Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation, and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data and the various rights you have in relation to it.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, and National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Mortgage/Loans/Financial and Insurance, Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses, and documents necessary to verify your identity.
- Employment and remuneration information (including salary/bonus schemes/overtime/sick pay/other benefits) and employment history.
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances, and details of dependents.
- Health status and history, details of treatment and prognosis, medical reports (further details are provided below regarding the processing of this type of information).
- Any pre-existing Mortgage/Loans/Financial and Insurance products and the terms and conditions relating to these.
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Mortgage/Loans/Financial and Insurance requirements, we do so on the basis that both parties are entering a contract for the supply of services. In order to perform that contract and arrange the products you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from mortgage lenders, insurance providers, and our Compliance Service Provider relating to the advice we have given to you, or to contact you for feedback on the service you received.
We may also process Your Personal Data in order to meet legal, compliance, or regulatory obligations, including obligations to The Financial Conduct Authority.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with insurance needs, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask for information about your ethnic origin, health, and medical history (Your Special Data). We will record and use Your Special Data in order to make enquiries with insurance providers and to provide you with advice regarding the suitability of any product available to you.
If you have parental responsibility for children under the age of 13, we may also record information relating to those children, including Special Data.
The arrangement of certain types of insurance may require disclosure of historic or current criminal convictions or offences (Criminal Disclosures). This is relevant to underwriting, claims, and fraud management.
We will use Special Data and Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
How do we collect Your Personal Data?
We collect Your Personal Data primarily from you, through meetings, phone calls, emails, and forms. We may also obtain some information from third parties, such as credit reference agencies, your employer, and public records. If we use technology to verify your credit status, we will do so only with your consent, except where conducting electronic ID checks, which do not require consent but will be explained to you.
What happens to Your Personal Data when it is disclosed to us?
Your Personal Data will be:
- Recorded and stored securely on our systems and accessible only to authorised employees or consultants.
- Shared with relevant Product Providers / Mortgage Lenders / Commercial Lenders / Insurance Providers / Conveyancers to progress your application.
- Used for responding to queries related to products you take out with us.
Sharing Your Personal Data
We may share Your Personal Data with:
- Mortgage, financial, conveyancing, and insurance providers.
- Compliance advisers, product specialists, estate agents, and legal service providers (where relevant to your circumstances).
- Credit reference agencies for identity verification and credit history checks.
Marketing Communications: We may send you marketing communications about our services if you have provided explicit consent or if you are an existing customer. You can opt out at any time by contacting us or using the unsubscribe link in our emails.
Automated Decision Making & Profiling
We may use automated processing to assess your eligibility for financial products. You have the right to request a review of any automated decision and express your views regarding it.
Data Transfers Outside the UK & EEA
If we transfer your Personal Data outside the UK/EEA, we will ensure that appropriate safeguards, such as Standard Contractual Clauses, are in place to protect your data.
Security and Retention of Your Personal Data
We will keep Your Personal Data secure and protect it against unauthorised access. We also encourage you to take steps to safeguard your information, such as using encryption for sensitive emails.
Your Personal Data will be retained for a minimum of six years, or longer where required for regulatory or legal reasons.
Your Rights in Relation to Your Personal Data
You can:
- Request copies of Your Personal Data held by us.
- Ask us to explain how we use Your Personal Data.
- Ask us to correct, delete, or restrict the use of Your Personal Data.
- Request an electronic copy of Your Personal Data to be sent to another organisation.
- Withdraw consent for marketing communications at any time.
How to Contact Us
If you have any questions about this Privacy Notice or wish to exercise your rights, please contact:
Yogesh Parekh
Tel: 0116 4823435
If you have concerns about how we handle Your Personal Data, you can lodge a complaint with the Information Commissioner’s Office (ICO) at https://ico.org.uk/global/contact-us/ or by writing to:
Information Commissioner’s Office,
Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF.