In this Customer Privacy Notice the terms, 'we', 'us' and 'our' are references to Embrace Financial Services which is a trading name of Embrace Financial Services Ltd. Embrace Financial Services Ltd is part of the LSL group of companies of which the ultimate parent company is LSL Property Services plc (LSL Group). Embrace Financial Services Ltd is also an Appointed Representative of PRIMIS Mortgage Network which is a trading name of First Complete Limited (Our Network). From time to time we authorise advisers to provide our services independently or under a separate trading name but within Embrace Financial Services. Where this is the case the brand names are listed below.
During the course of dealing with us we will collect or 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) via all the methods we communicate with you including our website www.embracefs.co.uk (Our Site). We would like to explain to you what we will need to do with Your Information, and the various rights you have including:
Your Information means any information describing or relating to you. Your Information may identify you directly, for example your name, address, date or 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:
When we speak with you about your mortgage and/or insurance requirements we will 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. If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.
On occasion, we will use Your Information to enable us to meet any 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, fraud prevention or other regulatory obligation to which we are subject.
When needed we may also we may also seek your consent to process your Information by passing it to a partner organisation to provide you with additional advice or service not currently provided by Us. The organisation we pass your Information to will provide you with their own Privacy Notice and you can withdraw or amend that consent at any time.
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 for information which is of a sensitive nature such as your ethnic origin, your health and medical history (Your Special Category Data). We will record and use Your Special Category 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 Category Data.
The arrangement of certain types of insurance may involve disclosure by you to us of information relating to current (including charged but not tried yet) or historic criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.
Your Special Category 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 but it will be processed with the standards of security required by relevant Data Protection laws.
When we process Your Special Category 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, support any claims and to prevent fraud.
We will collect and record Your Information from a variety of sources, including from other LSL Group companies, our introducer organisations and partners, 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 by email and via video or conference calling technology (that we provide).
Unless already provided by and introducer organisation or partner 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.
In the course of handling Your Information we will:
From time to time Your Information will be shared with or transferred to:
Where we transfer Your Information to a third party, this will include but may not be limited to, product specialists (including those within our Network and other Appointed Representatives of the Network such as First2Protect), estate agents, providers of legal services such as conveyancing, Surveyors and Valuers.
Your Information is only transferred where we believe this to be required due to your particular circumstances and/or 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.
We do not envisage that the performance by us of our service will involve Your Information being transferred outside of the European Economic Area.
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 Category Data and Criminal Disclosures.
In the course of handling Your Information (including Your Special Category Data/Criminal Disclosures) Our Network will:
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.
The personal information that you provide will be retained by us in accordance with applicable laws and our internal retention policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our retention policy is available on request.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive and we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
If you have questions or comments about our Privacy Notice or if you wish to exercise your rights mentioned above, please contact our Data Protection Officer by:
Post: Data Protection Officer, Newcastle House, Albany Court, Newcastle Business Park, NE4 7YB; or
Telephone: 0191 233 4600.
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 Category 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 Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
From time to time we authorise advisers to provide our services, independently or under a separate trading name within Embrace Financial Services but we ensure that Your Information is processed in the same way as outlined in this Privacy Notice.