Customer Privacy Notice
LM Financial and Protection Solutions is an Appointed Representative of PRIMIS
Mortgage Network a trading name of First Complete Ltd/Advance Mortgage
Funding Limited.
Why are we asking you to 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
(YourInformation). We would like to explain to you what we will need to do with
Your Information, and the various rights you have in relation to Your Information.
What do we mean by “Your Information”?
Your Information means any information describing or relating to you. Your
Information may identify you directly, for example your name, address, date of
birth, National Insurance number and the like. Your Information 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 Information 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 mortgage and/or insurance products and the terms and
conditions relating to these
record and store Your Information in our paper files, mobile devices and on
our computer systems (websites
, email, hard drives
, cloud facilities) and it will be accessed by employees and consultants within, or contractors
engaged, by our Firm as necessary to provide our service to you and to
perform any administration tasks associated with or incidental to that service
submit Your Information to mortgage lenders and/or insurance product
providers, both in paper form and on-line via mortgage lender/insurance
provider systems,in order to progress any enquiry or application made on
your behalf and to deal with any additional questions or administrative issues
that mortgage lenders and insurance providers may raise
input Your Information, along with full details of the mortgage and/or
insurance, discussed with you or which you have taken out, to the computer
systems of our Network use Your Information for the purposes of responding to any queries you may
have in relation to any mortgage product or insurance policy 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
Record and store Your Information and Your Special Data/Criminal
Disclosures on Network systems run on secure servers. Your Information and
Your Special Data/Criminal Disclosures will be accessed by authorised
employees and consultants within, or engaged, by the Network as necessary
for the purposes of supervision, training, quality audits, customer surveys
and complaint handling or otherwise to comply with any other legal or
regulatory obligation the Network may have
use, and where appropriate transmit, Your Information and Your Special
Data/Criminal Disclosures to respond to any request from the FCA, the
Financial Ombudsman Service, HMRC, the O
ffice of the Information
Commissioner or any other regulatory, law enforcement or governmental
body need to access and process Your Information and Your Special Data/Criminal
Disclosures to deal with enquiries received from mortgage lenders and
insurance providers that relate to the service this Firm has provided to you,
including the payment of any commission or fees to us that may be linked to
the product you have taken out.
ask us to correct, delete or require us to restrict or stop using Your
Information (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 Information to another organisation
should you wish
The basis upon which our Firm will deal with Your
Information
When we speak with you about your mortgage and/or insurance requirements we
do so on the basis that a contract for the supply of services is in place between
us. In order to perform that contract, and to arrange the products you require, we
have the right to use Your Information for the purposes we set out 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 Information 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 Network 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 Information to enable us to meet a
ny contractual
responsibilities we may owe our Network, or for wider compliance with any
legal or regulatory obligation to which we might be subject. If this were to arise we would be processing Your Information in order to meet a legal,
compliance or other regulatory obligation to which we are subject.
The basis upon which we will process certain parts of
Your Information
Where you ask us to assist you with your insurance needs, in particular life
insurance and insurance that may assist you in the event of an accident or illness,
we will ask you information about your ethnic origin, your health and medical
history (Your Special Data). 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 regarding the suitability of any
product that may be available to you.
If you have parental responsibility for children under the age of 16 it is also very
likely that we (and consequently our Network) 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.
You’re Special Data and any Criminal Disclosures will be used by us in the same
way as Your Information generally, as set out in this Customer Privacy Notice.
When we process your Special Data and any Criminal Disclosures we do so on the
basis that it is in the substantial public interest to be able to provide vital insurance
products and as permitted by UK data protection related laws and regulations
from time to time. 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.
How do we collect Your Information?
We will collect and record Your Information 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 and
needs and preferences in relation to mortgages and insurance. You will provide
information to us verbally and in writing, including email.
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 Information, such as software that is able to verify your identity
on-line or to access your credit status and/or bank account entries, then you will
be required to provide your consent for us or our nominated processor to access
your information in this manner, and details of how such software operates will be
provided to you prior to the activation of the service.
What happens to Your Information when it is disclosed to
us?
In the course of handling Your Information we will:
Sharing and transferring Your Information
From time to time Your Information will be shared with or transferred to:
our Network to mortgage lenders and insurance 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, such third
parties will include but may not be limited to, product specialists (including
those within our Network and other Appointed Representatives of the
Network), estate agents, providers of legal services such as conveyancing,
surveyors and valuers (in each case where we believe this to be required due
to your particular circumstances).
In each case for the purposes set out in this customer privacy notice, i.e. to
progress your mortgage and/or insurance enquiry and to provide you with our
professional services.
Please note that this sharing of Your Information does not entitle such third
parties to send you marketing or promotional messages: it is shared for the
purpose of ensuring we can adequately fulfil our responsibilities to you, and
as otherwise set out in this Customer Privacy Notice.
These parties may be located in the UK or elsewhere in the world where different
privacy laws may apply which may not offer the same level of protection as UK
law. We only make these arrangements or transfers where we are satisfied that
adequate levels of protection are in place to protect any information held in that
country and that the service provider acts at all times in compliance with
applicable privacy laws.
The basis upon which our Network will deal with Your
Information, Your Special Data and Criminal Disclosures
Our Network is authorised and regulated by the Financial Conduct Authority
(FCA). Our Network is responsible for the quality of the advice that we provide to
you in relation to your mortgage and/or insurance products, where those products
are regulated by the FCA. In the course of doing so, our Network will also process
Your Information generally, including Your Special Data and Criminal Disclosures.
In the course of handling Your Information and Your Special Data/Criminal
Disclosures our Network will:
Your Information and Your Special Data/Criminal Disclosures will be retained by
our Network either electronically or in paper format for a minimum of six years and
possibly for a longer period where this is required to enable the Network to fulfil its
legal and regulatory obligations.
Please note that the above information is a summary of the Network Privacy Policy
for customers. If, you wish to understand in more detail what the Network will do
with Your Information and Special Data/Criminal Disclosures then please visit the
Network Privacy Policy for customers located at
https://www.primis.co.uk/index.php/terms-and-conditions/
Security and retention of Your Information
Your privacy is important to us and we will keep Your Information secure in
accordance with our legal responsibilities. We will take reasonable steps to
safeguard against Your Information being accessed unlawfully or maliciously by a
third party, accidentally lost, destroyed or damaged.
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 sent to us.
Your Information will be retained by us either electronically or in paper format for a
minimum of six years, or if longer than six years, the duration of this Firm’s
relationship with you.
Your rights in relation to Your Information
You can:
request copies of Your Information that is under our control
ask us to further explain how we use Your Information
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)
How to make contact with our Firm in relation to the use of
Your Information
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:
Lee Morris on 07811210404 or email lee@lmmortgages.co.uk
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 Information, 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
Information or Your Special Data/Criminal Disclosures 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 O
ffice, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.