This privacy notice explains how we collect, use, share, store and protect your personal information – including where we use artificial intelligence (AI).

What information do we collect about you?

We collect information about you when you engage us for financial planning 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.

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We’ll use your information collected from the website to personalise your repeat visits to the site.

Information about connected individuals

We may need to gather personal information about your close family members and dependents 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 them or, where appropriate, ask you to pass the privacy information to them.

Why do we need to collect and use your personal data?

We must have a valid legal reason (a ‘lawful basis’) for processing your personal information.

Contract: the primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. 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.

Legal obligations: certain legal and regulatory requirements mean we are required to process certain information. For example, to meet FCA regulatory requirements or anti-money laundering laws.

Consent: we may need to process special category data (such as health information). We’ll always explain why we need to process this information and obtain your explicit consent before using your information.

We also ask for your consent if you would like to receive updates about products or services that may interest you.

If we rely on your consent, you can withdraw it at any time.

Legitimate interest: We may keep certain personal information because we have a legitimate business reason to do so, for example, to check the suitability of our services, respond to any complaints in the future, or to meet the requirements of our professional indemnity insurer.

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. We’ll also use your information to carry out appropriate identity, fraud and anti‑money‑laundering checks as required.

Using artificial intelligence (AI)

We may use AI tools to help us review information more efficiently and provide you with faster, more accurate services. The AI doesn’t make decisions about you on its own — a human always checks the results.

When we do:

Purpose of AI use

AI tools may be used for:

• Draft or summarise internal documents (e.g., meeting notes)
• Identify patterns or errors in data
• Enhance compliance monitoring
• Support risk assessments or vulnerability detection (non‑decision‑making)

We do not use any systems for making automated decisions. All outputs and decisions made by AI are subject to human review and approval before being used or relied on.

Purpose and lawful basis for processing

The purpose of processing personal information using Artificial Intelligence (AI) systems is to:

• Support the provision of regulated financial advice and related services
• Improve administrative efficiency and service delivery
• Assist in document drafting, file reviews, and suitability analysis
• Enhance risk management, compliance monitoring and quality assurance
• Analyse client data to support financial planning projections and portfolio modelling
• Identify potential errors, inconsistencies or regulatory risks within client files
• Improve client communications and response times

AI systems are used as decision-support tools only. All regulated advice, suitability determinations, and client-specific recommendations remain subject to human review and approval.

We do not use AI to make solely automated decisions that produce legal or similarly significant effects on client

Our lawful basis for using AI to process your personal information are

Article 6 UK GDPR

• Article 6(1)(b) – Performance of a Contract
  Where processing is necessary to provide financial planning, investment advice, or related services under our engagement terms.
• Article 6(1)(c) – Legal Obligation
  Where processing is necessary to comply with FCA rules, anti-money laundering regulations, tax reporting obligations, or other statutory requirements.
• Article 6(1)(f) – Legitimate Interests
  Where processing is necessary for our legitimate interests in:
  • Improving operational efficiency
  • Enhancing compliance oversight
  • Ensuring advice quality and consistency
  • Preventing fraud and regulatory breaches

We conduct Legitimate Interest Assessments (LIAs) where appropriate to ensure that such processing does not override the rights and freedoms of data subjects.

Human review

Any AI assisted output is reviewed by a human adviser before being used or relied on.

Data sharing and storage 

Where AI tools are used:

• Ensure only the minimum necessary personal information is processed?
• Anonymise or pseudonymise, where possible, personal information?
• Ensure processing occurs in secure, regulated systems
• Have signed data processing agreements with all suppliers to ensure personal information is protected and that they cannot use this to improve their own AI products?
• No personal information be transferred outside the UK/EEA without appropriate safeguards and consent being in place.

We do not use AI tools that use your personal information to train public models.

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 won’t share your information for marketing purposes with other 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. We may occasionally need to also share your information with regulatory authorities such as the FCA, HMRC or the Financial Ombudsman Service (FOS).

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 to protect your personal data in transit.

Encrypted — All files are transferred with Microsoft message encryption, as is Data in Transit and Data at rest

Authenticated — All downloads are authenticated ensuring that only the intended recipient will receive the files. Even Unauthenticated messages are protected using Strong Random Numbers to ensure only recipients with access to the secure link will be able to access the message.

Audited / Logged — All transfers are logged, giving proof of any files sent in and out of the organisation.

Scanned — All files are Virus Scanned when uploaded and deleted if found to be infected.

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 keep hold of 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
• Indefinitely for pension transfers and opt-out business
• Three years for insurance business

We also have to keep identity‑verification documents (required under UK anti‑money‑laundering rules) for:

• At least 5 years after our relationship with you ends
• Up to 10 years if we still have an ongoing relationship

These are minimum periods, during which we have a legal obligation to retain your records.

We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we’ll not retain your personal data for longer than 5 years past the time of your death.

You have the right to request deletion of your personal data. 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 you hold 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.

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. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity.

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 link to other websites you should read their own privacy policies.

What can you do if you are unhappy with how your personal data is processed?

You also have the 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

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. This privacy policy was last updated on 12/2/2026.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you: by email at financial planning@akfp.net

Or write to us at The Compliance Officer, Building 2, The Sidings, Antrim Road, Lisburn, Co Antrim, BT28 3AJ