About Us

 

SPB Mortgage Consultants Ltd is a registered company whose registered number is 7471124, the registered address is 1, The Old Stables, Eridge Park, Tunbridge Wells, Kent, TN3 9JT. SPB Mortgage Consultants Ltd is an Appointed Representative of PRIMIS Mortgage Network, a trading name of First Complete Limited (our network) which is authorised and regulated by the Financial Conduct Authority for mortgages, protection insurance and general insurance products.

We are committed to protecting your privacy and have updated our Privacy Policy to comply with the EU's data privacy law, the General Data Protection Regulation (GDPR). This Privacy Policy forms part of our legal information and sets out how we handle data which identifies you. You can trust us to respect your privacy and keep your personal information safe. If you have any queries concerning your personal information, please contact us at email address steve@spbmortgages.com

 

Customer Privacy Notice

 

 

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.   Your Information may identify you directly, for example your name, address, date of 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:-

Title, names, 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 and/or insurance products and the terms and conditions relating to these.

 

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 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.

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 or other regulatory obligation to which we are subject.

 

The basis upon which we will process certain parts of Your Information

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 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 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 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.

Your Special 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.

When we process your Special 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.

 

How do we collect Your Information?

We will collect and record Your Information 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 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 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.

 

What happens to Your Information when it is disclosed to us?

In the course of handling Your Information we will:-

Record and store Your Information in our paper files, mobile devices and on our computer systems (websites, email, hard drives, cloud facilities) and it will be accessed by employees and consultants within, or contractors engaged, by our Firm as necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.

Submit Your Information to mortgage lenders and/or insurance product providers, both in paper form and on-line via mortgage lender/insurance provider systems, in order to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that mortgage lenders and insurance providers may raise.

Input Your Information, along with full details of the mortgage and/or insurance, discussed with you or which you have taken out, to the computer systems of our Network.

Use Your Information for the purposes of responding to any queries you may have in relation to any mortgage product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

 

Sharing and transferring Your Information

From time to time Your Information will be shared with or transferred to:-

Our Network.

To mortgage 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, such third parties will include but may not be limited to, product specialists (including those within our Network and other Appointed Representatives of the Network), estate agents, providers of legal services such as conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).

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.

 

The basis upon which our Network will deal with Your Information, Your Special Data and Criminal Disclosures

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 Data and Criminal Disclosures.

In the course of handling Your Information and Your Special Data/Criminal Disclosures our Network will:-

Record and store Your Information and Your Special Data/Criminal Disclosures on Network systems run on secure servers. Your Information and Your Special Data/Criminal Disclosures will be accessed by authorised employees and consultants within, or engaged, by the Network as necessary for the purposes of supervision, training, quality audits, customer surveys and complaint handling or otherwise to comply with any other legal or regulatory obligation the Network may have.

Use, and where appropriate transmit, Your Information and Your Special Data/Criminal Disclosures to respond to any request from the FCA, the Financial Ombudsman Service, HMRC, the Office of the Information Commissioner or any other regulatory, law enforcement or governmental body need to access and process Your Information and Your Special Data/Criminal Disclosures to deal with enquiries received from mortgage lenders and insurance providers that relate to the service this Firm has provided to you, including the payment of any commission or fees to us that may be linked to the product you have taken out.

Your Information and Your Special Data/Criminal Disclosures will be retained by our Network either electronically or in paper format for a minimum of six years and possibly for a longer period where this is required to enable the Network to fulfil its legal and regulatory obligations.

Please note that the above information is a summary of the Network Privacy Policy for customers.  If, you wish to understand in more detail what the Network will do with Your Information and Special Data/Criminal Disclosures then please visit the Network Privacy Policy for customers located at http://www.primis.co.uk/privacy-policy-and-tcs.

 

Security and retention of Your Information

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.

We have security measures in place to protect our customer database and access to this database is restricted internally. However, it remains your responsibility:

• If you open more than one browser of the same type whilst using the website, to remember to close down all browser windows when you finish. 
• If you share a computer with someone else or use a public Internet access then we advise you to delete the browsing history and log off the computer. This will help ensure any personal information stored temporarily in the computer's memory is lost.

Disclosure for legal and regulatory reasons

We reserve the right to communicate such personal information as we hold to third parties which seek the disclosure of it, if we are requested to do so by law or by a regulatory authority.

Your Information will be retained by us either electronically or in paper format for a minimum of six years, or if longer than six years, the duration of this Firm’s relationship with you.

 

Your rights in relation to Your Information

You can:-

Request copies of Your Information that is under our control.

Ask us to further explain how we use Your Information.

Ask us to correct, delete* or require us to restrict or stop using Your Information (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 Information 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 Information

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:

Steve Bassi – SPB Mortgage Consultants Ltd, Unit B6, Speldhurst Business Park, Langton Road, Speldhurst, Tunbridge Wells, Kent. Tel: 01892 861658 Email: steve@spbmortgages.  

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 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.

 

Information Gathered and Its Use

We receive and store any information you enter on our website, or give us in any other way, for example during a meeting. We use your contact details only to communicate with you. We may contact you by post, email, telephone or fax. Please note that there may be instances where it may be necessary for us to communicate with you, in any event, for administrative or operational reasons relating to our service.

 

Place of Processing

The personal information held by us is held on and processed by computers situated in the United Kingdom.

 

Security

We have security measures in place to protect our customer database and access to this database is restricted internally. However, it remains your responsibility:

• If you open more than one browser of the same type whilst using the website, to remember to close down all browser windows when you finish. 
• If you share a computer with someone else or use a public Internet access then we advise you to delete the browsing history and log off the computer. This will help ensure any personal information stored temporarily in the computer's memory is lost.

Disclosure for legal and regulatory reasons

We reserve the right to communicate such personal information as we hold to third parties which seek the disclosure of it, if we are requested to do so by law or by a regulatory authority.

 

Links to Third Party Sites

Our site contains links to other sites. We are not responsible for the privacy practices, or the content of those websites. You should read the privacy policies of every website that collects data.

 

Legal Information and Your Agreement

Access by you to our web-site is confirmation that you have understood and agreed to be bound by all of these terms and conditions.

This web-site is prepared and issued in the United Kingdom and is intended for the information of United Kingdom residents only.

This web-site is for information purposes only and its content is subject to change without notice.

Nothing on this web-site shall be deemed to constitute financial advice and in the event that you wish to have any such advice, please contact us.

 

Disclaimer

Whilst we use all reasonable efforts to ensure that the information published on this website is accurate, current and complete at the date of publication, no representatives or warranties are made (express or implied) as to the accuracy, currency or completeness of such information. We cannot accept responsibility (to the extent permitted by law) for any loss arising directly or indirectly from the use of, or any action taken in reliance on, any information appearing on this web-site or any other web-site to which it may be linked. We make no warranty that this web-site is free from errors, defects or viruses.

We reserve the right to change, modify, add or remove provisions of this Privacy Policy. Any changes to this Policy will be shown here, and we recommend that you check this Policy again from time to time.

 

Copyright Notice

The entire contents of this web-site is our property and is subject to copyright with all rights reserved.

You may download or print individual sections of the web-site for personal use and information only provided that these properly indicate our copyright and other proprietary notices.

You may not reproduce (in whole or in part), modify, decompile, disassemble or transmit or use for any commercial purpose whatsoever any information from this website without our prior written consent.

 

E-Mail

There is no guarantee that any e-mail you send will be received by us or that the confidentiality of that e-mail will be maintained during internet transmission.

 

Applicable Law

Any disputes arising from the use of this website shall at all times be governed by the laws of England and Wales and the parties shall submit to the exclusive jurisdiction of the English Courts.

 

International Transfers of Personal Information

As the Internet can be assessed worldwide, if you are visiting the site from outside the UK, your visit will necessarily result in the transfer of information across international borders. By visiting this site and communicating electronically with us you are consenting to these transfers.