This notice is designed to explain how we (HQ Mortgage & Finance Ltd) will process the data we collect about you during our work together.
This privacy notice applies when you provide us with personal information about yourself in the interest of engaging our services as a mortgage and insurance adviser.
HQ Mortgage & Finance Ltd will act as data controller when processing your data for the purposes outlined in this policy, the person or persons the data concerns are therefore the data subject(s).
"you" is used to refer to the data subject(s) throughout this document, "we", “our company" or “our business" is used in reference to HQ Mortgage & Finance Ltd.
What information are we collecting?
The type of information we collect from you will depend on the nature of the service we are providing to you; this information will always be requested from you explicitly and directly either orally or in writing.
You will, therefore, be made aware of exactly what information we are collecting and recording throughout the process.
We will collect as much information about you as is necessary to fulfil your request to provide service as well as meeting our regulatory, record keeping and compliance standards.
It might be necessary for us to collect more sensitive information (such as health or lifestyle information) which is called special category data. This is to allow us to provide a more comprehensive financial advice service to you. We process this data on the basis that you have explicitly consented to the collection and processing of this data. You can withdraw your consent at any time to us processing this data, however, this may mean that we can no longer provide you with the advice and recommendations you require.
What will we do with your information?
We will process your data in the following ways:
To build a picture of your circumstances in order to shape our advice and recommendation
To provide a quotation and/or to facilitate an application for offered products.
To record and evidence our dealings in written form in order to comply with the responsibility imposed on us by the industry regulator to keep proper records.
For the purpose of ongoing monitoring, analytics and performance measurement of our business.
If you have given explicit consent for us to do so, we will contact you when necessary to review the product(s) we have arranged for you.
Why do we process your data in these ways?
We process your data in these ways on the grounds that we as a business have genuine legitimate interests to do so.
Upon engagement of our services, and receipt of your personal data, our legitimate interests are:
To fulfil the request for service you have made of us and secure your custom. In order to fulfil your requests, we will have to process your personal information and share it with third parties such as those listed in this document. We are unable to offer our service without the processing of your data as it is integral to our advice, recommendation and the ongoing transaction(s).
To comply with the rules set out by the industry regulator, the Financial Conduct Authority (FCA). We are required to be able to produce a clear record of our dealings with you in durable form and justify the advice given and actions we have taken.
To better understand how we as a business are performing and serving our customers so as to improve our service in future.
We will also process your data in cases where we have received your explicit consent to do so, as requested at the end of this document, these will include:
Storing and processing your contact details and information relating to a transaction when it comes time to review the product(s) we arranged for you in our previous dealings.
Storing and processing your contact details in order to provide you with useful information regarding related products or topics that we believe will benefit you, this may cover things like insurance that aligns with a mortgage we have arranged for you.
How long will we store your data?
Where we are processing your data in order to fulfil a request for service that you have made, we will process your data for as long as it is necessary to achieve that; i.e., once we have obtained a mortgage or insurance product for you as per your request.
Given the nature of these transactions, the length of time data is retained will be influenced by the following:
Where we are processing your data in the interest of contacting you when appropriate with related products or a review of your existing products, we will do so until you express that you no longer wish for us to do so and end your relationship with us.
For the purposes of business analytics and service improvement, we will store and process your data for as long as we deem it relevant and genuinely useful to our business.
Where we are processing your data to comply with the rules set out by the FCA, we will store and process your data for as long as it is necessary in order to comply with those rules.
Who will have access to your data?
We are the primary controller of your data.At various points during our dealings, it may be necessary for us to share your data with third parties such as:
Mortgage Lenders: In order to fulfil your request to obtain a mortgage on your behalf.
Insurance Providers: In order to fulfil your request to obtain insurance products on your behalf.
Software Providers: In order to securely and effectively manage your data, we employ software companies to provide us with appropriate solutions such as Customer Relationship Management (CRM) systems and software that assists us in the application of our service.
Regulatory Bodies: We may be required to share your data with an authority or regulatory body in order to aid them in an investigation or other matter. We are required to do so when it is requested of us.
Estate Agents, Solicitors, Surveyors, Accountants and other parties potentially involved in the transaction: We may need to share your data with third parties that play an integral role in your transaction, we do this only when it is absolutely necessary in order to fulfil your request and will inform you when we have done so. In these cases, we will share only the minimum level of information required in order to progress your transaction(s).
Approved consultant companies: Some of our mortgage advisers may operate as their own limited company, approved by and contracted to HQ, in order to fulfil your request for our service, it is necessary for us to share your information with them. These companies are individually registered with the Information Commissioner’s Office and act as a data processor on behalf of HQ.
Your rights as data subject:
You have the right to request that we provide you with a copy of any and all personal data that we are processing.
If you believe the personal data we are processing is inaccurate, you have the right to have that data rectified or made complete if it is incomplete.
Objection to processing
You have the right to object to the processing of your data outlined in this document, you can do so at any time.
Restriction of processing
Where you have exercised your right to object to the processing of your data, and we are reviewing that request, you have the right to restrict its processing in the interim period.
Your right to be forgotten
Where you have given consent for us to contact you to review a product or retain your information to provide useful information regarding related products or topics, you can withdraw your consent at any time and relevant details will be removed.
Dealing with your requests
The above-outlined rights are subject to circumstance and are not guaranteed or absolute, they will depend entirely on context.
Your request will be subject to our review, during our review process we will balance your rights, freedoms and interests against our own, taking in to account the regulatory responsibility imposed on us and determine whether we are able to grant your request.
To make a request or to exercise one of your rights, call us on 01823 286 271 or write to us at email@example.com
We will respond to any request made within one calendar month of its receipt.
If you would like a copy of this privacy notice in an alternative format, please contact us at firstname.lastname@example.org or by phone on 01823 286 271 with your requirements.
A copy is also made available on our website at www.hqmf.co.uk.
For more information on data protection and your rights, you can visit the Information Commissioner’s Office website at https://ico.org.uk.
HQ Mortgage & Finance Ltd is registered with the Information Commissioner’s Office licence no: Z1375368.