GDPR and financial advice: Connected individuals

A particular sticking point the Working Group arrived at in connection with the General Data Protection Regulation (GDPR) related to the processing of an individual's data where they have not been present when their data was collected for processing. This situation, it seems, occurs quite regularly, with a spouse or partner or relative approaching an advice firm and entering into the advice process where information is required to be provided about them as part of a couple or family. Often a husband or wife may provide information about their partner to a financial adviser and their p...