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.  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 during 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 contact 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 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 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 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 voter’s 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?
 

While 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, 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

• Use your Information for the purposes of responding to any queries you may have in relation to any mortgage product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware

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

• 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 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 always acts 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.   While doing so, our Network will also process Your Information generally, including Your Special Data and Criminal Disclosures.

While 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/