Our Privacy Policy

New Chapter Financial Planning Limited is an independent financial planning business based in Edinburgh, and an Appointed Representative of New Leaf Distribution Ltd. In this policy, “we”, “us” and “New Chapter” mean New Chapter Financial Planning Limited.

For the core activities involved in providing regulated financial advice, New Chapter Financial Planning Limited and New Leaf Distribution Ltd jointly determine how and why certain client information is used. For those activities, we act as joint data controllers. New Chapter remains solely responsible for certain other activities, such as our own direct marketing.

Section 6 explains New Leaf’s role.

This policy applies to our clients and to anyone who contacts us about our services, including through our website. It also explains how we treat information you give us about other people, such as your partner or children.

Registered company number SC897901. Registered office 6 Logie Mill, Beaverbank Business Park, Edinburgh EH7 4HG. Registered with the Information Commission (ICO) under number ZC287117.

If you have a question about this policy or your information, or want to use any of your rights, please contact Ross Carter or Kris Steel, our directors, who are jointly responsible for data protection.

Email: contact@newchapterfp.co.uk Phone: 0131 344 4610 Address: New Chapter Financial Planning, 21 Young Street, Edinburgh EH2 4HU

We will update this policy when the law or the way we work changes and tell you about any significant change. The latest version will be on our website at newchapterfp.co.uk/privacy-policy. This version is dated 11 November 2026.

We only ask for information that is relevant to your circumstances. We believe financial planning should start with your life rather than your money, so we need a full picture of you and your finances before we can give you sound advice.

We will require your name, contact details, date of birth, National Insurance number, tax residence, and two forms of identification, one with your photo and one showing your address, to confirm who you are.

What matters to you, what you want your life to look like now and in the future, your plans for work and retirement, and what you want your money to make possible.

Your income and spending, savings, investments, pensions, property, debts, insurance policies, tax position, and arrangements such as wills, trusts and powers of attorney.

Your employment and workplace pensions and, if you own a business, information about the business and your role in it.

Your attitude to investment risk, your knowledge and experience of investing, and how much of a fall in value you could withstand (your capacity for loss).

Information about your health and lifestyle where it is relevant to our advice, and any circumstances in which you might need extra support from us. Section 4 explains how we treat this.

Notes of our meetings and calls, our emails and letters, the advice we give you and the instructions you give us. If you pay our fees directly, we also keep the payment details we need.

The details you give us when you get in touch, such as your name, email address, phone number and message. Our website’s cookie notice explains which cookies the site uses, and we ask for your agreement before using any that are not strictly necessary.

Most of it comes from you. We also receive information from:

• your existing pension, investment, insurance providers, and your employer’s pension scheme, when you authorise us to contact them.
• other professionals you work with, such as your accountant or solicitor, when you ask them to share it with us.
• your partner or a family member, if we advise you together or they help you with your finances.
• electronic identity verification services, which may check your details against public records and credit reference agency data. This check does not affect your credit rating.
• public sources, such as Companies House if you own a business.
• the providers that hold your pensions, investments and policies, once they are in place, for example valuations and statements.

You do not have to give us information, but we need most of it to advise you. Some is required by law, such as what we need to confirm your identity. Without it, we may not be able to advise you or act for you.

If we advise you together with your partner or another person, we share information between you, because joint advice depends on it. If there is anything you would prefer to keep private, please tell us before you share it, and we will explain what we can and cannot do.

Planning often involves other people, such as your children, dependants, beneficiaries, or someone who holds a power of attorney for you. When you tell us about them, we use that information only for your planning and advice. Please let them know you have shared it, and where they can find this policy.

Some advice depends on your health. Insurers need medical details to offer life cover or income protection. Annuity providers use health and lifestyle information to work out how much income they will pay, and some pay more to people with certain health conditions. Your health can also affect how long your plan needs to last.

Life does not always go to plan. If something makes it harder for you to manage your finances, such as illness, bereavement or a big change in your circumstances, please tell us. We will note what we need to support you, including health information where relevant, and agree with you what we record.

Health information is “special category” data, which the law protects more strictly. We ask for your explicit consent before we collect and use it, with its own tick box in our Client Agreement.

We will not normally ask for other special category information, such as your religious beliefs. If you share something like this because it matters to your plans, for example wanting your investments to reflect your beliefs, we will protect it in the same way and use it only for that purpose.

You can withdraw your consent at any time. We will then stop using your health information for new advice, which may limit what we can advise on, such as protection insurance and annuities. We will keep records of advice already given where the law requires it, or where we need them to deal with a complaint or legal claim.

Our identity checks may occasionally reveal information about criminal offences, financial sanctions or fraud. We use this only to meet our legal duties to prevent money laundering and other financial crime.

The law only allows us to use personal information where we have a lawful basis for doing so. We rely on different bases for different purposes, and we ask for your consent only where consent is the right basis.

Where we rely on legitimate interests, we only do so where our interests are not outweighed by your rights and interests. You can ask us how we reached that view, and you can object (section 11).

We do not make decisions about you based solely on automated processing. Tools such as cashflow modelling and risk-profiling software support our work, but we review the results and talk through any recommendation with you.

If we want to use your information for a new purpose that is not compatible with the reason we collected it, we will tell you first.

New Chapter is an Appointed Representative of New Leaf Distribution Ltd, which is authorised and regulated by the Financial Conduct Authority. As our principal firm, New Leaf takes responsibility for the regulated advice we give you and supervises that advice.

For the core activities involved in providing regulated financial advice, we and New Leaf are joint data controllers of your information, as section 1 explains. New Chapter alone is responsible for some other activities, such as our own direct marketing. Whatever the arrangement between us, you can use your data protection rights with either of us.

New Leaf may access our client records for supervision, compliance, complaints and regulatory purposes. It uses them to check our advice, monitor how we meet the FCA’s rules, handle complaints about our service and meet its own legal and regulatory duties.

New Leaf’s paraplanners also help us prepare our advice, working from the information in your client file.

New Leaf’s privacy notice explains how it uses personal information: newleafdistribution.co.uk/privacy. New Leaf is registered with the ICO under number Z966060.

We share your information only where we need to. We do not sell it, and we do not pass it to other organisations for their own marketing.

Pension, investment, insurance providers, platforms and discretionary fund managers, so that we can arrange and manage the products you ask for. Each is responsible for how it uses your information and has its own privacy notice.

Our principal firm, as section 6 explains.

Organisations that provide services to us, such as our client records system, cashflow modelling, research software, identity verification, IT, email and secure document storage. They may only use your information to provide their services to us, under contracts that require them to keep it confidential and secure.

Your accountant, solicitor or other professionals where you ask us to work with them, and specialists we refer you to with your agreement.

Anyone you authorise to deal with us on your behalf, such as someone who holds a power of attorney for you, within the authority they hold.

Our own professional advisers, such as lawyers and accountants, and our insurers, where they need it.

The Financial Conduct Authority, the Financial Ombudsman Service, the Financial Services Compensation Scheme, the Information Commission (ICO), HM Revenue & Customs, the police and other authorities, where the law requires or allows it.

If responsibility for our clients ever had to pass to another firm, for example under our business continuity arrangements, we would share your information with that firm so that it could continue to look after you, and we would tell you.

Some of the organisations we work with may store or access information outside the UK. If your information is transferred outside the UK, we make sure it stays protected, either because the UK has recognised the other country’s data protection standards, or through safeguards such as the UK International Data Transfer Agreement. You can ask us for details.

Some of our messages are part of our service, such as arranging your annual planning meetings, updates on your plan and anything the law requires us to tell you. We send these while you are a client. They are not marketing, so they do not depend on the choices you make in our Client Agreement.

With your agreement, we will also send you occasional articles and updates by email. We will only do this if you tick the box for them in our Client Agreement. Every email will include a simple way to unsubscribe, or you can just tell us. If you would rather have them by post, let us know.

We do not pass your details to other organisations for their own marketing.

We keep your information only for as long as we need it and then delete it securely. For advice records that can be many years, because the FCA sets minimum periods and a complaint or legal claim about advice can be made long after it was given.

We protect your information with measures that include two-factor authentication, so a password alone is not enough to get into our systems. We also encrypt our devices and limit access to client information to the people who need it for their work. If a data breach is likely to put your rights and freedoms at high risk, we will tell you without undue delay.

You have the following rights over your personal information. Some apply only in certain circumstances, and if we cannot do what you ask, we will explain why.

You can ask for a copy of the personal information we hold about you at any time.

You can ask us to correct information that is wrong, or complete information that is missing.

You can ask us to delete your information. We will do so where we no longer need it, but we often have to keep advice records by law.

You can ask us to limit how we use your information, for example while we check whether it is accurate.

You can object to us using your information on the basis of legitimate interests, and we will stop unless we have compelling grounds to continue. You can always object to direct marketing, and we will stop.

Where we use information you gave us with your consent or under our contract, you can ask for it in a format you can pass to another organisation.

Where we rely on your consent, you can withdraw it at any time. This does not affect anything we did before you withdrew it.

Contact us using the details in section 1. You can also write to New Leaf’s Privacy Officer at New Leaf Distribution Ltd, 165–167 High Street, Rayleigh, Essex SS6 7QA. There is no charge unless a request is clearly unfounded or excessive. If you ask for a copy of your information, we may ask for two current forms of identification, so that we only give it to you. We may also ask you to tell us more about what you need. We will respond within one month of receiving your request, or of receiving anything we need to confirm your identity. For complex requests this can extend by up to two further months, and we will tell you within the first month if so.

If you are unhappy with how we have handled your personal information, please contact us using the details in section 1. You can also write to New Leaf’s Privacy Officer at the address in section 11. We will acknowledge your complaint within 30 days, look into it without undue delay, keep you updated and tell you the outcome.

Complaints about our advice or service more generally are handled separately, under the complaints procedure in our Client Agreement and on our website.

You also have the right to complain to the Information Commission (ICO), the UK’s data protection regulator.

Website: ico.org.uk/make-a-complaint Phone: 0303 123 1113

When you become a client, we ask each of you to make two choices in our Client Agreement, each with its own tick box: whether you agree to us using information about your health and other sensitive information (section 4), and whether you would like to receive occasional articles and updates from us by email (section 8). You can change either choice at any time by contacting us.