Customer Privacy Notice

Why should you read this document?

During the course of dealing with us, we will ask you to provide detailed personal information relating to your circumstances, financial situation and, in some cases, your health and family health history (“Your Personal Data”). This document explains how we use Your Personal Data and the rights you have in relation to it.

What do we mean by “Your Personal Data”?

Your Personal Data includes any information that describes or relates to your personal circumstances. This may identify you directly (e.g. name, address, date of birth, national insurance number) or indirectly (e.g. employment situation, health history, financial information).

In the context of providing investment, mortgage, finance or insurance services, Your Personal Data may include:

• Title, name, date of birth, gender, nationality, marital status, contact details and identity verification documents
• Employment and remuneration information, including salary, bonuses, overtime, sick pay and benefits
• Bank details, tax information, loans, credit commitments, credit history, income and expenditure, family circumstances and dependents
• Health status and medical history, treatment details and medical reports
• Details of existing investment, mortgage, finance or insurance products

The basis upon which we will deal with Your Personal Data

When we discuss your investment, mortgage, finance or insurance requirements, we do so on the basis that both parties are entering into a contract for the supply of services. We use Your Personal Data to perform that contract and arrange the products you require.

We may also use Your Personal Data where it is in our legitimate business interests to do so and your rights are not affected. For example, responding to lender or provider queries, or seeking feedback on our service.

On occasion, we may process Your Personal Data to meet legal or regulatory obligations, including those required by the Financial Conduct Authority.

Processing Special Category Data and Criminal Disclosures

When assisting with insurance or ethical investment products, we may need to process information relating to your health, medical history or ethnic origin (“Special Data”). We use this to obtain quotations and assess product suitability.

We may also process information relating to criminal convictions (“Criminal Disclosures”) where relevant to insurance underwriting or fraud prevention.

Special Data and Criminal Disclosures are processed in the same way as Your Personal Data and may be shared with insurers where necessary.

How do we collect Your Personal Data?

We collect Your Personal Data mainly directly from you during meetings, calls or written communication. We may also obtain information from:

• Credit reference agencies
• Your employer
• Public sources such as the electoral register
• Technology solutions used to verify identity or credit status

What happens to Your Personal Data when it is disclosed to us?

• We store Your Personal Data in paper files, mobile devices and secure computer systems
• We submit Your Personal Data to product providers, lenders and insurers via secure channels
• We use Your Personal Data to respond to queries and keep you informed about your products

Sharing Your Personal Data

Your Personal Data may be shared with:

• Investment providers, mortgage lenders, finance lenders and insurance providers
• Compliance advisers and product specialists
• Estate agents, legal service providers, conveyancers, surveyors and valuers

Your Personal Data is shared only to progress your enquiry or application. It is not shared for marketing purposes.

We do not expect Your Personal Data to be transferred outside the UK or EEA.

Security and retention of Your Personal Data

We take reasonable steps to safeguard Your Personal Data against unlawful access. We expect you to take similar precautions when sending information to us.

Your Personal Data will be retained for at least 6 years following the advice or service provided, or longer if required by regulatory bodies.

Your rights in relation to Your Personal Data

You can: