H D Consultant - Customer Privacy Notice – v1 July 2023 
 
Customer Privacy Notice 
 
H D Consultants (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. 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. 
 
H D Consultant - Customer Privacy Notice – v1 July 2023 
 
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. 
 
H D Consultant - Customer Privacy Notice – v1 July 2023 
 
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. 
 
These parties may be located in the UK or elsewhere in the world where different privacy laws 
may apply which may not offer the same level of protection as UK law. We only make these 
arrangements or transfers where we are satisfied that adequate levels of protection are in place 
to protect any information held in that country and that the service provider acts at all times in 
compliance with applicable privacy laws. 
 
H D Consultant - Customer Privacy Notice – v1 July 2023 
 
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 https://www.primis.co.uk/index.php/terms-and-conditions/ 
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. 
 
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. 
 
H D Consultant - Customer Privacy Notice – v1 July 2023 
 
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: 
H D Consultants 
109 Maldon Road 
Colchester 
Essex CO3 3AX 
 
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. 
 
H D Consultants. Contact details here Live Chat webpage here Broker Log In / BrokerCentre here 
 
Head Office address; 109 Maldon Road, Colchester, Essex CO3 3AX (Administration Centre only) 
 
Your home may be repossessed if you do not keep up repayments on your mortgage. 
 
We normally charge a Professional Client Fee for mortgage advice. The amount will depend on your circumstances. A typical fee would be £500. The actual Professional Fee may be more or less than this, and is subject to a full Fact Find discussion and research process. H D Consultants is a trading name of Howard Reuben who are an Appointed Representative of PRIMIS Mortgage Network, a trading name of Personal Touch Financial Services Ltd. Personal Touch Financial Services Ltd is authorised and regulated by the Financial Conduct Authority. Registered Office: Preston House, 163 High Street, Crowthorne, Berkshire, RG45 7AF. Registered in England & Wales. Company Registration Number 4952586. This site is for UK Consumers only. Website Terms and Conditions click here for our Privacy Policy. GDPR Privacy Policy - click here (PDF download / view) This site contains third party links. By clicking these links you will depart from the H D Consultants' regulated site. H D Consultants nor PRIMIS Mortgage Network is responsible for the accuracy of the information contained within the linked site. The Financial Conduct Authority does not regulate some of the services listed. H D Consultants, mortgage and life insurance advisers, is authorised by the FCA no 403701. Our in house Wills and Trusts Practice is a long standing Member of the Society of Will Writers and Estate Planning Practitioners.  
FP Ref: 1436009 / exp 25.08.2025 
Long established, recognised and national nominees and award winners for our professional mortgage services; 
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