Data Protection
Privacy Notice
How True Hand collects, uses, shares, protects and retains personal information.
1. Who we are
True Hand Private Office Limited is a company incorporated in England and Wales (Company No. 17251647), with registered office at 2nd Floor Connaught House, 1–3 Mount Street (entrance via Davies Street), London W1K 3NB. For the personal data described in this Notice, True Hand will generally act as controller. True Hand is an Appointed Representative of Robert Quinn Advisory LLP (RQA), which is authorised and regulated by the Financial Conduct Authority (Firm Reference Number 548030).
Privacy enquiries and requests should be sent to: enquiries@truehandprivateoffice.com.
2. Information we collect
- Identity and contact information, including date of birth, nationality, National Insurance number, tax identifiers and identification documents;
- Family, relationship and governance information;
- Financial information, including assets, liabilities, income, expenditure, tax residence, source of wealth and source of funds;
- Investment objectives, knowledge and experience, attitude to risk and capacity for loss;
- Corporate, trust, partnership and beneficial-ownership information;
- Communications, meeting notes, instructions, portal activity and records of services provided;
- Information needed for anti-money-laundering, sanctions, fraud-prevention and regulatory checks; and
- Special-category or other sensitive information where relevant to the services, such as health information affecting planning or vulnerability considerations.
3. Where information comes from
We obtain information from you, family members and authorised representatives; your professional advisers and service providers; custodians, banks, managers and platforms; public registers and official sources; identity, sanctions and fraud-prevention providers; and RQA or other regulators where applicable. If you provide information about another person, you should ensure you are authorised to do so and, where appropriate, direct them to this Notice.
4. Why we use information and our lawful bases
| Purpose | Typical lawful basis |
|---|
| Assessing whether to enter into and administering an engagement | Steps before contract; performance of contract; legitimate interests |
| Providing private-office, oversight, advisory and arranging services | Performance of contract; legitimate interests; legal obligation |
| Client categorisation, suitability, recordkeeping, AML, sanctions and regulatory reporting | Legal obligation; substantial public interest where applicable |
| Protecting systems, preventing fraud and maintaining business continuity | Legitimate interests; legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests; legal claims condition where special-category data is involved |
| Marketing to existing or prospective contacts | Legitimate interests or consent, as applicable; you may opt out at any time |
Where we rely on legitimate interests, those interests include operating and protecting the private office, delivering and improving services, managing risk, maintaining records and communicating with clients.
5. Sharing information
We may share information, where necessary and subject to appropriate safeguards, with RQA; regulators, courts, law-enforcement and tax authorities; identity, sanctions and fraud-prevention providers; banks, custodians, platforms, investment managers and product providers; lawyers, accountants, trustees and other advisers; technology, portal, cloud, reporting and secure-storage providers; insurers, auditors and professional advisers; and a purchaser or successor in connection with a genuine corporate transaction. We do not sell personal data.
6. International transfers
Some providers or recipients may process information outside the United Kingdom. Before making a restricted transfer, we will use an applicable adequacy regulation, approved contractual safeguards or another lawful transfer mechanism, and will undertake any required risk assessment. You may request further information about relevant safeguards.
7. Retention
We retain personal data only for as long as necessary for the purposes described in this Notice and to meet legal, regulatory, tax, accounting, dispute and evidential requirements. Regulatory client and service records are normally retained for at least the period required by applicable FCA and RQA rules, which may be five years or longer depending on the record. Prospective-client information that does not lead to an engagement is reviewed and securely deleted or anonymised when no longer required.
8. Security and use of technology
We use access controls, secure systems, encryption or equivalent safeguards where appropriate, staff confidentiality duties, supplier controls, backup and recovery measures, and incident-management procedures. Identifiable client information may be processed only through an enterprise AI environment specifically approved by True Hand following privacy, security and contractual review. AI output is subject to human review and is not used to make solely automated decisions producing legal or similarly significant effects.
9. Your rights
Depending on the processing and lawful basis, you may have rights of access, rectification, erasure, restriction, data portability and objection, and the right to withdraw consent without affecting earlier lawful processing. The right to object to processing based on legitimate interests, and to direct marketing, is brought specifically to your attention. We may need to verify identity and may lawfully refuse or limit a request in some circumstances.
10. Complaints and updates
Please raise privacy concerns with us at enquiries@truehandprivateoffice.com. You also have the right to complain to the Information Commissioner's Office at ico.org.uk. We will review this Notice periodically and will bring material changes to your attention before beginning materially different processing where required.
Version 1.0 | True Hand Private Office Limited
