Point 2 Mortgages Ltd (referred to as “our Firm,” “we,” “our,” or “us”) is an Appointed Representative of PRIMIS Mortgage Network, a trading name of Personal Touch Financial Services Limited (“our Network”).
Why Are We Asking You to Read This Document?
As part of our work with you, we will need to collect personal information about your circumstances, financial situation, and, in some cases, your health and family health history (“Your Information”). This notice explains how we use Your Information and your rights regarding it.
What Do We Mean by “Your Information”?
“Your Information” refers to any data that identifies you. This can include:
- Direct identifiers: e.g., your name, address, date of birth, and National Insurance number.
- Indirect identifiers: e.g., your employment details, health history, or any data connected to your identity.
As part of our mortgage and/or insurance services, Your Information may include:
- Title, name, date of birth, gender, marital status, contact details, and identification documents.
- Employment details (e.g., salary, bonuses, benefits) and history.
- Financial information, such as bank details, tax records, credit history, loans, and expenses.
- Health history and status, including medical reports (where relevant for insurance advice).
- Details of dependents and family circumstances.
- Information on existing mortgage or insurance products.
Our Basis for Using Your Information
To Provide Our Services:
When we assist with your mortgage and/or insurance needs, we do so under a contract to provide these services. This allows us to use Your Information to fulfil our obligations and provide advice.
For Legitimate Interests:
Outside our contractual relationship, we may use Your Information for legitimate business reasons, such as responding to mortgage lender queries or seeking feedback on our service.
For Legal or Regulatory Obligations:
We may process Your Information to meet legal or regulatory requirements, such as responding to requests from lenders, insurers, or regulators.
Processing Special Data and Criminal Disclosures
If you request assistance with life insurance or accident/illness policies, we may need to process:
- Special Data: e.g., health, ethnicity, or medical history, used to tailor advice and recommendations.
- Criminal Disclosures: Information on past or current convictions, relevant for underwriting or claims.
We process this information in the public interest, following UK data protection laws, to secure suitable insurance solutions.
If your application involves dependents (e.g., children under 16), we may also collect their Special Data as part of the process.
How We Collect Your Information
Most of Your Information is collected directly from you during meetings or correspondence (e.g., emails or phone calls).
We may also obtain information from:
- Third parties: e.g., credit checks or employer references.
- Public sources: e.g., the electoral roll.
- Technology solutions: e.g., tools for identity verification or credit analysis, with your consent.
How We Handle and Use Your Information
We will:
- Store Your Information in paper files, on secure computer systems, or cloud storage.
- Share Your Information with mortgage lenders, insurance providers, and our Network to progress your application or enquiry.
- Record details of the products discussed or arranged in our systems for future reference.
- Use Your Information to respond to queries, keep you updated on your products, or inform you of relevant changes.
Sharing Your Information
We may share Your Information with:
- Our Network: For compliance, quality checks, or regulatory purposes.
- Lenders/Insurers: To arrange your mortgage or insurance products.
- Other Third Parties: e.g., legal professionals, surveyors, or estate agents, where necessary to support your requirements.
We only share Your Information for the purposes outlined in this notice.
International Transfers:
In rare cases, Your Information may be transferred outside the UK. We will ensure adequate protections are in place to safeguard your privacy.
How Our Network Handles Your Information
Our Network, PRIMIS Mortgage Network, processes Your Information for compliance and regulatory purposes. This includes:
- Storing Your Information securely on their systems.
- Sharing information with regulators (e.g., FCA), law enforcement, or other authorised bodies as required.
For full details, visit the PRIMIS Privacy Policy.
Security and Retention of Your Information
We take reasonable steps to protect Your Information from unauthorised access, loss, or damage. You should also take care when transferring information to us (e.g., use secure email or encrypted attachments).
Your Information will be retained for at least six years or as long as our relationship lasts.
Your Rights
You can:
- Request copies of Your Information.
- Ask us to correct, delete, or restrict our use of Your Information.
- Request electronic transfer of Your Information to another organisation.
- Withdraw consent for marketing communications.
How to Contact Us
If you have questions or wish to exercise your rights, contact:
[Insert Contact Details or Data Protection Officer Information]
If you’re unhappy with how we’ve handled Your Information, you can complain to the ICO:
- Visit: ICO Contact Page
- Write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.