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What do we mean by "Your Personal Data"?
Your Personal Data means any information that describes or relates to your personal circumstances. It may identify you directly, for example your name, address, date of birth or National Insurance number. It 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/or 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.
- Employment and remuneration information (including salary, bonus schemes, overtime, sick pay and other benefits) and employment history.
- Bank account details, 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, and medical reports.
- Any pre-existing mortgage and/or insurance products and the terms and conditions relating to these.
The basis on which our firm will deal with Your Personal Data
When we speak with you about your mortgage 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, we may need 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.
Special category data
Where you ask us to assist you with insurance, in particular life insurance and insurance that may assist you in the event of an accident or illness, we will ask you for information about your ethnic origin, your health and your medical history ("Your Special Data"). We will record and use Your Special Data in order to make enquiries of insurance providers in relation to 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. 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.
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, needs and preferences in relation to mortgages and insurance. You will provide information to us verbally and in writing, including by email and through the form on this page.
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 electoral roll. Where we use technology solutions to assist in the collection of Your Personal Data, we will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regard to electronic ID checks we would not require your consent, but will inform you of how such software operates and the purpose for which it is used.
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 (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 product providers, mortgage lenders, commercial lenders and/or insurance product providers, both in paper form and online 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.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage, finance product or insurance policy you may take out, or to inform you of any developments in relation to those products of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with mortgage and finance lenders and insurance providers, and with 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. These third parties will include but may not be limited to our compliance advisers, product specialists, estate agents, and providers of legal services such as estate planners, conveyancers, surveyors and valuers.
In each case, Your Personal Data will only be shared for the purposes set out in this notice: to progress your mortgage and/or insurance enquiry and to provide you with our professional services. This sharing does not entitle such third parties to send you marketing or promotional messages. We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Security and retention of Your Personal Data
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 where we have a legal right to such information, we will retain records indefinitely.
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 or delete Your Personal Data, or require us to restrict or stop using it. 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 that consent in its entirety.
How to contact us about 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 Rebecca Wilkins at protection@cemtgs.co.uk or on 01289 388 736.
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 make contact with us as soon as possible upon 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 ico.org.uk or by writing to Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Cutting Edge Mortgages LTD · 5 Morris Hall Cottages, Berwick Upon Tweed, TD15 2JY · FCA reference 922009.
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