Privacy Notice DATA
PRIVACY NOTICE
THE FINANCIAL
SOLUTIONS PARTNERSHIP LIMITED
We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains
important information on who we are ,
how and why we collect , store, use
and share personal data, your rights in relation to your personal data and on
how to contact us and supervisory
authorities in the event you have a complaint.
Who we are? The Financial Solutions Partnership Limited collects, uses and is responsible for
certain personal data about you. When we do so we are required to comply with data protection regulation, and we are responsible as a data controller of that personal data
for the purposes of those laws.
When we mention "we",
"us" or "our" we are referring to Company name.
Company
name is a company registered in England and Wales, company number 3449683 and
has its registered office at Lawley House,
Butt Road, Colchester, Essex CO3 3DG
We provide you with services for Commercial Mortgages, Secured Loans, Non-Regulated Bridging.
The
personal data we collect and use In the course
of providing our service to you we may collect the following personal data when you provide it to us :
•
contactinformation
•
identityinformation
• financial information
• employment status
•
lifestyle information
• public records
• health information
•
data about criminal convictions or offences
•
details of any vulnerability
•
[details of your dependents and/or beneficiaries under a policy (If you are providing information about
another person, we expect you to ensure that they know you are doing so and are
content with their information being provided to us . You might find it helpful to show them this privacy notice and
if they have any concerns please contact us
in one of the ways described below.)]
• product details
Information collected from other sources We also obtain personal data from other sources in the course of
providing our intermediary services .
Where we obtain this information from
another party it is their responsibility to make sure they explain that they
will be sharing personal data with us and ,
where necessary, ask permission before sharing information with us .
The personal
data we obtain from other sources may
include the following:
From lenders and/or product providers: product details
From identification and verification checking agencies: identity information and sanction check information
From your
Accountants
How we use your personal data The below table sets out:
•
how we use your personaldata
•
the lawful bases upon which we collect and use your personal data
•
who we routinely share your
personal data with
Rationale/Reason for
Processing
Lawful Basis for Processing
Third party recipients linked to that activity
to provide you with intermediary services
Performance of a contract
Company name
to conduct money laundering
and personal identification checks
Anti-Money Laundering and
Sanctions checks
Experian via Company name
To comply with our Principal Network
Compliance and monitoring
purposes
Company name
to apply for decisions in
principle for mortgage products and/or quotations for protection, general
insurance and Conveyancing products on your behalf and to apply for these on
your behalf
Performance of a contract
Lenders/product providers
to refer you to third party advisers to provide you with advice in
relation to Equity release
Consent
Responsible Life
to retain records of any
services or advice provided to you by us in order to defend potential legal
claims or complaints
Legitimate interests
External supplier(s) of data storage and data
hosting services to retain records on our behalf
to provide you with details
of products and services from us and third parties that may be of interest to
you in accordance with your preferences. For more information see ‘Marketing’
below
Consent
Special
category data Certain
types of personal data are considered more sensitive and so are subject to
additional levels of protection under data protection legislation. These are
known as ‘special categories of data’ and include data concerning your health,
racial or ethnic origin, genetic data and sexual orientation. Data relating to
criminal convictions or offences is also subject to additional levels of
protection.
We may process:
�
health information and lifestyle information when providing
intermediary services in relation to a protection insurance product; and/or
�
criminal conviction and offence information when providing intermediary
services in relation to a general insurance
product
�
claims information for the purpose of advising on, arranging or
administering an insurance contract
In addition to the lawful basis
for processing this information set out in the above table, we will be processing it either (1) for
the purpose of advising on, arranging or administering an insurance contract or
(2) for the establishment, exercise or defence of legal claims.
In the course of our activities
relating to the prevention, detection and investigation of financial crime, we may process criminal conviction or
offence information. Where we do so,
in addition to the lawful basis for processing this information set out in the
above table, we will be processing it
for the purpose of compliance with regulatory requirements relating to unlawful
acts and dishonesty.
Marketing We may use personal data we hold about
you to help us identify , tailor and
provide you with details of products and services from us that may be of interest to you. We will only do so where we have
obtained your consent and then have a legitimate business reason to do this and
will do so in accordance with any marketing preferences you have provided to us .
In addition, where you provided
your consent, we may provide you with
details of products and services of third parties where they may be of interest
to you.
You can opt
out of receiving marketing at any time. If you wish to amend your marketing
preferences, please contact us:
By phone: 01206 767678
By email: [email protected]
By
Post: The Financial
Solutions Partnership Limited, Lawley House, Butt Road, Colchester ESSEX CO3
3DG
Whether information
has to be provided by you, and if so why We will tell you if providing some personal data is optional,
including if we ask for your consent
to process it. In all other cases you must provide your personal data in order
for us to provide you with intermediary services .
How long your personal data will be kept We will hold your personal data
for differing periods of time depending upon the reason we have for processing
it. These retention periods are set out below.
Type of Record
Retention Period
All data collected where we
apply to a mortgage lender or Insurer.
All of your personal data
and any call recordings
Minimum of six years or for
the duration of our relationship with you in line with our regulatory
obligation with the FCA. Where we need to hold your file for longer than this
then we will inform you of this.
All data processed for a
Money laundering check and Identity check
Minimum of one year where
no business is conducted or for the duration of our relationship with you in
line with our regulatory obligation with the FCA. Where we need to hold your
file for longer than this then we will inform you of this.
All of your personal data and any call
recordings
Where no business is
transacted, we will delete all information we hold unless you email us to
confirm you wish for your data to be held and for what period.
Transfer
of your information out of the United Kingdom We will not transfer your
personal data outside of the United Kingdom or to any organisation (or
subordinate bodies) governed by public international law or which is set up
under any agreement between two or more countries.
You have a right to ask us for more information about the safeguards we have put in place as mentioned above. To learn more, please see
‘Your rights’ below.
Your rights You have legal rights under data protection regulation in relation to your personal data. These
are set out under the below headings:
�
To access personaldata
�
To correct / erase personal data
�
To restrict how we use personal data
�
To object to how we use personal data
�
To ask us to transfer
personal data to another organisation
�
To object to automated decisions
�
To find out more about how we use personal data
We may ask you for proof of identity when making a request to
exercise any of these rights. We do
this to ensure we only disclose
information or change your details where we
know we are dealing with the
right individual.
We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where
a fee is necessary, we will inform
you before proceeding with your request.
We aim to respond to all valid requests within one month. It may
however take us longer if the request is particularly complicated or you have
made several requests. We will always
let you know if we think a response
will take longer than one month. To speed up our response , we may ask
you to provide more detail about what you want to receive or are concerned
about.
We may not always be able to
fully address your request, for example if it would impact the duty of
confidentiality we owe to others, or
if
we are otherwise legally
entitled to deal with the request in a different way.
To access personal data (also known as Subject
Access Request (SAR) You can ask us to confirm whether or not we
have and are using your personal data. You can also ask to get a copy of
your personal data from us and for
information on how we process it.We
will respond to requests within one month
To rectify / erase personal data You can ask that we rectify any information about you
which is incorrect. We will be happy
to rectify such information but would need to verify the accuracy of the
information first.
You can ask that we erase your personal data if you think we no longer need to use it for the
purpose we collected it from you.
You can also ask that we erase your personal data if you have
either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to
object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to
erase your personal data.
We may not always be able to comply with your request, for example
where we need to keep using your
personal data in order to comply with our
legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
To restrict our use of personal data You can ask that we restrict our use of your personal data in certain circumstances, for example
•
where you think the information is inaccurate and we need to verify it;
•
where our use of your
personal data is not lawful, but you do not want us to erase it;
•
where the information is no longer required for the purposes for which
it was collected but we need it to
establish, exercise or defend legal claims;or
•
where you have objected
to our use of your personal
data, but we still need to verify ifwe have overriding grounds
to use it.
We can continue to use your personal data following a request for
restriction where we have your
consent to use it; or we need to use
it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a
company.
To object to use of personal data You can object to any use of
your personal data which we have justified on the basis of our legitimate interest, if you believe your
fundamental rights and freedoms to data protection outweigh our legitimate interest in using the
information. If you raise an objection, we
may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
To request a transfer of personal data You can ask us to provide your personal data to you
in a structured, commonly used, machine-readable format, or you can ask to have
it transferred directly to another data
controller (e.g. another company).
You may only exercise this right
where we use your personal data in
order to perform a contract with you, or where we asked for your consent to use your personal data. This right
does not apply to any personal data which we
hold or process outside automated means.
To contest decisions based on automatic decision making If we made a decision about you based solely by automated means (i.e.
with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects
you, you may have the right to contest that decision, express your point of
view and ask for a human review. These rights do not apply where we are authorised by law to make such
decisions and have adopted suitable safeguards in our decision -making processes to protect your rights and freedoms.
You can contact us for more information If you are not satisfied with the
level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have how
you can make a complaint, where we got your data from and whether we have carried
out any automated decision making using your personal data.
•
let us have enough information to identify you, e.g. name, address,
date of birth;
•
let us have proof of your identity and address(a copy of your driving licence or passport and are centutility or credit card bill);
and
•
let us know the information to which your request relates.
•
If you would like to exercise any of the above rights,please:
•
contact John Schultz
• Email:
johnschultz@financial solutionsonline.co.uk
• Postal:
The Financial Solutions Partnership Ltd, Lawley House, Butt Road, Colchester,
ESSEX CO3 3DG
Keeping your personal data secure We have appropriate security measures in place to prevent personal
data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to
those who have a genuine business need to know it. Those processing your
information will do so only in an authorised manner and are subject to a duty
of confidentiality.
We also have procedures in place to deal with any suspected data
security breach. We will notify you
and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our
supervisory authority If you are not happy with the
way we are handling your information,
you have a right to lodge a complaint with the Information Commissioners
Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt
to resolve any issues with us before the ICO.
