Privacy Policy

Why you should read this document

During the course of dealing with us, we will ask you to provide detailed personal information relating to your circumstances, your financial situation and, in some cases, your health and family health history. This document explains what we need to do with your personal data and the rights you have in relation to it.

What we mean by Your Personal Data

Your Personal Data means any information that describes or relates to your personal circumstances. It may identify you directly, for example your name, address, date of birth or national insurance number, or indirectly, for example information about your employment, health history or any information associated with your cultural or social identity.

In the context of assisting with mortgage, finance and insurance requirements, this may include:

• Title, name, date of birth, gender, nationality, civil or marital status, contact details, addresses and documents required to verify your identity
• Employment and remuneration information such as salary, bonus or 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 dependants
• Health status and history, treatment details and medical reports where relevant to the products or services you ask us to arrange
• Details of any existing mortgage, finance or insurance products and the terms and conditions relating to them

Our lawful basis for using Your Personal Data

When we speak with you about your mortgage, finance or insurance requirements we do so on the basis that both parties are entering a contract for the supply of services. To perform that contract and arrange the products you require, we have the right to use your data for the purposes set out in this notice.

We may also process Your Personal Data where it is in our legitimate interests to do so and your rights are not affected. For example, responding to requests from lenders, insurance providers or our compliance service provider, seeking feedback on the service you received, meeting obligations to our regulator or complying with the law.

Processing Special Category and Criminal Disclosures

Where you ask us to assist with insurance needs, particularly life insurance or cover that may assist in the event of accident or illness, we may ask about your ethnic origin, health and medical history. We record and use this to make enquiries with providers in relation to products that may meet your needs and to provide advice on suitability.

We may also need information about criminal convictions or offences where relevant to insurance related activities such as underwriting, claims and fraud management. We will handle Special Category Data and Criminal Disclosures in the same way as other personal data, as set out in this notice.

How we collect Your Personal Data

We collect data mainly from you, during meetings or conversations to establish your circumstances, needs and preferences. You may provide information verbally and in writing, including by email.

We may also obtain information from third parties, for example credit checks, your employer, or searches of public information such as the electoral roll. Technology solutions may be used to assist with collection, for example software that verifies credit status. Where electronic ID checks are undertaken we will inform you about how they operate and why they are used.

What happens when your data is disclosed

• We record and store Your Personal Data in paper files, mobile devices and on our computer systems such as email, hard drives and cloud services. Access is limited to employees and consultants when necessary to provide our service and to perform related administration.
• We submit Your Personal Data to product providers including mortgage and finance lenders and insurance providers, both in paper form and online through secure portals, so we can progress enquiries and applications and deal with any additional questions or issues they raise.
• We use Your Personal Data to respond to queries you may have and to inform you of developments related to products or policies of which we become aware.

Sharing Your Personal Data

From time to time we share Your Personal Data with:

• Investment providers, mortgage lenders, finance lenders, insurance providers, subsidiaries and partner companies
• Third parties able to assist with your enquiry or application, such as compliance advisers, product specialists, estate agents, providers of legal services including conveyancers, surveyors and valuers where required due to your circumstances

Your data is shared only for the purposes set out in this notice, namely to progress your enquiry and provide our professional services. It does not entitle third parties to send you marketing messages.

We do not envisage that delivering our service will involve transferring Your Personal Data outside the European Economic Area.

Security and retention

We keep Your Personal Data secure in line with our legal responsibilities and take reasonable steps to protect it against unauthorised or unlawful access or malicious activity. We also ask you to take sensible steps when sending information to us, for example avoiding unprotected email for confidential data and using secure methods of postage for original documents.

Your Personal Data will be retained electronically or in paper format for a minimum of six years, or longer where we have a legal right to do so.

Your rights

• Request copies of Your Personal Data we control
• Ask us to explain how we use Your Personal Data
• Ask us to correct, delete, restrict or stop using Your Personal Data where applicable
• Ask us to send an electronic copy of Your Personal Data to another organisation
• Change the basis of any consent you previously provided, including withdrawing it in full

How to contact us

If you have questions about this notice or wish to exercise any of your rights, please contact:

If we have a legal right not to deal with your request, or to act in a different way to how you have requested, we will inform you of this at the time. Please also contact us as soon as possible if you become aware of any unauthorised disclosure of Your Personal Data.

Contacting the ICO

If you have concerns or complaints about how we have handled Your Personal Data, you may lodge a complaint with the UK's data protection regulator, the Information Commissioner's Office:

Website: ico.org.uk/global/contact-us/
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF