Sail Mortgages Ltd, take your personal information and data privacy seriously, please read through this document to understand how we do this.
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 with your personal advice requirements, your Personal Data may include:
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. We also need this in order to be able to provide you with fully and properly personalised advice, tailored to your specific circumstances.
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, we may need to respond to requests from mortgage lenders, regulators, 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. 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.
When discussing your financial plans we will need to ask you about your ethnic origin, your health and medical history (Your Special Category Data). We will record and use Your Special Category Data in order to ensure we recommendations and use products that meet your needs fully. For example, health information can have an impact on underwriting for life cover, as well as on life expectancy when considering investments and pensions. We need to be able to ensure that we have sufficient information about these points to ensure that the products recommended are fully suited to your individual needs.
If you have parental responsibility for children under the age of 13, we may need to record information on our systems that relates to those children and potentially, to their Special Category Data. This might be necessary if you had a child with a long-term health problem or disability, for example.
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.
We will use Special Category 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 discussing your financial plans we will need to ask you about your ethnic origin, your health and medical history (Your Special Category Data). We will record and use Your Special Category Data in order to ensure we recommendations and use products that meet your needs fully. For example, health information can have an impact on underwriting for life cover, as well as on life expectancy when considering investments and pensions. We need to be able to ensure that we have sufficient information about these points to ensure that the products recommended are fully suited to your individual needs.
If you have parental responsibility for children under the age of 13, we may need to record information on our systems that relates to those children and potentially, to their Special Category Data. This might be necessary if you had a child with a long-term health problem or disability, for example.
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.
We will use Special Category 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.
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. 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. We may need to 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 need to conduct an electronic ID check to comply with anti-money-laundering rules. This will include a Politically Exposed Persons (PEP) and Sanctions check. On some occasions we may ask you to supply a Passport or Driving Licence number, as this can be required to complete an electronic ID check.
In the course of handling Your Personal Data, we will:
From time to time Your Personal Data will be shared with:
In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice. i.e. to progress in helping us to meet your financial requirements, 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.
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 in instances whereby we have the legal right or regulatory requirement to hold records indefinitely for complaint handling purposes.
You can:
Some data is provided jointly, for example on a joint mortgage. If we are later asked by just one person to provide a copy of the data held, we will also need consent from the other person. This is because joint personal information provided for advice and applications cannot later be separated out.
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 our principal firm:
Address: The Data Protection Officer, Rosemount Financial Solutions (IFA) Ltd, Rosemount House, 2-4 Chequers Road, Basingstoke, Hampshire, RG21 7PU
Or Tel: 01256405460
If we feel we have a legal right not to deal with your request, or to action, it in 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 by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Please keep this Privacy Notice stored safely along with the Client Agreement and any other advice related documents that you receive later in the process. The Declaration page on your Client Agreement makes reference to this Privacy Notice. Your declaration and signature will confirm your consent for us to process your personal data for the purposes stated in this Customer Privacy Notice.
As part of ensuring that our advice to you remains suitable over the longer term, we may need to contact you in future. As an example, we may need to do this if we have recommended a fixed term mortgage deal, where the term is shortly coming to an end.
If you have any questions about this Privacy Notice, you can reach out to us using the form on our contact page or via details below:
Phone – 07986 641318
Email – lisa.neath@sailmortgages.co.uk
© 2024 All Rights Reserved | Privacy Policy | Privacy Notice
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