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Why are we asking you to 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 Your Personal Data.


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, 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 and Insurance requirements Your Personal Data may include: 

  • Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity 

  • Information about your employment status including whether you are employed, self-employed, retired or receive benefits; remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history 

  • Bank account details, details of your savings, 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 regards to the processing we may undertake in relation to this type of information) 

  • Any pre-existing Mortgage and Insurance products and the terms and conditions relating to these.

  • Biometric data and information used for authentication purposes, such as facial recognition or fingerprint scans.

  • Documents provided by you for identity verification, such as government-issued identification documents.

  • Credit Information obtained from third-party credit rating agencies to assess your creditworthiness, including credit scores and credit history.Records of how you have contacted us and, if you get in touch with us online, details such as your mobile phone location data, IP address and MAC address;

  • Personal data about your credit history which we obtain from Credit Reference Agencies (CRA) including data which originates from Royal Mail (UK postal addresses), local authorities (electoral roll), the insolvency service, Companies’ House, other lenders and providers of credit (who supply data to the CRAs), court judgments decrees and administration orders made publicly available through statutory public registers (see the section on ‘Credit Reference Agencies’ below);

  • Information about your occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property in which you live at the time of your application;

  • Information which is relevant for your residency and/or citizenship status, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK;

  • Your marital status, family, lifestyle or social circumstances if relevant to the mortgage product (e.g. the number of dependents you have or if you are a widow or widower); and

  • Where relevant, information about any guarantor which you provide in any application.



The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your Mortgage 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 to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed 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 Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject. For example, we may need to respond to requests from insurance providers and our Firm may contact you to seek feedback on the service you received. 
On occasion, we will use Your Personal Data to enable us to meet compliance with legal or regulatory obligation to which we might be subject. This includes sharing Your Personal Data with all applicable regulators such as the Financial Conduct Authority (FCA) and the Information Commissioner.
 
The basis upon which we will process certain parts of Your Personal Data

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 or other dependants, it is also very likely that we will record information that relates to them 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 offenses (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management. 
We will use Special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.
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.
When we make reference in the remainder of this document to Your Personal Data this includes Your Special Data and Criminal Disclosures.


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 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. If you are introduced to us by a broker or other intermediary, they will provide us with the personal data you give them.
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 Personal Data, for example software that is able to verify your credit status, we will only do so if we have consent from you, for us, or our nominated processor to access your information in this manner. With regards to electronic ID checks, we will inform you of how such software operates and the purpose for which it is used.
In addition, we may obtain personal data about you from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, your employer, landlord, other lenders, HMRC, DWP, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.
Some of the personal data obtained from Credit Reference Agencies will have originated from publicly accessible sources.  In particular, Credit Reference Agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll).  


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, 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 firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.

  • Submit Your Personal Data to Mortgage Lenders, Product Providers and Insurance 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 lenders and providers may raise.

  • Use Your Personal Data for the purposes of responding to any queries you may have in relation to any Mortgage or insurance policy 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.

  • Use Your Personal Data to analyse your personal and financial circumstances and provide tailored mortgage product recommendations.

  • Verify your identity and authenticate your access to the Application using biometric data and document verification.

  • Assess your creditworthiness and eligibility for mortgage products by obtaining information from third-party credit rating agencies.



Sharing and transferring Your Personal Data 

From time to time Your Personal Data will be shared with:

  • 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, 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 circumstances) 

  • contractors or suppliers who we may engage to assist us with any customer feedback exercises 

  • our professional indemnity insurers, brokers, claims handlers and legal advisers and another person who may provide professional services in connection with the handling of a complaint, litigation, or investigation 

  • any person we may engage in connection with any investigation to detect, prevent or investigate financial crime, including those that may be carried out by or in conjunction with insurance providers and regulators 

  • contractors or suppliers who we may engage with to assist us with discharging our compliance obligations arising out of FCA regulation 

  • Third-Party Service Providers who we may engage to assist us in providing the Application, including authentication services and credit assessment agencies.

  • Our affiliates for internal business purposes.

Third parties to whom we may be required to disclose your information in order to comply with applicable laws, regulations, or legal processes.in each case for the purposes set out in this customer privacy notice, i.e., to progress your Mortgage and Insurance 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 for the purpose of ensuring we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice. 
Although your personal data will be held within the European Economic Area, for the purposes of performing our professional services, you explicitly authorise and grant consent, to the collection, receipt, use, retention, recording, storage and transfer, in electronic or other form, of your personal data by and amongst the employees and consultants within our firm and our support team from W.I.S. Accountancy (Private) Limited based in Colombo, Sri Lanka.
You understand that upon the transfer of personal data, the recipient's country Sri Lanka have adequate but different data privacy laws and protections than that of the United Kingdom. Therefore, we shall take all reasonable steps to ensure the protection of your individual rights and the protection of your personal data from loss, misuse, unauthorized copying, disclosure, dissemination, alteration or destruction.
The personal data transferred to Sri Lanka will be held for a period only as long as is necessary to process the information and complete the assigned tasks and to the extent required by the applicable law, you may, at any time, request details of any potential recipients of your personal data, request additional information about the storage and processing of data, and request for any necessary amendments and rectification to that data.
We also use third party suppliers who may transfer data to, or store data in, locations both inside and outside the UK. We also share some personal data with Credit Reference Agencies as well as Money Laundering Prevention Services and Fraud Prevention Agencies who may have operations both inside and outside of the UK.  Whenever information is sent to locations outside of the UK, we will ensure that there are suitable safeguards to protect it.


Security and retention of Your Personal Data

Your privacy is important to us, and we will keep Your Personal Date secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard against Your Personal Data being accessed unlawfully or maliciously by a third party, accidentally lost, destroyed, or damaged. We are committed to protecting the security of your personal information and have implemented appropriate technical and organizational measures to safeguard your data.
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 Personal Data will be retained by us either electronically or in paper format for a minimum of six years following the advice or service you receive from us, although your data could be held for a longer period where this may be needed to meet the regulatory requirements of our regulatory bodies.


Your rights in relation to Your Personal Data

You can:

  • request copies of Your Personal Data that is 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 

  • 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 contact our Firm 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: 
MortgagX, Abbey House, 25 Clarendon Road, Redhill, RH1 1QZ or telephone 0203 011 3227. 
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 contact 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 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.

Customer Privacy Notice

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