these specified minimum periods in order to allow us to investigate such complaints and, if necessary, defend a future claim against us.

We will therefore keep your personal information securely for as long as we need to under the terms of our services or for as long as we are required to by relevant regulations.  Wealth Wizards regularly reviews the legal and regulatory obligations around the retention of your personal information.

If you would like more information about how long we will keep your information for, please contact us at:

Keeping your personal data secure

Wealth Wizards takes measures to ensure the security of your data, industry best-practice is followed at all stages of the data life-cycle.  We are always working to improve the methods employed to secure your data, for example, data is encrypted when in transit across public internet links and stored in an encrypted format in our systems.  We limit access to your personal data to those who have a genuine business need to know it.  Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

Wealth Wizards has procedures in place to deal with any suspected data security breach.  We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Unfortunately, sending information via the internet is not completely secure.  Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide this at your own risk.

Transfer of your information out of the European Economic Area (EEA)

Where we transfer your personal data to a country outside the EEA, we shall ensure that your personal data is adequately protected.  To achieve this, we will use EU approved standard contractual clauses (or any other EU approved transfer mechanism) for the transfer of this data.  When transferring personal data to the US we will only use providers who are certified under the EU-US Privacy Shield. The EU-US Privacy Shield addresses the collection, protection, storage, transfer and use of data transferred from the EEA the US.

Wealth Wizards and your rights

You have legal rights under data protection regulation in relation to your personal data.  These are set out in the table below:

If you would like to exercise any of the above rights, please email: or write to: Wealth Wizards Ltd, Wizards House, 8 Athena Court, Tachbrook Park, Leamington Spa, CV34 6RT.

Links to other websites

Our websites may contain links to other websites of interest.  However, once you have used these links to leave our site, you should note that we do not have any control over that content.  Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites, and such sites are not governed by this Privacy Policy.  You should exercise caution and look at the Privacy Policy applicable to the website in question.

Wealth Wizards and the Information Commissioner’s Office

If you are not happy with the way we are handling your personal data, you have the right to lodge a complaint with the Information Commissioners Office (ICO).  It has enforcement powers and can investigate compliance with data protection regulation (  We do however request that you attempt to resolve any issues directly with us before contacting the ICO.

Should you feel you need to lodge a complaint with the ICO you can call or write to:

Information Commissioner’s Office
Wycliffe House
Water Lane

Helpline Number: 0303 123 1113 (local rate).

Making changes to this Privacy Policy

We reserve the right to add to or change the terms of this Privacy Policy without prior notice.  If Wealth Wizards changes this Privacy Policy, we will post the new Privacy Policy on our websites (, and it will become effective from the time of posting.  Please view the Privacy Policy on a regular basis to ensure you have read the latest version to understand what we do with your personal data.


We take security seriously here at Wealth Wizards.

We are a regulated business, comply with all relevant data protection standards, and employ cutting edge cybersecurity to keep our customers safe.

We have a company wide, ISO 27001 certified quality management system called Remus.

Our Security Approach

Wealth Wizards takes security seriously. We follow three key principles:

  • Shared – We treat Information Security as a shared responsibility.
  • Systematic – Managing Information Security is a systematic, continuous activity.
  • Safe – Ultimately our approach is about keeping our customers and ourselves safe.

Our Management System

We have a comprehensive and innovative Management System – Remus.  Remus holds all our policy, risk and control information, and raises and tracks tasks to ensure these are continuously reviewed and improved.

Our Organisation

We employ a Three Lines of Defense model:

  • First line – Operational and business teams – Remus ensures that controls are in place and are monitored to treat the risks which we and our customers face.  Our Platform team implements and monitors security controls on our end user and platform infrastructure.
  • Second line – We have dedicated risk, compliance and platform teams which monitor the performance of Remus, and provide subject matter expertise for its improvement.
  • Third line – We run an internal audit programme, and employ external auditors to monitor the performance of our Remus and first and second line teams.

Information Security is a standing agenda item for all of our key committees, up to and including our main board.

Our Policies

We have a comprehensive set of controlled policies covering Information Security.  Each is owned by a specific individual in the second line of our defense, with a defined review cadence and approval process.

Our relevant policies include:

  • Business Continuity Management Plan
  • Continuous Improvement
  • Data Handling Policy
  • Data Protection
  • Data Protection Impact Assessments (DPIA)
  • Data Protection Policy
  • Data Retention Policy
  • Data Retention Schedules
  • Group Security Policy
  • Information Security Consolidated Communication Plan
  • Information Security Incident Handling Procedure
  • Information Security Policy
  • Information Security Roles & Responsibilities
  • Internal Audit Process
  • Personal Data Breach Notification
  • Platform Security
  • Privacy Policy
  • Risk Management Policy
  • Risk Treatment Process
  • Security in the Software Delivery Life Cycle
  • Third Party Purchase Procedure

ISO 27001

ISO/IEC 27001:2013 (ISO 27001) is the international standard that describes the requirements for an ISMS (information security management system). It is supported by its code of practice for information security management, ISO/IEC 27002:2013.

Wealth Wizards holds accredited certification to ISO 27001.  This provides independent, expert assessment that our information security is managed in line with international best practice and business objectives.  We have extended the approach to manage risks across our entire business.

Our approach to risk management

We have a unified approach to Risk Management.  It’s based on internationally recognised best practice (specifically ISO27001, IS1 and CISSP), and has been designed to be engaging and understandable across our organisation.

The approach covers the assessment and treatment of risk against our agreed risk appetite, and includes consideration of the confidentiality, integrity and availability aspects of each risk.

Risk assessments are triggered;

  • when any new system is implemented;
  • when there is a significant change to our risk appetite;
  • when there is a significant change to our security requirements;
  • at a cadence appropriate to the area of risk (at least annually);
  • ad hoc when raised as a concern via our incident management system; or
  • on a specific event such as a near miss incident.

Risk assessments cover all aspects of our business including:

  • Our physical assets & security
  • Our people
  • Our processes (in particular those relating to data security and handling)
  • Our suppliers
  • Our systems
  • Our platform

Whilst our impact and probability assessment scales are consistent to allow us to compare risks across all domains, our methods are tailored according to best practice in that area.

Security domains

Information cuts across all aspects of our business.


We undertake the following checks on all our people:

  • Verification of name and address
  • Verification of identity
  • Verification of previous two years employment history
  • Disclosure and Barring Service (DBS) check

In addition we perform the background checks required by the Financial Conduct Authority (FCA) for our Financial Advisors.

Security responsibilities are included in all job descriptions, and people receive security awareness training (and undertake qualifications) appropriate to their role.  Individual awareness, training and qualifications are reviewed as part of our mastery framework.

Asset management

End user devices

We maintain a complete, real-time inventory of all our End User devices.  Our workstations and laptops have anti-virus software included as part of the standard build we deploy across all devices:

  • We don’t store any data locally on laptops, and we do not allow the use of detachable, portable media (e.g. memory sticks)
  • We encrypt all local disc storage (to protect cached information)
  • We use Mobile Device Management allows us to monitor laptop usage, and to remotely wipe/lock down devices
  • Internet access and network connectivity is routed through our network, with access to services locked to our office locations


We ensure that all data has an appropriate level of protection, and unauthorised access or deletion is prevented:

  • All data we hold is classified and processed in accordance with our data handling policy
  • We have procedures in place to ensure that all data is deleted in accordance with the retention period applicable to its classification
  • We have procedures in place to ensure that any data transferred between us and our customers is secure
  • Data is encrypted at rest, and in transit across public internet, in accordance with industry best practice
  • PII Data is further encrypted at column level in datastores.

Access management

Access to our systems is strictly limited to those who are authorised to do so:

  • User responsibilities are documented, and users held accountable for safeguarding the data they have access to
  • We employ multi-factor authentication, and password complexity requirements in line with the National Cyber Security Centre guidelines
  • Access is managed by designated administrators of each given system, and processes are in place to manage access and removal from all systems
  • Customer and user requests are administered via our Service Desk
  • Access is segregated where required to ensure that it is controlled and appropriate to the system content
  • Processes are in place to ensure that access rights are removed in a timely fashion


We operate an encryption policy to protect confidentiality and integrity of information:

  • PII data is encrypted at column level in data-stores.
  • All data is encrypted at rest.
  • Real time application data is transmitted over encrypted TLS connections
  • We use unique encryption keys for each customer and secrets management and rotation to protect API keys and other access related information

Physical security

We use third parties and our own controls to prevent unauthorised access to our locations:

  • We use Amazon Web Services (AWS) to host our applications.  Details of their approach to physical security can be found here:
  • We operate a paper free environment, scanning and shredding all paper documents
  • All our office locations are protected by key and fob access and appropriate alarm systems
  • Additional physical devices (such as screen protectors) as used where necessary

Operations security

Although we use third parties to host our information processing infrastructure, we use their Infrastructure as a Service (IaaS).  This means we put in place the controls needed to secure our account and platform configuration (the shared responsibility model).

Our controls ensure that our infrastructure is secure, and protected against malware and data loss:

  • We define our infrastructure as code in version controlled repositories
  • All our live servers are torn down and replaced by the up to date image on a frequent basis
  • Pattern updates to anti-malware software are checked at least once a day, with virus scans conducted in real time where possible (and daily where not)
  • All data is backed up in an encrypted format to encrypted AWS S3 buckets.
  • We use a third party service to continually scan our infrastructure for vulnerabilities and suspicious activity
  • We hold immutable logs on system and network activity, and store these centrally
  • We have a system of alerts which are triggered if any suspicious activity is detected
  • All applications and services are managed through reviewed, version controlled configuration stores with fully automated deployment systems.
  • We frequently benchmark our systems against the appropriate Centre for Internet Security (CIS) benchmarks, which represent Industry best practice

Communications security

We employ a variety of processes and technologies to ensure that our communications are protected within our network, and in transit to/from our customers:

  • We use WPA2 and Active Directory authentication to protect our Wifi network
  • We use encrypted VPNs for all remote connections to our internal systems
  • We use a third party, managed, Host Intrusion Detection System (HIDS)
  • We employ a separate third party to conduct penetration testing on our Infrastructure and applications
  • We segment our networks by security value
  • We separate our proving and production environments (and never store user data in non-production environments)
  • We have procedures in place to ensure that any transfer of information to and from customers is protected by TLS

System acquisition, development and maintenance

Security is an integral part of our entire Software Development Life Cycle:

  • We train all our people in the relevant technologies for their job role
  • Our developers undertake OWASP training and refresher sessions
  • Our code review process covers OWASP vulnerabilities, adherence to secrets policy and the security of our endpoints
  • We make extensive use of automated testing – this is executed as part of our build process, and also overnight for all our test environments
  • We maintain a balanced pyramid of tests, automating unit, contract, system and performance tests
  • All tests are executed as part of our automated build pipeline
  • We do not make use of any client data for testing purposes
  • All code is held in configuration managed repositories

We have processes in place to ensure that the third party software and libraries we us are safe:

  • We automatically check our code libraries for known vulnerabilities
  • All third party products are risk assessed and reviewed for GDPR compliance:
  • When we are considering using a new product
  • When an existing product undergoes a major upgrade
  • When we change the way we are using an existing product

Release Management

We have controls in place which ensure the software we release is code reviewed, tested and configuration managed:

  • We use an automated build pipeline to ensure changes are:
  • reviewed
  • tested
  • committed to our configuration managed repositories
  • scanned for code vulnerabilities
  • We employ additional governance around the release process where changes can affect the advice which our products give – this requires:
  • adviser approval
  • compliance approval

Supplier Relationships

In order to protect the data we hold, we employ a number of controls to manage our interaction with suppliers:

  • We have a supplier risk assessment tool (Dora) which covers the suppliers financial and security obligations
  • Our contractual terms cover all aspects of Data Protection compliance, including notification requirements
  • We regularly review supplier service delivery in line with the agreements we have in place

Incident Management

We have controls in place which ensure a consistent and effective approach to the management of security incidents:

  • We have a dedicated Service Desk which allows customers and our own people to raise incidents quickly and easily
  • We have established an open culture which encourages the raising of incidents
  • We have dedicated roles and responsibilities which cover all aspects of incident management:
  • Identification
  • Triage
  • Containment
  • Resolution
  • Communication
  • We retrospectively analyse all incidents to allow trends to be analysed, and improvements to be put in place

Business Continuity Management

Information security is an integral part of our Business Continuity Plan (BCP):

  • We maintain a central BCP, with processes for the containment and communication of any continuity event
  • We rehearse our BCP at least annually
  • By storing all aspects of the configuration of our systems in code, we are able to rapidly rebuild and redeploy them to other geographical locations in the event of a disaster
  • We train all our people in remote working safely
  • We maintain very little of our own infrastructure meaning we are largely unaffected by non-availability of any of our office locations


We are a regulated business, and maintain a range of controls to ensure we comply with legal, statutory, regulatory and contractual obligations:

  • We conform to all the requirements placed upon us by the FCA, Information Commissioner and our certification auditors
  • We maintain registers for all compliance related events in our management system, Remus
  • We maintain a registry of relevant legislation, and its impact on the organisation of Security
  • We run an internal audit programme which verifies our adherence to our obligations
  • We have an exception process to respond to non-conformances
  • We employ third party experts to validate our technical approach, and to ensure we are up to date with expert community best practice

This page was last updated on 1st May 2019

Data protection policy

This is the policy of the ‘Wealth Wizards Group’, which is Wealth Wizards Limited and its subsidiaries from time to time including Wealth Wizards Benefits Limited.

The Legislation

Data Protection Act 2018 (DPA 2018)

Data protection obligations are currently set out in the Data Protection Act 2018 (DPA 2018). The DPA 2018 sets out when personal data can lawfully be processed and how it should be processed. It governs processing by data controllers of personal data relating to data subjects.

Reform of the law at EU level: GDPR

In April 2016, the European Parliament approved a general data protection reform package, thereby bringing to a close nearly four years of work overhauling the EU’s data protection rules.

Data Protection Bill (DPB)

In June 2017, the government announced that the DPA 1998 would be replaced by a new Data Protection Bill (DPB). It is intended that the DPB, supplemented by the GDPR, will modernise data protection law in the UK given the demands of an increasingly digital economy and society. When the UK leaves the EU, the GDPR will be incorporated into UK domestic law under the European Union (Withdrawal) Bill currently before Parliament.

The four main areas covered by the DPB are:

  • General data processing (which will be relevant to an employer’s day-to-day dealings with its workforce).
  • Law enforcement data processing (the DPB will implement the DPLED).
  • Data processing for national security purposes (including processing by the intelligence services).
  • Regulatory oversight and enforcement by the Information Commissioner’s Office (ICO).

Wealth Wizards Limited is a data processor. Wealth Wizards Benefits Limited is a data controller and is registered with the Information Commissioner’s Office.

The Information Commissioner’s Office (ICO)

The Information Commissioner’s Office (ICO) is an independent public body responsible for upholding information rights in the public interest, promoting openness by public bodies and data privacy for individuals.

The GDPR requires every member state to provide one or more independent public authorities to be responsible, as a “supervisory authority”, for monitoring its application, in order to protect the fundamental rights of individuals in relation to processing and to facilitate the free flow of personal data within the EU (Article 51(1)). The DPB confirms that the ICO will continue and will be the supervisory authority in the UK (clauses 112(1) and 113(1)).

Data controllers, and (where applicable) their representatives must co-operate on request with the ICO in the performance of its tasks (Article 31, GDPR).

The GDPR and DPB: concepts and definitions

The GDPR and DPB together create a new regime which will govern the processing by data controllers of personal data relating to data subjects. As it is put in recital 11 to the GDPR:

”Effective protection of personal data throughout the Union requires the strengthening and setting out in detail of the rights of data subjects and the obligations of those who process and determine the processing of personal data, as well as equivalent powers for monitoring and ensuring compliance with the rules for the protection of personal data and equivalent sanctions for infringements in the Member States.”

Under the new regime, the definition of personal data is more detailed and reflects changes in technology and the means organisations use to collect information about people. Data controllers will still be required to comply with a set of principles for processing personal data. The new principle of accountability requires data controllers to show how they have complied with the principles. For example, data controllers will not only need to have policies which demonstrate that they comply with the principles, but they will also need to be able to show how the policies have been implemented.


Data Subject – the identified or identifiable living individual to whom personal data relates.

Personal data – data held or likely to be held about a living individual who can be identified from the data, including any expression of opinion about the individual. Personal data includes;

  • CCTV footage if it could be used to match an image to a photo, description or physical image of an individual.
  • An identifier such as a name, an identification number, location data or an online identifier.
  • One or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.
  • Web based tracking technology used with the intention of linking the web user to a name and address would also be considered personal data.

The GDPR does not apply to the personal data of the deceased.

Special categories of personal data (currently sensitive personal data) – Under the DPB, read with the GDPR, there are slight changes to the categories of sensitive personal data currently identified by the DPA 1998 and which are now identified as “special categories of personal data” (Article 9(1), GDPR). This includes information about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, health, sex life and sexual orientation.

Processing of the special categories of personal data is prohibited unless an exception applies (Article 9(2), GDPR).

The commission or alleged commission of any offence and criminal proceedings are no longer included in the special categories of personal data. They are dealt with separately under the new regime, Criminal convictions and offences.

Data Controller – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by EU law or member state law, the controller or the specific criteria for its nomination may be provided for by EU law or member state law (clause 5(1), DPB and Article 4(7), GDPR).

Data Processor – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller (Article 4(8), GDPR).

Pseudonymisation – the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person (Article 4(5), GDPR).

Recital 28 of the GDPR recognises that applying pseudonymisation to personal data can reduce the risks to the data subjects concerned and enable data controllers to meet their obligations. Pseudonymised personal data can still be covered by the GDPR if, with additional information, the personal data can be attributed to a particular person.

It should be possible for a controller to use pseudonymisation in internal processes, as long as care is taken to identify those authorised to process the data and as long as the additional information needed to attribute the personal data to a specific data subject is kept separate (recital 29, GDPR).

Anonymisation – there is a distinction between information that has been pseudonymised and information that is anonymous. The GDPR does not apply to anonymous information, namely information which does not relate to an identified or identifiable person, or to personal data which has been anonymised so that the data subject is not, or is no longer, identifiable (recital 26, GDPR). This means that the processing of anonymous information for statistical or research purposes is not covered by the GDPR.

The ICO produced Anonymisation: managing data protection risk code of practice, which provides guidance on the way in which data can be rendered anonymous and retained in a form in which identification of the data subject is no longer possible.

Processing personal data – The processing of personal data means an operation (or set of operations) which is performed on personal data (or on sets of personal data), such as:

  • Collection, recording, organisation, structuring or storage.
  • Adaption or alteration.
  • Retrieval, consultation or use.
  • Disclosure by transmission, dissemination or otherwise making available.
  • Alignment or combination.
  • Restriction, destruction or erasure.

Processing of personal data must be carried out in accordance with the data protection principles.

Automated decision-making (including profiling) – Data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal, or similarly significant, effects. Recital 71 of the GDPR gives e-recruiting practices which have no human intervention as an example of automated processing. There are limited exceptions to this right which are considered below.

The circumstances in which data subjects can be subject to a decision based solely on automated decision-making, including profiling, are those in which the decision is:

  • Necessary for entering into, or performance of, a contract between the data subject and a controller.
  • Based on the data subject’s explicit consent.
  • Authorised by EU law or member state law to which the controller is subject, and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests.

In the first two of the exceptions, the data controller must implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, being at least the right to:

  • Obtain human intervention.
  • Express their point of view.
  • Contest the decision.

Decisions may not be based on the special categories of personal data unless either the data subject has given explicit consent or the processing is necessary for reasons of substantial public interest and, in either case, suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests have been put in place.

Profiling – Profiling is any automated processing of personal data which evaluates an individual in order to analyse or predict such things as their performance at work, economic situation, health, personal preferences or interests, reliability or behaviour, location or movements.

Recital 71 of the GDPR suggests that in order to ensure fair and transparent processing, taking into account the specific circumstances and context in which the personal data is processed, the controller should:

  • Use appropriate mathematical or statistical procedures for the profiling.
  • Implement technical and organisational measures appropriate to ensure, in particular, that factors which result in inaccuracies in personal data are corrected and the risk of errors is minimised.
  • Secure personal data in a manner that takes account of the potential risks involved for the interests and rights of the data subject and that prevents, inter alia, discriminatory effects on natural persons on the basis of racial or ethnic origin, political opinion, religion or beliefs, trade union membership, genetic or health status or sexual orientation, or that result in measures having such an effect.

Processing personal data in the context of employment – Under the GDPR, it is open to member states to provide for more specific rules to ensure the protection of the rights and freedoms in respect of the processing of employees’ personal data in the employment context, in particular for:

  • The purposes of recruitment.
  • The performance of the contract of employment, including discharge of obligations laid down by law or by collective agreements.
  • The management, planning and organisation of work.
  • Equality and diversity in the workplace.
  • Health and safety at work.
  • Protection of the employer’s or customers’ property.
  • For the purposes of the exercise and enjoyment, on an individual or collective basis, of rights and benefits related to employment.
  • For the purpose of the termination of the employment relationship.

Any such rules must include suitable and specific measures to safeguard the data subject’s human dignity, legitimate interests and fundamental rights, with particular regard to:

  • The transparency of processing.
  • The transfer of personal data within a group of undertakings, or a group of enterprises engaged in a joint economic activity and monitoring systems at the work place.

The DPB makes specific provision for the processing of special categories of personal data when it is necessary for the carrying out of rights or obligations under employment law.

Data protection principles

The GDPR sets out a number of principles with which data controllers must comply when processing personal data (Article 5).

Lawfulness, fairness and transparency: Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject.

Purpose limitation: Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purpose.

Data minimisation: Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy: Personal data shall be accurate and, where necessary, kept up to date.

Storage limitation: Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

Integrity and confidentiality: Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Accountability: The controller shall be responsible for, and be able to demonstrate compliance with the GDPR.

Conditions for lawful processing under Article 6(1)

Processing personal data will be lawful only if, and to the extent that, at least one of the conditions in Article 6 of the GDPR is met. Those conditions (which are similar those under the DPA 1998) are that:

  • The data subject has given consent to the processing of their personal data for one or more specific purposes
  • The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of a data subject prior to entering into a contract
  • The processing is necessary to comply with a legal obligation to which the controller is subject
  • The processing is necessary to protect the vital interests of the data subject or another person
  • The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  • The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests and fundamental rights and freedoms of the data subject which require protection of personal data, especially were the data subject is a child.

Criminal Offence Data

The GDPR rules for sensitive (special category) data do not apply to information about criminal allegations, proceedings or convictions. Instead, there are separate safeguards for personal data relating to criminal convictions and offences, or related security measures, set out in Article 10.

Article 10 also specifies that you can only keep a comprehensive register of criminal convictions if you are doing so under the control of official authority. Article 10 says:

“Processing of personal data relating to criminal convictions and offences or related security measures based on Article 6(1) shall be carried out only under the control of official authority or when the processing is authorised by Union or Member State law providing for appropriate safeguards for the rights and freedoms of data subjects. Any comprehensive register of criminal convictions shall be kept only under the control of official authority.”

This means you must either be processing the data in an official capacity, or have specific legal authorisation – which in the UK, is likely to mean a condition under the Data Protection Bill and compliance with the additional safeguards set out in the Bill. We will publish more detailed guidance on the conditions in the Bill once these provisions are finalised.

Even if you have a condition for processing offence data, you can only keep a comprehensive register of criminal convictions if you are doing so in an official capacity.

Data Controller Requirements and Duties

Notifying the Information Commissioner

The Data Protection Act 1998 requires data controllers to give details about their processing of personal information to the Information Commissioner for inclusion in a public register, unless they are exempt.

The registration must be renewed annually.

The Data Protection registration number for Wealth Wizards Benefits Limited is: ZA163085.

Notification process

The details to be notified are:

  • name and address of the data controller or their representative
  • description of the information being processed
  • purpose of processing the information
  • those to whom the information will be or may be disclosed
  • countries outside the European Economic Area (the EU plus Norway, Iceland and Liechtenstein) where data may be transferred
  • certain details on information security measures

Notification can be initiated by calling the Information Commissioner Notification Line on Telephone: 01625 545 740.

The period of notification is one year. Notifications must be renewed annually. There is an annual fee of £35.  Changes to a notification entry must be notified as soon as possible and are made free of charge.

Wealth Wizards Benefits Limited is the Data controller and responsible for all the data held on their clients. The DPC for Wealth Wizards Benefits Limited is the Governance & Information Security Manager.

Wealth Wizards Benefits Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference 596641

Registered Address: Wizards House, 8 Athena Court, Tachbrook Park, Leamington Spa, CV34 6RT.
Registered in England & Wales, No. 07014133. The information contained within this site is intended for UK consumers only and is subject to the UK regulatory regime.

Wealth Wizards®, Pension Wizard ®, Retirement Wizard®, Turo® and MyEva® are registered trademarks; the trademarks, trade names and logos on this website, and the copyright and pending patent applications, are used by Wealth Wizards Benefits Limited under licence from Wealth Wizards Limited. Pension Tidy-up, Pension Predictor, Investment Wizard, are trademarks and logos of Wealth Wizards Limited. Wealth Wizards Benefits Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference 596641.