We take your privacy seriously and are committed to processing your information lawfully. We know that there’s probably other things you would rather be doing but recommend you read this carefully so you understand how we process your information and your rights.
This privacy notice tells you about the information we collect from you when you engage with our financial services. In collecting this information, we are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we collect, store and use your data, and about the rights you have to control our use of your personal data.
WHO ARE WE
Charwin Private Clients Limited is registered in England (Company number 06628612). We are directly authorised and regulated by the Financial Conduct Authority (“FCA”) and our firm’s registration number is 498486.
Our registered address is Charwin Private Clients, Holland Court, The Close, Norwich, NR1 4DY. You can visit our website at www.charwinprivateclients.co.uk
You can contact us by post at the above address, by email: email@example.com or you can call us on 01603 216881
PERSONAL DATA WE COLLECT
To provide our core services (advising and arranging a mortgage or insurance contracts) we are required to collect a range of information about you and your immediate family. We will keep this to a minimum where possible but sufficient to fulfil our obligations to you. We will collect required information such as:
Personal details such as names (including children), nationality, address and address history, email, telephone numbers, employment information, banking and credit commitments, financial dependents, general household expenditure, future plans and aspirations and product preferences. How you answer these questions will determine what other questions we ask as different lenders have different eligibility criteria.
Mortgage lenders are data controllers and have their own privacy notices. Many lenders automatically profile your information against their lending criteria and against Credit Reference Agencies as soon as your information is forwarded to them to provide lending decisions. This may affect your credit score. We will never supply this information without your prior agreement to do so.
We will also retain documentary evidence on file to support any applications such as copies of passports or photographic drivers licence (ID and signature verification), payslips or accounts (income verification), bank statement (proof of affordability) and any other related items as required from time to time.
We require this information as part of our “know your customer process” that allows us to deliver the best advice given your situation.
For life or health related insurances we will need to collect special category data. You may be assured that we and any company associated with us will treat all personal data and sensitive personal data as confidential and will not process it other than for legitimate purposes. Steps will be taken to ensure that the information is accurate, kept up to date and not kept for longer than is necessary.
WHAT WE DO WITH YOUR INFORMATION
In most cases you will provide the information mentioned above as you want to use our services. The purpose for which we use this information and the legal basis under data protection law is as follows:
We collect this information as is in our Legitimate Interests or that of a third party to provide advice and make personal recommendations and subsequent processing of applications. This means that we will use your information as you would reasonably expect it to be used. It will also have minimal impact on your privacy whilst preserving your overall rights. You can withdraw from any process at any time.
Once a recommendation for a mortgage or insurance product has been made, we will need to pass your personal data to third parties. This is done to fulfil our contractual obligations. This may include:
Mortgage lenders to agree a mortgage in principle or apply for a proposed mortgage,
Secured Loan lenders to agree or apply for a proposed secured loan,
Insurance Companies to provide quotations for home insurance or landlords insurance, life insurance, critical illness cover or income protection,
Credit Reference Agencies who will provide copies of your credit file, verify identity and fraud prevention
Solicitors acting for you as part of a mortgage process,
Estate Agents who are acting agents for a related property purchase or sale,
TrustPilot to collect reviews on our service and gain feedback
Lead Suppliers is your information was introduced to us by a third party
Marketing Partners who advertise our services, run or otherwise facilitate our financial promotions
Twenty7Tec whose mortgage sourcing software we use
Financial Ombudsman Service or Financial Conduct Authority where they request this to resolve complaints or in connection with their duties.
This is necessary to advance your applications and provide our services.
We do not sell any of your information to external companies. You will be asked to confirm your marketing and communication preferences in our Key Messages document.
We may use your information to communicate relevant or related products or services that Charwin Private Clients offer and we would reasonably expect you to be interested in.
Your information is stored on secure servers located within the EU.
HOW WE KEEP YOUR INFORMATION SECURE
We understand how important it is to keep your personal information secure. We use a variety of technologies and procedures to protect your personal information from accidental or unlawful breaches of security. These include physical, organisational, and technological measures.
All information we process is encrypted in a variety of ways so that your personal and financial information is secure.
When we share your information with third parties to carry out some of our services, including lenders and insurers amongst others, we require every third party that we share information with to apply appropriate security safeguards and comply with all the required laws and standards for protecting personal information.
HOW LONG WE KEEP YOUR INFORMATION FOR
We only keep your information for as long as we need to.
If you become a client of a lender/insurer as a result of the advice we provide to you, we will keep a full record of your interactions with us for your lifetime plus a reasonable period to enable us to meet our regulatory obligations to evidence we gave suitable advice and to enable us to answer any complaints that may arise as a result of our advice. In practice this means that we will keep your records for no longer than 100 years after you last transact with us.
If, as a result of our advice, you make an application to a lender/insurer but do not ultimately become a client of that institution, we will keep a full record of your interactions with us for 6-years to meet our obligations under UK Money Laundering regulations.
If we provide you with advice on a financial product, but you do not engage our services to make an application to a lender/insurer, we will keep a full record of your interactions with us for 3-years, to enable us to meet our regulatory record keeping obligations regarding evidencing suitability of our advice.
If we collect personal information from you, but are unable to provide you with suitable advice, then we will keep a full record of your interactions with us for 1-year to facilitate an easier interaction between us if you re-engage our services within this period.
If you request we contact you in relation to our service by providing us with your name and a contact method (e.g. phone, email) through an enquiry form (either on our own, or a 3rd party website) we will use our best endeavours to contact you as soon as possible. If we are unable to contact you, we will retain this information for a period of 90-days from the time we de-activate your information from our database, to ensure we can fulfil our contractual obligations to our lead partners.
YOUR INDIVIDUAL RIGHTS
Your right to be informed
This privacy notice is part of the process where you have the right to be informed.
You have the right to be informed in a concise, transparent, intelligible and easily accessible way about how we use your personal information. We will explain why we need information (including any uses that are not obvious) at the time we collect information from you and make sure that all our data collection forms and letters point you to this Privacy Notice.
Your right of access
You have the right to obtain confirmation that your data is being processed. You also have the right to access your personal data and to verify the lawfulness of processing.
Any request is free of charge however we may charge a reasonable fee if the request is excessive. We may also charge if subsequent requests are made for the same information.
We will ensure that any data subject access request is provided within one month of receipt.
We will need to verify your identity as part of this process using reasonable means. Generally, this is by letter or electronically by email.
Your right of rectification
You have the right to have any inaccurate information corrected or completed if incomplete. This request can be made in writing or verbally.
We will correct any data we hold within one month of being notified. We will not charge to amend or correct your data unless it is excessive.
We may need to verify your identity to make the requested changes.
If we have provided this information to other parties, we will contact each of them individually to update their records of your data.
Your rights to erasure
You have the right to have your personal data erased. This is known as your right to be forgotten. Such a request can be made either verbally or in writing.
We will respond to any request within one month of receipt of the request.
In some circumstances, we can refuse to erase personal information if it forms part of a legal obligation. For example, if you complete a mortgage using our service, the FCA require us to maintain a record for 7 years from the date of the transaction. In such circumstances, you can exercise your right to restrict processing (see below), including marketing activities. Once the 7 years has elapsed, your data will be erased.
We will not charge a fee for erasing your data. We will also need to verify the identity of each of the individual persons exercising the right to be forgotten.
Your right to restrict processing
You have the right to request that we restrict or stop using your personal information. We may continue to store the information but will stop using it.
Your request can be made verbally or in writing and will be responded to without undue delay and no later than one month from the date of the request. In the event of a complaint, this restriction will continue until the matter concerned is fully resolved.
You have the right in some circumstances to have the data you have provided to us sent to you or provided to another person or business in an electronic machine-readable format. Where this applies we will download the information and send it as a Microsoft Excel file.
Rights to object
You have the right to object to your personal data being used. If you wish for us to stop using your personal data we will do so without undue delay.
Rights in relation to automated decision making and profiling
This right only applies where a decision which has a legal or similar effect is DECISION MAKING taken about a person by automated means without any human intervention.
Where such decisions are made individuals have a right to ask for the decision to be reviewed and the data controller must make sure appropriate safeguards are in place. However, Charwin Private Clients does not make automated decisions about any of its clients.
YOUR RIGHT TO COMPLAIN
Information Commissioner's Office
CHANGES TO THIS PRIVACY NOTICE
We will continuously refine this Privacy Notice to make sure we are complying with our obligations to be transparent about how we use your personal information and that it is as concise, transparent, intelligible and as easily accessible as it can be. However, if we make any changes to how we process your personal information in ways that you would not reasonably expect, we will contact you and bring these changes to your attention.