PRIVACY
POLICY
Swansea
Mortgage Brokers Limited is committed to protecting your privacy
Company number: 12848308 Registered in
England and Wales
Registered address: 136 Walter Road,
Swansea SA1 5RQ
Privacy Notice
Swansea
Mortgage Brokers Limited is an Appointed Representative of PRIMIS Mortgage
Network, a trading name of Personal Touch Financial Services Limited. Personal
Touch Financial Services Limited is authorised and regulated by the Financial
Conduct Authority.
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 Information). We would like to explain
to you what we will need to do with your information, and the various rights
you have in relation to your information.
“Your Information”
Your
Information means any information describing or relating to you. Your
Information may identify you directly, for example your name, address, date of
birth, National Insurance number and the like. Your Information 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
and/or insurance requirements, Your Information may include:
–
Titles, names, date of birth, gender, nationality, civil/marital status,
contact details, addresses and documents that are necessary to verify your
identity
–
Employment and remuneration information, (including salary/bonus
schemes/overtime/sick pay/other benefits), 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 specifically with regard to the processing
we may undertake in relation to this type of information)
–
Any pre-existing mortgage and/or insurance products and the terms and
conditions relating to these
The
basis upon which our Firm will deal with Your Information
When
we speak with you about your mortgage and/or insurance requirements we do so on
the basis that a contract for the supply of services is
in place between us. In order to perform that contract, and to arrange the
products you require, we have the right to use Your Information for the
purposes we set out 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 Information 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 Network 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 will use Your Information to enable us to meet any
contractual responsibilities we may owe our Network, or for wider compliance
with any legal or regulatory obligation to which we might be subject. If
this were to arise we would be processing Your Information in order to
meet a legal, compliance or other regulatory obligation to which we are
subject.
The basis upon which we will process
certain parts of Your Information
Where you
ask us to assist you with your insurance needs, in particular
life insurance and insurance that may assist you in the event of an
accident or illness, we will ask you information about your ethnic origin,
your health and medical history (Your Special Data). We will
record and use Your Special Data in order to make enquiries of insurance
providers in relation to insurance products that may meet your needs and
to provide you with advice regarding the suitability of any product
that may be available to you.
If
you have parental responsibility for children under the age of 16 it is
also very likely that we (and consequently our Network) will record
information on our systems that relates to those children and potentially,
to their Special Data.
The
arrangement of certain types of insurance may involve disclosure by you to us
of information relating to historic or current criminal convictions or
offences(together “Criminal Disclosures”).
This is relevant to insurance related activities such as underwriting, claims
and fraud management.
Your
Special Data and any Criminal Disclosures will be used by us in the same way as
Your Information generally, as set out in this Customer Privacy Notice.
When
we process your Special Data and any Criminal Disclosures we do so on the basis
that it is in the substantial public interest to be able to provide vital
insurance products and as permitted by UK data protection related laws and
regulations from time to time. Information on Special Category Data and
Criminal Disclosures must be capable of being exchanged freely between
insurance intermediaries such as our Firm, and insurance providers, to enable
customers to secure the important insurance protection that their needs
require.
How do we collect Your Information?
We
will collect and record Your Information from a variety of sources, but mainly
directly from you. You will usually provide information during the course of
our initial meetings or conversations with you to establish your circumstances
and needs and preferences in relation to mortgages and insurance. You
will provide information to us verbally and in writing, including email.
We
may also obtain some information from third parties, for example, credit
checks, information from your employer, 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 Information, such as software that is able to
verify your identity on-line or to access your credit status and/or bank
account entries, then you will be required to provide your consent for us or
our nominated processor to access your information in this manner, and details
of how such software operates will be provided to you prior to the activation
of the service.
What happens to Your Information when
it is disclosed to us?
In
the course of handling Your Information we will:
–
Record and store Your Information in our paper files, mobile devices and on our
computer systems (websites, email, hard drives, cloud facilities) and it
will be accessed by employees and consultants within, or contractors engaged,
by our Firm as necessary to provide our service to you and to perform any
administration tasks associated with or incidental to that service
–
Submit Your Information to mortgage lenders and/or insurance product providers,
both in paper form and on-line via mortgage lender/insurance provider systems, in
order to progress any enquiry or application made on your behalf and to deal
with any additional questions or administrative issues that mortgage lenders
and insurance providers may raise
– Input
Your Information, along with full details of the mortgage and/or
insurance, discussed with you or which you have taken out, to the computer
systems of our Network.
Sharing and transferring Your
Information
From
time to time Your Information will be shared with or transferred to:
–
Our Network
– To
mortgage lenders and insurance providers
– To
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, such third
parties will include but may not be limited to, product specialists (including
those within our Network and other Appointed Representatives of the Network),
estate agents, providers of legal services such as conveyancing, surveyors and
valuers (in each case where we believe this to be required due to your
particular circumstances)
In
each case for the purposes set out in this customer privacy notice, i.e. to
progress your mortgage and/or insurance enquiry and to provide you with our
professional services.
Please
note that this sharing of Your Information does not entitle such third parties
to send you marketing or promotional messages: it is shared for the purpose of
ensuring we can adequately fulfil our responsibilities to you, and as otherwise
set out in this Customer Privacy Notice.
These
parties may be located in the UK or elsewhere in the world where different
privacy laws may apply which may not offer the same level of protection as UK
law. We only make these arrangements or transfers where we are satisfied that
adequate levels of protection are in place to protect any information held in
that country and that the service provider acts at all times in compliance with
applicable privacy laws.
The basis upon which our Network will
deal with Your Information, Your Special Data and Criminal Disclosures
Our Network
is authorised and regulated by the Financial Conduct Authority (FCA). Our Network
is responsible for the quality of the advice that we provide to you in
relation to your mortgage and/or insurance products, where those products
are regulated by the FCA. In the course of doing so, our Network
will also process Your Information generally, including Your Special Data
and Criminal Disclosures. In the course of handling Your Information and
Your Special Data/Criminal Disclosures our Network will:
– Record
and store Your Information and Your Special Data/Criminal Disclosures on
Network systems run on secure servers. Your Information and Your Special
Data/Criminal Disclosures will be accessed by authorised employees and
consultants within, or engaged, by the Network as necessary for the purposes of
supervision, training, quality audits, customer surveys and complaint handling
or otherwise to comply with any other legal or regulatory obligation the
Network may have
–
Use, and where appropriate transmit, Your Information and Your Special
Data/Criminal Disclosures to respond to any request from the FCA, the Financial
Ombudsman Service, HMRC, the Office of the Information Commissioner or any
other regulatory, law enforcement or governmental body
– Need
to access and process Your Information and Your Special Data/Criminal
Disclosures to deal with enquiries received from mortgage lenders and insurance
providers that relate to the service this Firm has provided to you, including
the payment of any commission or fees to us that may be linked to the product
you have taken out.
Your
Information and Your Special Data/Criminal Disclosures will be retained by our
Network either electronically or in paper format for a minimum of six years and
possibly for a longer period where this is required to enable the Network to
fulfil its legal and regulatory obligations.
Please
note that the above information is a summary of the Network Privacy Policy for
customers. If, you wish to understand in more detail what the Network
will do with Your Information and Special Data/Criminal Disclosures then please
visit the Network Privacy Policy for customers located at https://www.primis.co.uk/index.php/terms-and-conditions/
Security and retention of Your
Information
Your
privacy is important to us and we will keep Your Information secure in
accordance with our legal responsibilities. We will take reasonable steps to
safeguard against Your Information being accessed unlawfully or maliciously by
a third party, accidentally lost, destroyed or damaged.
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 sent to us.
Your
Information 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 this
Firm’s relationship with you.
Your rights in relation to Your
Information
You
can:
–
Request copies of Your Information that is under our control
–
Ask us to further explain how we use Your Information
–
Ask us to correct, delete or require us to restrict or stop using Your
Information (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 Information to another
organisation should you wish
–
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 Firm in
relation to the use of Your Information
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:
Swansea
Mortgage Brokers
Tel
– 01792278299
Email
– enquiries@swanseamortgagebrokers.co.uk
If
we feel we have a legal right not to deal with your request, or to action it
indifferent 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 Information, 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 Information
or Your Special Data/Criminal Disclosures 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 by writing
to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF.
Internet Privacy
This
site does not automatically collect or store personal information regarding its
users. The site may log the IP address and session information, such as the
duration of visit and type of software used to access the site. This data is
used solely for the administration of the site and for statistical purposes to
enable us to evaluate the services offered.
We
do not use cookies for the collection of personal information; however, they
may be used to store information regarding your visits to the site, and to
recall information previously entered by yourself for the purposes of site
interaction. this information will be stored on your computer only and will not
be collected, stored or processed by us.
We
may ask you for personal information in order to make available specific
services you wish to take part in such as newsletters, of financial
services. In each case we will use the information to provide you with
the specified services. We will also use and retain information regarding
regulated services in order to comply with the requirements of the Financial
Conduct Authority and may transmit data to our auditors and
regulators for the purposes of compliance with the requirements of the Financial
Conduct Authority. This may include transmission of
information outside the European Economic Area. Where this is the case
your information will be treated in accordance with the UK Data Protection Act
1998.
Where
we wish to collect information for the purposes of marketing, we will make this
clear before any information is collected.
This
privacy statement applies to all pages within the regulated site.
Summary
of Terms
IP
Address –
A series of numbers used to identify your computer, in order to access content
on the Internet (e.g. 255.0.01). For users accessing via an Internet
service Provider, e.g. AOL this will often be different every time you log on
and cannot be used to personally identify you unless your Internet Service
Provider provides that information.
Cookie – A small
file containing only text, which can be created by your internet software when
sent an instruction to do so by a web site. Your internet software (e.g.
Internet Explorer) will have various settings to control the use of these,
however turning them off may limit the content available to you on the
internet.