Our Legals
IronMarket Wealth
IronMarket Wealth & NET-WORTH NTWRK (trading style of IronMarket Limited company #08411874), is incorporated in England and Wales and are authorised & regulated by the Financial Conduct Authority. Further details are available on the FCA Register at www.fca.org.uk, our FCA Firm Reference Number is 620330.
What information do we collect
We collect information about you when you engage us for any of our services, these may include personal or business financial planning/financial advice/mortgage, protection advice/investment management services/auto enrolment services. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health if this is necessary for the provision of our services.
We may also collect information when you voluntarily complete client surveys or provide feedback to us. Website analytics are collected using cookies via We also use Google Analytics to collect information regarding site usage. This data is collected via cookies, which are text files placed on your computer to collect standard internet log information and visitor behaviour information. We use the information collected to better understand and improve our user experience.
Information about connected individuals
We may need to gather personal information about your close family members and dependants in order to provide our service to you effectively. In such cases, it will be your responsibility to ensure that you have the consent of the people concerned to pass their information on to us. We’ll provide a copy of this privacy notice for you to pass to the connected individual if appropriate.
Why do we need to collect and use your personal data?
Whilst it is our policy to seek consent to process your data wherever possible, this is not a legal obligation in certain circumstances. The primary legal basis for the processing of your data is for the performance of our contract with you, or as a result of other legal obligations such as regulatory compliance with the Financial Conduct Authority (FCA). The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we’d also be unable to fulfil our legal and regulatory obligations.
Where special category data * is required, we are legally obliged to obtain your explicit consent in order to collect and process this information.
* Special category’ data is sensitive personal data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, sexual orientation and health details
How will we use the information about you?
We collect information about you in order to provide you with the services for which you engage us.
Who might we share your information with?
If you agree, we may email you about other products or services that we think may be of interest to you. We never share your information for marketing purposes with companies outside our group of companies.
In order to deliver our services to you 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 product and platform providers that we use to arrange financial products for you.
Where third parties are involved in processing your data; we’ll 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’ll only act in accordance with our written instructions. Where it’s necessary for your personal data to be forwarded to a third party we’ll use appropriate security measures such as password protection and/or encryption of data to protect your personal data in transit.
To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.
How long do we hold your information?
During the course of our relationship with you, we’ll retain personal data which is necessary to provide services to you. We’ll take all reasonable steps to keep your personal data up to date throughout our relationship. We’re also subject to regulatory requirements to retain your data for specified minimum periods.
These are, generally:
• Five years for investment business
• Three years for mortgage business
• Indefinitely for pension transfers and opt-out business
• Three years for insurance business
These are minimum periods, during which we have a legal obligation to retain your records.
We reserve the right to retain data for longer where we believe it’s in our legitimate interests to do so. In any case, we’ll not keep your personal data with the exception of pension transfer business, for longer than 5 years after our relationship with you has ended.
You have the right to request deletion of your personal data at any time. We’ll comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.
How can I access the information held about me?
You have the right to request a copy of the information that we hold about you. If you’d like a copy of some or all of your personal information please email or write to us using the contact details noted below.
When your personal data is processed by automated means, you have the right to ask us to move your personal data to another organisation for their use.
We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.
Automated decision making and profiling
If you use our online application portal (The IronMarket App) some personal information will be gathered through the information that you input into the system. Your data is collected in order for us to carry out the service for which you engage us. If you’re unsure about the outcome of the automated process you can contact us to discuss or to challenge the outcome.
We take measures to ensure the security of your data, with our application being encrypted and only accessed with individual secure log-in details. We don’t use any special category data (such as data about your health) in the automated process unless it’s strictly necessary to deliver our service and we have obtained your explicit consent to do so.
We regularly check our systems for accuracy and bias and feed any changes back into the design process.
Marketing
We’d like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please click on ‘Set Preferences’ in the footer at the bottom of this page or, alternatively, you can contact us by email or post.
What can you do if you are unhappy with how your personal data is processed?
You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:
Information Commissioner’s Office Wycliffe House,
Water Lane
Wilmslow
Cheshire
SK9 5AF P:
0303 123 1113 (local rate)
Changes to our privacy policy
We keep our privacy policy under regular review and we’ll place any updates on this web page.
Cookies
We use Google Analytics to track non-personal visitor information regarding the use of this website and to compile statistical reports on website activity via Google Analytics. For further information visit http://www.allaboutcookies.org/
You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Other websites
Our website contains links to other websites.
This privacy policy only applies to this website so when you follow a link to other websites, you should read their own privacy policies.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you.
Email:
hello@IronMarketGroup.com
Our registered office and mailing address:
10 Brindley Court,
Lymedale Business Park,
Dalewood Road,
Newcastle-under-Lyme,
ST5 9QA
Financial ombudsman
The Financial Ombudsman Service is available to sort out individual complaints that clients and financial services businesses aren’t able to resolve themselves. To contact the Financial Ombudsman Service please visit www.financial-ombudsman.org.uk.
Pillar III Disclosures
1. Introduction
IronMarket Limited is a private client wealth management firm, authorised and regulated in the United Kingdom by the Financial Conduct Authority (‘FCA’). Under the FCA’s Prudential Sourcebook for Banks and Investment Firms (‘BIPRU’), IronMarket Limited is classified as a BIPRU €50K Limited Licence investment firm. As such, it is required to comply with the three “Pillars” of the EU’s Capital Requirements Directive (‘CRD’) framework.These are:
Pillar 1, which sets out the minimum amount of capital the Firm needs to meet its regulatory requirements;
Pillar 2, which requires us and our regulatory supervisors to consider the requirement to hold additional capital against risks not covered in Pillar 1. In the UK, this is implemented through the Internal Capital Adequacy Assessment Process (“ICAAP”) undertaken by IronMarket Limited, and by the FCA through the Supervisory Review and Evaluation Process (“SREP”);
Pillar 3, which requires us to disclose to market participants key information about our underlying risks, risk management controls and capital position. The purpose of this document is to meet our obligation in respect of Pillar 3.
2. Disclosure Policy
IronMarket Limited is a directly authorised discretionary fund management and financial advisory company. IronMarket Limited makes Pillar 3 disclosures on at least an annual basis, as soon as practicable following the end of our Financial Year. These are provided on our corporate website, www.ironmarket.co.uk . Under the rules of BIPRU 11, the firm may omit certain information from the Pillar 3 disclosure, in specifically defined circumstances, where it believes that the disclosure contains information that is immaterial, proprietary or confidential. We confirm that we have not omitted any disclosures on these grounds. All figures in this document are correct at 30th May 2020 unless stated otherwise 3.
3. Risk Management Policies and Objectives
Risk Appetite
Our interpretation of risk appetite is how comfortable would we be if a risk were to emerge. This is quite a subjective analysis, however, it does gauge how the Board is feeling about the risks within our firm.
The current view is that the Board are relatively comfortable with the key risks potentially affecting the Firm, but we will keep this in view on an ongoing basis.
The Board will review the overall effectiveness and relevance of the Firm’s system and controls for each financial year. The Board will also carry out an evaluation of the major risks affecting the business and the processes in place within the business to control and monitor such risks on an ongoing basis. On this basis the Board will report and disclose its findings and whether it believes that all necessary actions have been, or are being, taken to remedy any significant failings identified as part of the ongoing risk management process and that no significant weaknesses were identified during the year.
The Firm’s activities are non-complex and the Firm does not hold client money or assets or trade on its own account.
Risk Management Framework
In order to ensure that IronMarket Limited regularly reviews and monitors all the potential areas of risk to the business, the Firm has put in place a risk management framework which enables all senior management and any relevant committee and the Board to be kept fully informed of any potential risks to the business and also how those risks might impact the group’s capital adequacy position.
A Risk Matrix has been designed which captures the core fundamental risks inherent in the firm and assesses how those risks are managed and mitigated, the key indicators that would suggest if the risk is likely to materialise together with an assessment that each risk may have on the Firms regulatory capital. This is the core assessment of the Pillar 2 requirements.
A thorough Compliance Monitoring Programme (“CMP”) is managed via an annual programme of reviews. Details of the CMP and the current status are provided to the Board on a regular basis, with any material issues being escalated to the Board immediately they are identified.
The CMP also includes undertaking stress and scenario testing of its key risks to determine the impact to our current and future profitability and balance sheet.
The key risk exposures the Firm faces and the mitigating controls in place are listed below:
Credit Risk
As IronMarket is not a lender to businesses and individuals and does not make credit available to clients, the firm is not exposed to potential credit losses if customers are unable to repay loans and outstanding interest or fees. The firm does have exposure to counterparties with which it places deposits of its own funds and mitigates for the risk of losses in this regard by holding additional capital in accordance with BIPRU. The credit risk capital component of the firm is 8% of the total of its risk weighted exposure amounts.
Operational Risk
This relates to the risks resulting from inadequate or failed business processes and systems. IronMarket Limited seeks to monitor potential sources of errors arising from its operations and continually strengthen our internal systems and processes, supervisory and oversight functions to reduce our residual risk exposure. The Firm maintains resilient infrastructure, and regularly tests its Business Continuity and Disaster Recovery arrangements to limit the impact of potential external events. Additionally the Firm maintains comprehensive Professional Indemnity Insurance cover to cap our exposure to potential large claims or operational losses. There are two registered investment managers, who act as a contingency for each other.
Liquidity Risk & Market Risk
Reduction in Portfolio Values – The two principal reasons for a reduction in the value of a clients’ portfolio, would either be adverse market movements or poor relative investment performance. We have modelled the impact of a downturn in the markets, with the result that income derived from discretionary assets under management could fall by 69% before ongoing profitability would fall into a loss-making situation. Our current view is that such a market correction is unlikely.
The key liquidity requirements within the firm are the cashflows within the business and how a non-receipt of funds may significantly impact the firm. At present the firm is not materially reliant on any one client for income (materiality is defined as any exposure to one client which may impact the balance sheet by more than 10%). Additionally, the firm debits funds in respect of client fee’s directly from the client funds managed by the firm and as such, the risk of default by any client in respect of fees due, is minimal.
Business Risk
The value of the assets that we manage or advise upon could reduce for a variety of reasons, including the loss of clients and a reduction in the value of a clients’ portfolio either due to market movements or poor portfolio performance. The highest potential risks are:
Loss of Clients – The firm has a diverse client base for our discretionary managed clients. IronMarket Limited currently manages £68.8 million of discretionary assets for 552 client relationships across 712 active accounts (as at 30/10/21). The current average client size across all portfolios is approximately £125,000. Client relationship management and retention is at the very centre of operations. Should a client be deemed to be ‘at risk’ a formal action plan would be managed to prevent the loss of the client.
Relative investment performance is monitored and reported on an ongoing basis. Should the performance be such that either we or the clients were unhappy with portfolio performance, we would instigate a formal action plan, as discussed above.
The firm has undertaken an analysis of how a significant increase, or decrease, in business volumes may impact the firm. It is envisaged that the client base of approximately 552 clients, could increase by a further 30% before the three principal advisors of the firm would require additional assistance in managing those relationships.
4. Business Strategy
The mission of IronMarket is to provide the highest standards of advice, discretionary investment management and service to its clients. We wish to establish a successful partnership with our clients, our staff and product providers that respect the interests and the goals of each party.
We strive to maintain and increase our current customer base by providing our services in a manner whereby the fair treatment of customers is consistently at the heart of the business. Success is measured by our clients choosing us above the competition because of their belief in our ability to meet or exceed their expectations on cost, service and expertise.
5. Capital Resources
As at 31st May 2021 the firm’s Capital Resources were £404,000 which covered a capital adequacy requirement of approximately £117,000, providing a surplus of £287,000.
The following table itemises the components of the Capital Resource Requirement, the Firm’s Pillar 2 current Capital figures and the Total Capital and Surplus:
| Base Requirement | £42,990 | P1 |
| Credit Risk (8% of 20% of cash at bank) | £6,405 | P1 |
| Market Risk | £0.00 | P1 |
| Fixed Overhead Requirement (FOR) | £117,000.00 | P1 |
| Uninsured provision (IPRU-inv13.1.23) | £37,000.00 | P2 |
| DB provision (IPRU-inv13.1.23) | £37,000.00 | P2 |
| Excess provision (IPRU-inv13.1.27) | £23,000.00 | P2 |
| Winding down excess over FOR | £0.00 | P2 |
Pillar 2 total £97,000.00
Total cap requirement including provisions (TCR) £214,000.00
Balance Sheet Capital £404,000.00
Surplus/Deficit vs FOR £287,000.00
Surplus/Deficit vs TCR £190,000.00
Surplus/Deficit as % of FOR £245.30 Surplus/Deficit as % of TCR £88.79
6. Remuneration Code
SYSC 19F, which came into force on 1 January 2018, requires that where remuneration arrangements have the potential to create material conflicts of interest between individuals and Clients:
(a) Incentives must not be solely or predominantly based on quantitative commercial criteria, and must take fully into account appropriate qualitative criteria reflecting compliance with the applicable regulations, the fair treatment of clients and the quality of services provided to clients.
(b) A balance between fixed and variable components of remuneration must be maintained at all times, so that the remuneration structure does not favour the interests of the firm or its relevant persons against the interests of any client.
SYCS 19 requires IronMarket Limited to implement remuneration policies and procedures consistent with sound risk management and which do not incentivise staff to take risks outside the Company’s risk profile. In line with FCA Rules and Guidance, IronMarket Limited has deemed that it does not need to comply with the prescriptive quantitative requirements in SYSC 19C on variable remuneration as these are not appropriate to the nature scope and complexity of its activities. Nevertheless, IronMarket Limited has adopted a remuneration policy (“the Remuneration Policy”) that covers all aspects of staff reward, including all fixed and variable components of remuneration, such as salaries, pensions and other benefits. The Policy is intended to incentivise and reward performance and encourage staff retention, but to do so in a manner that:
a) Is consistent with, and promotes sound and effective risk management;
b) Does not encourage risk-taking which is inconsistent with the risk profiles of the Company or its clients;
and c) Does not impair our compliance with our duty to act in the best interests of clients. The Policy comprises a number of interlinked components, which are applied depending on the level of an individual’s seniority within the business:
Annual Pay Review – Awards are based upon the job evaluations and with reference to market rates.
Annual Bonus (Short Term Incentive Compensation) – Awards are based on a combination of Company and Personal Performance factored against market rates. Company results adjust the level of personal performance awards available based upon agreed business measures such as New Money, Assets, profit and loss, customer scope, expenses etc.
All staff performance measurement is subject to qualitative as well as quantitative commercial criteria and at least one performance measurement for all staff must be linked to risk control.
IronMarket Risk
Important notice
This is the privacy notice of Broker Network Ltd (registration number: 123456) whose registered office is at hexagon House Grimbald Crag HG5 8PJ referred to as we, us or our in this privacy notice.
This privacy notice sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.
This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times. Please read this privacy notice carefully as it explains how we may collect and use your personal data.
This privacy notice may vary from time to time so please check it regularly. This privacy notice was last updated on 25/06/2019
How to contact us
Controller and contact details
For the purposes of relevant data protection legislation, we are a controller of your personal data. As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.
If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details as set out below.
Our [Data Protection Officer] is Simon Flanigan who you can contact at 0344 346 1331
What information we hold about you and where we obtain this from
The personal data that we collect about you may include the following information:
- Personal data you provide to us in person, via our website or by telephone
- Personal data you provide when you enquire about insurance, or when you purchase a policy, through us, including information about what and/or who you want to insure, such as vehicle details, business activities, your home or travel details
- General information about you, such as your name, address, contact details and date of birth
- Personal data you provide if you subscribe to any of our mailing or newsletter services
- Your claims and credit history
- Financial details, such as your bank account and card details
- Criminal convictions
- Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies
In addition, we may obtain certain special categories of your data (special categories of data) and data about criminal convictions, and this privacy notice specifically sets out how we may process these types of personal data. The special categories of data are data concerning health.
We collect your personal data from you as a controller when we obtain quotations for insurance for you, when we set up your policy for you and when we make changes to your policy for you. This may also involve the collection of data from or about others who are associated with you and your insurance policy such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of arranging insurance for them under your policy such as named driver, employee or travel companion etc. you confirm that you have their permission to do so and that you have shared this privacy notice with them.
By asking us to arrange a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child.
We also collect information from publically available sources and third party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.
How we use your personal data and the lawful basis for doing so
Where we are relying on a basis other than consent
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
| Purposes for which we process your personal data | The basis on which we can do this (this is what the law allows) |
| In order to perform our contractual obligations to you. This would include our fulfilling your requests for insurance services (including obtaining insurance for you, fulfilling requests for mid-term adjustments and obtaining renewals) | The processing is necessary in connection with any contract that you may enter into with us |
| To administer your account, including financial transactions for insurance broking | The processing is necessary in connection with any contract that you may enter into with us |
| To assist in the prevention and reduction of fraud and other financial crime | The processing is necessary for us to comply with the law and our legal requirements |
| In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded | The processing is necessary to pursue our legitimate interest in the management and operation of our business |
| To let you know about similar products and services that may be of interest to you | The processing is necessary to pursue our legitimate interest in operating our business |
Special categories of data and criminal convictions
We may also need to collect special categories of data from you such as information about your health, in order for us to perform our contractual obligations to you the lawful basis on which we can do this is that processing is necessary (a) for an insurance purpose (b) is of personal data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership, generic data or data concerning health and (c) is necessary for reasons of substantial public interest. We may also process information on criminal convictions data which we may share with third parties under the processes of (a) and (b) above.
Insurance purposes mean (a) advising on, arranging, underwriting or administering an insurance contract (b) administering a claim under an insurance contract or (c) exercising a right or complying with an obligation, arising in connection with an insurance contract, including a right or obligation arising under an enactment or a rule of law.
Who we pass your personal data to
We may need to pass your personal data to other companies which may include:
- Other companies or brands within our group of companies, for example if we are unable to provide a suitable insurance policy on request or at renewal we will check if any of our associated group companies can provide you with suitable cover
- The insurers, intermediaries and third party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
- Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
- Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
- Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime
- Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
- Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
- Third parties we use to recover money you may owe us or to whom we may sell your debt
- Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over
The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK and the European Union. We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.
Accessing our website and cookies
When you visit one of our websites we may collect information from you, such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We use third parties to collate IP addresses to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website. We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.
We may use cookies and/or pixel tags on some pages of our website. A cookie is a small text file sent to your computer. A pixel tag is an invisible tag placed on certain pages of our website, but not on your computer. Pixel tags usually work together with cookies to help us to give you a more tailored service. We also use cookies and pixel tags in our email communication to personalise the email and track whether the email has been opened and whether the recipient has used any website links contained in the email communication. This allows us to monitor and improve our email communications and website. Useful information about cookies, including how to remove them, can be found at http://allaboutcookies.org.
Internet browsers normally accept cookies by default, although it’s possible to set a browser to reject cookies. We’ll ask your permission before using any cookie that’s not essential to the email or the use of the website. However, refusing to accept cookies may restrict your use of our website and/or delay or affect the way in which our website operates. You can find more information on cookies when you visit our website.
The open nature of the internet is such that data may flow over networks without security measures, and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.
Your Rights
We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep you information. If this is the case, we’ll let you know our reasons.
You can ask us to:
- Provide a copy of your personal information
- Correct or delete unnecessary or inaccurate personal information
- Restrict or to object to the use of your personal information at any time
- Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made we will advise you of this and of your rights
- Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you
- Where we rely on your consent to use your personal information, you can withdraw that consent at any time. Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again
If you have any questions or concerns about this privacy notice or your data protection rights please contact us using our details set out at the beginning of this privacy notice.
You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement. Further details about the ICO are available at: www.ico.org.uk.
How we contact you about other products and services
We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom and we pride ourselves in offering professional and tailored advice which meets your specific insurance needs. This includes keeping you informed on the latest insurance and industry information and details of any offers or promotions relating to the insurance services we provide to you. Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so. We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.
IronMarket Talent
IronMarket Talent (company # 11811508) is incorporated in England and Wales with the registered address 10/11 Brindley Court, Lymedale Business Park, Newcastle Under Lyme, England, ST5 9QA .
1. Privacy commitment
We are committed to safeguarding your privacy online and have developed this privacy policy to deal with issues which may concern you. Please read this policy to understand how your personal information will be treated. This policy may change from time to time so please check it periodically.
2. Personal information
The details which you provide about yourself and any information which identifies you (such as your name, address, email address) will be collected by us when you upload your CV, when you submit such information directly by filling in an online form, and when you browse, where cookies may be used.
3. Use of personal information
This information will be held on our system and used only for job search activities for which you have given us your express permission and to make available to you all information relating to us.
4. Protection of information
We will not pass on your personal information to third parties unless we are required by law or by a regulatory or government authority to do so. We do not normally link IP addresses to anything personally identifiable, which means that you remain anonymous even though we include your IP address in our aggregate information. However, we can and will attempt to use IP addresses to identify a user when we feel it is necessary to enforce compliance with our terms and conditions, or to protect our services and other users.
5. How we protect information
We take every precaution to protect your information. To this end all personal information stored by us is kept on a server in a secure environment. Only employees and approved contractors/developers who need the information to perform a specific job are granted access to personally identifiable information. Regular security reviews are held by us to ensure that the site remains safe and secure for your protection. We cannot guarantee the security of data you disclose online, and you accept that the internet is not completely secure and agree that we shall not be liable for unauthorised use, distribution or destruction of your personal information.
6. Correcting/updating personal information
If your personal information changes or if you no longer wish to subscribe to the service, we will endeavour to correct, update or remove the personal information provided to us as speedily as possible. This can be done by using the remove email on the website and email signature.
7. Data retention
IronMarket Talent will hold your data for no more than 5 years without positive inbound contact from yourself. Once your data has been on our database for 5 years and we have had no contact from you we will permanently delete all data related to you.
8. Data access
IronMarket Talent will provide subjects with either an Office Word Document or a PDF copy of all data held on them within one month of the subject access request. IronMarket Talent will only provide data held if it is requested by the subject that the data is held on.
9. Cookie policy
A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
We use the following cookies on our website:
Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features. Without these cookies, services you have asked for such as remembering your login details cannot be provided.
Performance cookies
These cookies collect anonymous information on how people use our website. For example, we use Google Analytics cookies to help us understand how customers arrive at our site, browse or use our site and highlight areas where we can improve areas such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
Functionality cookies
These cookies remember choices you make such as the country you visit our website from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers.
Social Media Cookies
These cookies allow you to share what you’ve been doing on the website on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies for how their cookies work. If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.
Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site. To find out more about cookies please visit: www.allaboutcookies.org or see www.youronlinechoices.eu which contains further information about behavioural advertising and online privacy.
10. Governing law
This privacy policy forms part of our website terms. Any dispute or claim arising out of this policy and the use of your personal information will be governed by English law and the courts of England and Wales have exclusive jurisdiction to resolve any such dispute or claim
11. GDPR
To see how we use your personal data in compliance with GDPR (General Data Protection Regulation) please view our full ‘GDPR Agreement‘ below.
This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation which replaces the Data Protection Regulation (Directive 95/46/EC). The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your new rights under the GDPR are set out in this notice and were last updated on 10th May 2018.
The Information we collect
To carry out our core recruitment activities, we collect information about you which may include: your name, address and post code; private and corporate e-mail address and phone number; financial information and compliance documentation; references verifying your qualifications and experience and your right to work in the United Kingdom; curriculum vitae and photograph; employment details and preferences; links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook for Business or corporate website.
How we collect this information
The information we collect about you will be provided by you, either by filling out a form on our website (net-worthntwrk.com) or by corresponding with us by phone, e-mail or otherwise. It will also include information you provide when you register to use our website, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey, and when you report a problem with our site.
We may also obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and any relevant social media sites.
On a 6 monthly basis you will receive an email asking you to check the information we hold, amend if required or alternatively request for it to be removed by emailing remove@ironmarkettalent.com or completing the survey.
Our legal basis for the processing of personal data is: Legitimate interest, Contract and/or Consent. Legitimate interest: the processing of data is necessary to fulfil our duty to act on your behalf as recruitment consultants. We will not act under this if there is reason to protect your personal data.
Contract: the processing of personal data is necessary if you have been placed and/or are contracting through IronMarket Talent.
Consent: If the above do not apply, we will not hold your data without clear consent to process personal data. Where we store your personal data
All information stored on our recruitment software is backed up at regular intervals and stored in two alternative locations within the EU at all times, as per AWS recommended guidelines. Finally, security and performance tests are carried out at regular intervals to ensure the smooth running of the service.
How long we keep your data for
We retain different types of data for differing periods of time. The criteria we use to determine whether we should retain your personal data and how long for includes:
• The nature of the personal data
• Its perceived accuracy of your date
• Your engagement levels with our services
• Our legal obligations following an offer or when a placement has been made.
We may archive part or all your personal data or retain it on our financial systems but delete all or part of it from our recruitment software system. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure we do not re-enter your personal data to our database, unless you have requested us to do so.
Our current retention period for data on candidates who have not been placed or are no longer showing any signs of engagement with our website, is 5 years.
Your rights
The GDPR provides you with the following rights:
• The right to be informed about the personal data we process on you
• The right of access to the personal data we process on you
• The right to rectification of your personal data
• The right to erasure of your personal data in certain circumstances
• The right to restrict processing of your personal data
• The right to data portability in certain circumstances
• The right to object to the processing of your personal data
• The right not to be subjected to automated decision-making and profiling. Therefore, we encourage you to log in to your profile through our website to ensure your data is accurate, complete and up to date always.
Changes to our privacy notice
Any changes we make to our privacy notice in future will be posted on this page and, where appropriate, you will be notified by e-mail. Please check back frequently to view any updates or changes to our privacy notice or for any further information please email compliance@ironmarkettalent.com.
