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.
