The data we collect about you
Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different types of personal data about you which we have grouped together as follows:
- Identifying Information: i.e. information used to identify a specific individual such as given name(s), date of birth
- Contact information: e.g. postal address, telephone number, email address
- Family information: e.g. family structure, siblings
- Financial information: e.g. bank account number and sort code
If you fail to provide personal data
Where we need to collect your personal data under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you and we may have to terminate the provisions of services or decline the requested performance of a task.
The basis upon which our company will deal with Your Personal Data
When we speak with you about your 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 to 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 interests to do so and your rights are not affected. For example, we may need to respond to requests from our service provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we may use Your Personal Data in accordance with responsibilities we may owe our regulator, the Financial Conduct Authority, or compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial conversations with you to establish your circumstances, needs and preferences in relation to finance. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit/bankruptcy checks and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data, for example software that is able to verify your identity on-line or to access your credit/bankruptcy status, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner, details of how such software operates will be provided to you prior to the activation of the service.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
Record and store Your Personal Data in our paper files, on mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our company and only when it is necessary to provide our services to you and to perform any administration tasks associated with or incidental to that service.
Submit Your Personal Data to product providers, both in paper form and on-line via a secure portal. The provision of this
information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that may raise.
Use Your Personal Data for the purposes of responding to any queries you may have in relation to any finance product you may take out, or to inform you of any developments in relation to those products and/or policies of which we might become aware.
Sharing Your Personal Data
From time to time, Your Personal Data will be shared with third parties who we believe will be able to assist us with your
enquiry or application, or who are able to support your needs as identified.
These third parties may include, but may not be limited to, our compliance advisers, IT providers, product specialists, estate agents, providers of legal services such as estate planners, surveyors, valuers and conveyancers (in each case where we believe this to be required due to your particular circumstances). We may also provide data to other Group companies, our auditors/advisers, and other third parties where required to by law or in accordance with our regulatory requirements.
In each case, Your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your finance enquiry and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages. It is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either, electronically or in paper format, for a minimum of six years, or if longer than six years, the duration of our company’s relationship with you.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that we have under our control;
- ask us to further explain how we use Your Personal Data;
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request);
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish; and/or
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety).
How to make contact with our company in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact: firstname.lastname@example.org
If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your
Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data, you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/
or in writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.