How we collect, use and protect your personal data.
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.
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, Finance and/or Insurance requirements Your Personal Data may include:
When we speak with you about your mortgage, finance and/or 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 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 interest to do so and your rights are not affected — for example, to respond to requests from mortgage lenders, insurance providers and our Compliance 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 will use Your Personal Data for contractual responsibilities we may owe our regulator, the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject.
Where you ask us to assist you with, for example, your insurance — 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 13, it is also very likely that we 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 (Criminal Disclosures). This is relevant to insurance related activities such as underwriting, claims and fraud management. 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.
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you, 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. Where we use technology solutions to assist in collecting Your Personal Data, we will only do this with your consent, except with regards to electronic ID checks, where consent is not required but we will inform you how the software operates and its purpose.
From time to time Your Personal Data will be shared with mortgage lenders, finance lenders and insurance providers, and with third parties who we believe will be able to assist us with your enquiry or application — including our compliance advisers, product specialists, estate agents, and providers of legal services such as estate planners, conveyancing, surveyors and valuers, where relevant to your circumstances.
Your Personal Data will only be shared for the purposes set out in this notice, i.e. to progress your enquiry and provide you with our professional services. This sharing does not entitle third parties to send you marketing or promotional messages.
We do not envisage that the performance of our service will involve Your Personal Data being transferred outside of the UK or European Economic Area other than as necessary to deliver our services.
When you complete our online fact find, Your Personal Data is processed using the following technology providers, each acting as a data processor on our behalf and bound by their own data processing terms:
Where any of these providers process data outside of the UK, appropriate safeguards are in place in accordance with UK data protection law.
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities, taking reasonable steps to safeguard it against unlawful or malicious access. We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us — for example, not sending confidential information over unprotected email.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or indefinitely where we have a legal right to retain such information.
You can:
If you have any questions or comments about this document, or wish to exercise any of your rights, please contact: Robert Kewley — 03301 33 11 43 — rob@node-finance.co.uk.
If we feel we have a legal right not to deal with your request, or to action it differently 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 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, via ico.org.uk or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.