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 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 Mortgages, Finance, Insurance and Estate Planning 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/other benefits), 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, medical reports (further details are provided below specifically with regard to the processing
- we may undertake in relation to this type of information)
- Any pre-existing Mortgages, Finance, Insurance and Estate Planning products and the terms and conditions relating to these.
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:
Advising and arranging on Mortgages, Finance, Insurance and Estate Planning.
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 Mortgages, Finance, Insurance and Estate Planning 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.
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/guidance 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 (together “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.
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 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. If we 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 only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards 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.
Technologies such as: cookies, beacons, tags and scripts are used by Niche Advice Limited and our partners [such as technology mortgage sourcing systems], affiliates, or service providers [such as analytics service providers].
These technologies are used in analysing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
The Internet is not a 100% secure medium for communication and, accordingly, Niche Advice Limited cannot 100% guarantee the security of any information you send to us via the Internet. Niche Advice Limited is not responsible for any loss or damage you or others may suffer as a result of the loss of confidentiality of such information.
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 (websites, 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 Mortgages, Finance, Insurance and Estate Planning Product providers both in paper form and on-line 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 and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any Mortgages, Finance, Insurance and Estate Planning you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
- Mortgages, Finance, Insurance and Estate Planning providers.
- 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, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).
- In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your Mortgages, Finance, Insurance and Estate Planning providers enquiry 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.
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.
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 legal right to such information we will retain records indefinitely.
- 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, delete or require us to restrict or stop using Your Personal Data (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 any consent in its entirety).
Richard Stokes, Data Control Officer.
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.