Modern Mortgage Solutions Ltd (our Firm, we, our, us) 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?
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 Information). 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. It may identify you directly (e.g. your name, address, date of birth, National Insurance number) or indirectly (e.g. your employment situation, physical and mental health history, or information associated with your cultural or social identity).
In the context of providing assistance with your mortgage and/or insurance requirements, Your Information may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and identity verification documents
- Employment and remuneration information (including salary, bonuses, overtime, sick pay, other benefits) and 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, medical reports
- Any pre-existing mortgage and/or insurance products and their terms and conditions
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 set out below.
Alternatively, either in the course of initial discussions or when the contract has ended, we have the right to use Your Information where it is in our legitimate business interest to do so and your rights are not affected - for example, to respond to requests from mortgage lenders, insurance providers and our Network, or to seek feedback on our service.
On occasion we will use Your Information to meet contractual responsibilities to our Network, or for compliance with legal or regulatory obligations.
Special Data & Criminal Disclosures
Where you ask us to assist with insurance needs (particularly life insurance or accident/illness insurance), we will ask about your ethnic origin, health and medical history (Your Special Data). We will record and use Your Special Data to make enquiries of insurance providers and advise on suitable products.
If you have parental responsibility for children under 16, we and our Network may also record information relating to those children, including their Special Data.
Certain types of insurance may require disclosure of historic or current criminal convictions or offences (Criminal Disclosures), relevant to underwriting, claims and fraud management. Your Special Data and Criminal Disclosures will be used in the same way as Your Information generally.
How do we collect Your Information?
We collect Your Information mainly directly from you - usually during initial meetings or conversations to establish your circumstances, needs and preferences. You may provide information verbally, in writing, or by email.
We may also obtain information from third parties such as credit reference agencies, your employer, or public domain sources (e.g. the electoral roll). Where technology solutions are used (e.g. identity verification or credit status software), you will be asked to provide consent and full details will be provided beforehand.
What happens to Your Information when disclosed to us?
- It will be recorded and stored in our paper files and computer systems, accessed by employees and consultants as necessary to provide our service
- It will be submitted to mortgage lenders and/or insurance providers to progress enquiries or applications
- It will be input to our Network's computer systems along with full details of any mortgage and/or insurance discussed or taken out
- It will be used to respond to your queries or to inform you of developments relating to your products
Sharing and Transferring Your Information
From time to time Your Information may be shared with:
- Our Network (PRIMIS Mortgage Network)
- Mortgage lenders and insurance providers
- Third parties able to assist with your enquiry, including product specialists, estate agents, legal services providers (conveyancing), surveyors and valuers
This sharing does not entitle such third parties to send you marketing or promotional messages. These parties may be located in the UK or elsewhere; we only make such transfers where adequate levels of protection are in place.
How our Network deals with Your Information
Our Network is authorised and regulated by the FCA and is responsible for the quality of advice we provide. In handling Your Information, our Network will:
- Record and store Your Information on secure Network systems, accessed by authorised personnel for supervision, training, quality audits, customer surveys and complaint handling
- Transmit Your Information to respond to requests from the FCA, Financial Ombudsman Service, HMRC, the ICO or other regulatory bodies
- Access Your Information to deal with enquiries from mortgage lenders and insurance providers relating to our service
Your Information will be retained by our Network for a minimum of six years or longer where required. For the full Network Privacy Policy visit primis.co.uk.
Security and Retention
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 unauthorised access, accidental loss, destruction or damage.
Your Information will be retained by us for a minimum of six years, or for the duration of our relationship with you if longer.
Your Rights
- Request copies of Your Information under our control
- Ask us to explain how we use Your Information
- Ask us to correct, delete, or restrict/stop use of Your Information
- Ask us to send an electronic copy of Your Information to another organisation
- Change or withdraw any consent provided for marketing purposes
Contact Us
If you have any questions or wish to exercise any of your rights, please contact:
If you have concerns about how we have handled Your Information, you may lodge a complaint with the ICO at ico.org.uk or write to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
