Customer privacy notice
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, 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, finance and Insurance requirements Your Personal Data may include:
- Title, name, 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, finance and insurance products and the terms and conditions relating to these
The basis upon which our firm will deal with Your Personal Data
When we speak with you about your mortgage, finance and or insurance requirements we do so on the basis that both parties are entering 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 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 mortgage lenders, insurance 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.
The basis upon which we will process certain parts of Your Personal Data
Where you ask us to assist you with for example your insurance 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 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.
How do we collect Your Personal Data?
We will collect and record Your Personal Data 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, finance 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 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.
What happens to Your Personal Data when it is disclosed to us?
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 Product Providers, Mortgage Lenders, Commercial Lenders and Insurance 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 mortgage, finance or insurance policy you may take out, or to inform you of any developments in relation to those products and polices of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Mortgage lender, finance 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. 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 investment, mortgage, finance and insurance 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.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. 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.
Your rights in relation to Your Personal Data
You can:
- 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)
How to make contact with our Firm in relation to the use of Your Personal Data
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:
Omar Nazir, Waltham Capital Ltd. Dashwood House, Level 17, 69 Old Broad Street, London, EC2M 1Qs.
Email: omar.nazir@walthamcapital.co.uk Tel: +44 (0) 207 193 4464
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 5A
Key facts about our Mortgage, general insurance, protection services & costs
1. The Financial Conduct Authority (FCA)
The FCA is the independent watchdog that regulates Financial Services. This document is designed by the FCA to be given to consumers considering buying certain financial products. You need to read this important document. It explains the service you are being offered and how you will pay for it.
2. Whose products do we offer?
We offer mortgages from the whole mortgage market.
We offer products from a range of insurers for life and critical illness insurance, buildings and contents insurance and mortgage payment protection insurance. Ask us for a list of insurers we offer insurance from.
3. Which service will we provide you with?
For mortgages we will advise and make a recommendation for you after we have assessed your needs.
For insurances we will advise and make a recommendation for you after we have assessed your needs for life and critical illness insurance, buildings and contents insurance or mortgage payment protection insurance.
4. What will you have to pay us for our services?
You will not be charged a fee for the initial mortgage consultation.
We charge a maximum broker fee equivalent to 2% of the total loan amount, subject to a minimum of £500. The exact fee depends on the complexity of the case. You will be provided with details of the exact fee after a free initial consultation and before any applications are submitted to the lender. The first £250 of the total agreed fee is payable if you choose to proceed after the free initial consultation. The second instalment of £250 is payable receipt of a successful decision in principal from the lender. The remainder of the fee is payable on receipt of formal mortgage offer from the lender. We will also receive commission from the mortgage Lender.
In all cases, you will receive a key facts illustration, which will tell you about any fees relating to a particular mortgage and any commission payable to us.
No fee for life and critical illness insurance, buildings and contents insurance or mortgage payment protection insurance.
You will receive a quotation which will tell you about any other fees relating to any particular insurance policy.
Refund of Fees
If we charge you a fee, and your mortgage does not go ahead, you will receive
No Refund
5. Who regulates us?
Waltham Capital Ltd trading as Waltham Capital Mortgage Specialists is authorised and regulated by the Financial Conduct Authority. Our FCA Register number is 828602.
Waltham Capital Ltd permitted business is advising on and arranging mortgages, general and pure protection insurance. You can check this on the FCA’s Register by visiting the FCA’s website (www.fca.org.uk) or by contacting the FCA on 020 7066 1000,
6. What do do if you have a complaint
If you wish to register a complaint, please contact us:
…in writing
Write to: Complaints Department, Waltham Capital Ltd, Dashwood House, Level 17, 69 Old Broad Street, London, EC2M 1QS
…by phone
Telephone +44 (0)207 193 4464
If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service.
7. Are we covered by the Financial Conduct Compensation Scheme (FSCS)?
We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. You can write to them at:- Financial Services Compensation Scheme, 10th Floor, Beaufort House, 15 St Botolph Street, London EC3A 7QU.
Insurance
Insurance advising and arranging is covered for 90% of the claim, with no upper limit.
Mortgages
Mortgage advising and arranging is covered up to a maximum limit of £85,000. Further information about compensation scheme arrangements is available from the FSCS
