Why should you read this document?
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.
What do we mean by "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 and 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 in relation to your mortgage and/or insurance requirements, Your Personal Data may include:
- Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents necessary to verify your identity.
- Employment and remuneration information (including salary, bonus schemes, overtime, sick pay and other benefits), together with employment history.
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants.
- Health status and history, details of treatment and prognosis, and medical reports (further details are provided below regarding the processing of this information).
- Any pre-existing mortgage and/or insurance products and their terms and conditions.
The basis upon 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 into 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 during our initial discussions or after our contract has ended, we may continue to use Your Personal Data where it is within our legitimate business interests and your rights are not adversely 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 you, or contact you to request feedback on the service you received.
On occasion, we will also use Your Personal Data to meet contractual responsibilities owed to our regulator, the Financial Conduct Authority, or to comply with legal or regulatory obligations.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with insurance, particularly life insurance or policies that protect you in the event of accident or illness, we will ask you for information about your ethnic origin, health and medical history (Your Special Data).
We record and use this information to obtain quotations from insurance providers and to provide advice on suitable insurance products.
If you have parental responsibility for children under the age of 13, we may also record information relating to those children, including Special Data where necessary.
Certain insurance applications may also require disclosure of historic or current criminal convictions or offences ("Criminal Disclosures") for underwriting, claims and fraud prevention purposes.
We process Special Data and 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 collect and record Your Personal Data from a variety of sources, primarily from you.
Information is normally provided during meetings, telephone conversations and correspondence, including email, as we establish your circumstances, needs and preferences.
We may also obtain information from third parties, including:
- Credit reference agencies.
- Your employer.
- Publicly available sources such as the electoral roll.
Where technology is used to verify your financial information, we will obtain your consent where required. Electronic identity checks do not require consent, but we will explain how they operate and why they are used.
What happens to Your Personal Data when it is disclosed to us?
We will:
- Record and securely store Your Personal Data in paper files, mobile devices and computer systems, including email, hard drives and cloud storage. Access is restricted to employees who require the information.
- Submit Your Personal Data to mortgage lenders, commercial lenders, packagers and insurance providers where necessary to process enquiries or applications.
- Respond to queries regarding mortgage or insurance products and keep you informed of relevant developments.
Artificial Intelligence (AI)
To improve the quality, efficiency and accuracy of our services, we use Artificial Intelligence (AI) to assist with:
- Recording and transcribing meetings (you may opt out of recordings).
- Generating meeting notes and summaries.
- Drafting correspondence and documentation.
- Conducting internal compliance checks.
We are committed to protecting your privacy and ensuring that any information processed using AI is handled securely.
If you have any questions about the AI we use in relation to your personal information, please contact us.
Sharing Your Personal Data
From time to time Your Personal Data may be shared with:
- Mortgage lenders, finance lenders and insurance providers.
- Third parties who assist with your enquiry or application, including compliance advisers, product specialists, estate agents, legal service providers, conveyancers, surveyors and valuers where appropriate.
Your Personal Data is only shared where necessary to progress your mortgage or insurance enquiry and to provide our professional services.
These organisations are not entitled to use your information for marketing purposes.
We do not expect Your Personal Data to be transferred outside of the United Kingdom or the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us.
We take reasonable steps to protect Your Personal Data against unauthorised or unlawful access.
We also ask you to protect your own information by avoiding unsecured email where possible, password protecting attachments and using secure methods of sending original documents.
Your Personal Data will normally be retained for a minimum of six years after the advice or service you receive, although it may be retained for longer where required by regulation.
Your rights in relation to Your Personal Data
You have the right to:
- Request copies of Your Personal Data.
- Ask us to explain how we use Your Personal Data.
- Request corrections, deletion or restriction of processing where applicable.
- Ask us to transfer your information electronically to another organisation.
- Change or withdraw any marketing consent you have previously provided.
Collection of data from a third party to support you
Where identifiable information is collected from a third party, such as a family member or trusted friend, it will only be used to support the contract for the supply of services described in this Privacy Notice.
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions about this Privacy Notice or wish to exercise your rights, please email:
compliance@prosperhomeloans.co.uk
If we believe we have a legal reason not to comply with your request, or need to respond differently, we will explain this to you.
Please contact us immediately if you become aware of any unauthorised disclosure of Your Personal Data so that we can investigate and meet our regulatory obligations.
If you are unhappy with how we have handled Your Personal Data, please contact us using the details above.
If you remain dissatisfied after receiving our response, you may complain to the Information Commissioner's Office (ICO) via:
https://ico.org.uk/global/contact-us/
or write to:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
