Smart Mortgages is authorised and regulated by the Financial Conduct Authority. The Financial Services Register number is 912358. Registered in Northern Ireland No. 912358. Registered office address for Smart Mortgages is 2 Columba Terrace, Derry/Londonderry, Northern Ireland, BT47 6JT
You can also find out more about us on our website at www.smart-mortages.co.uk
If you have any queries or concerns about how your data is being used or stored please contact us at the above address or on 028 7131 1103
This is the privacy notice of Smart Mortgages. In this document “we”, “us” or “the firm” refers to Smart Mortgages. This notice is to tell you our policy about all information that we record about you. It covers both information that could identify you and information that could not.
All policies, guidelines and procedures of Smart Mortgages reflects our commitment to the protection of the rights and privacy of individuals (including customers, staff and others) whose personal information is held by us. We have put in place a range of systems and procedures, which we review on a regular basis, in order to protect these rights and to be fully compliant with the provisions of the General Data Protection Regulation 2018.
In order to carry out our core functions, Smart Mortgages needs to collect and use personal data about our customers, staff and other individuals who come into contact with us. We need to process such information for purposes that include the advice and administration of financial transactions, recruitment and payment of staff, compliance with statutory and regulatory obligations, etc.
As a Data Controller, Smart Mortgages is legally obliged to safeguard the privacy rights of individuals in relation to the processing of their personal data for such purposes. We are committed to protect your privacy and confidentiality. We understand that all users of our website need to know that their data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party. Our policy is both specific and strict and complies with UK law, including the Data Protection Act 1998 and the General Data Protection Regulation 2018. If you think our policy falls short of your expectations or that we are failing to abide by our policy, please do tell us.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
Except as set out below, we do not share or sell, or disclose to a third party, any personally identifiable information collected on this site.
What Personal information do we collect?
We will only collect data that is required for your mortgage or protection needs and to enable us to give you the right advice when it comes to these needs. Personal information includes:
- Basic identification and contact information
- Financial data and circumstances, such as bank statements, income and expenditure details etc.
- Family details such as spouse, dependents
- Employment and lifestyle
- Sensitive information such as nationality, residence status and medical history.
- Marketing preferences
- Your domain and email address
- When we receive a complaint, we record all the information you have given us. We use that information to resolve your complaint. If your complaint reasonably requires us to contact some other person, we may decide to give that person some of the information contained in your complaint. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
- If you send us information in connection with a job application (eg CV) we may keep it for up to three years in case we decide to contact you at a later date. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
- Although we do not disclose your information to any third party (except as set out in this notice) we do receive data which is indirectly made up from your personal information, from software services such as Google Analytics and others. No such information is identifiable to you.
- As we are subject to the law we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
How do we collect it?
Personal data will only be collected in one of the following ways:
- Direct interactions with an adviser, either face-to-face, by phone, email, post or otherwise in the process of sourcing and applying for mortgage or protection policies.
- Automated technologies or interactions on our website, by using the “Contact Us” enquiry form on the website
- Estate Agents and other introducers who you may have consented to let pass your details to us
Why do we need this information and what is legal basis for processing?
Personal data and sensitive personal data will only be disclosed in ways that are necessary or compatible with the purpose for which the data is kept. In these circumstances, we need to know basic personal data and may share this information:
- To enable Smart Mortgages and our representatives to manage your dealings with us. We may use personal information supplied to meet your needs in arranging a mortgage, loan, protection and any associated arrangements. Data will be processed in the legitimate interest of the business.
- To disclose information to any third parties relevant to the transaction; such as lenders, insurers, lending specialists or contracted software providers. Data will be processed in the legitimate interest of the business.
- In order to verify your circumstances, third parties may be contacted such as your employer, accountant or credit reference agency. Data will be processed in the legitimate interest of the business.
- For compliance monitoring purposes, your data may be made available to the Financial Conduct Authority. Data will be processed in the legitimate interest of the business.
- To allow Smart Mortgages or their representatives to conduct compliance monitoring, to prevent financial crime, and to contact you for the purpose of ensuring you have received adequate advice. Data will be processed in the legitimate interest of the business.
- To assert our legitimate interest to be recompensed in return for our services in accordance with our Terms of Business.
- If you do not provide this information, then we will be unable to provide the services you have requested. We will not collect any personal data from you that we do not need in order to provide and oversee the services we provide.
- If you provide an e‐mail address, you consent to us sending communications by e‐mail. While we will take reasonable steps to ensure security of information by e‐mail, you accept the risks involved with this type of communication.
- To update other parties in the progress of your application, such as selling agent, vendor, solicitor, conveyancer, etc. We will only do this with your express consent.
- To update you on our own products and services or to review your current mortgage and protection needs, we may contact you for a period of 5 years unless you renew your permission. We will only do this with your express consent.
What will the information be used for?
All the personal data we hold about you will be processed by our staff in the United Kingdom and selected third parties as detailed above will have access to your personal data where there is a service they provide to us or there is a legal obligation for us to provide them with this. Please be aware, however, that your information may be stored on a cloud‐based system whose servers are located within the United Kingdom
How long will we keep it?
We will generally keep your personal data for a minimum of 6 years after our business relationship, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. The business relationship will usually be classed as over once we are aware any mortgage or insurance product has ended.
How is personal data secured?
Smart Mortgages has put in place appropriate stringent security controls to protect personal data from unauthorised access when in use and in storage, or from being destroyed, altered, lost or corrupted.
What are your rights?
Under data protection legislation, you have several rights relating to the use of your personal data
- You have the right to ask for a copy of information, usually free of charge. We will respond to this request within a month.
- You also have the right for certain data you have provided us with to be provided to you in a structured and commonly used electronic format (for example, a Microsoft Excel file), so that you can move, copy or transfer this data easily to another data controller.
- Family details such as spouse, dependents
- You may also request that we transmit this data directly to another organisation where it is practical for us to do so.
- You have the right to have personal data rectified if it is inaccurate or incomplete.
- You are entitled to have data deleted if it is no longer needed or there is no longer a legitimate reason for the processing, or if the data in question has otherwise unlawfully been processed.
- You may also request deletion of your personal data if it was only being processed as a result of you consenting to this and you now withdraw your consent
- You have the right to object to the processing of your personal data (note that this only provides you with the right to raise your objections, not a blanket right to have any and all processing cease).
- You have the right to restrict the processing of your personal data under certain circumstances, including if you have contested its accuracy and while this is being verified by us, or if you have objected to its processing and while we are considering whether it has legitimate grounds to continue to do so.
How to complain about use of your data
If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact email@example.com and they will investigate your concerns. If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). You can find further information about the ICO and their complaints procedure here: https://ico.org.uk/concerns.