Mortgages First Ltd is committed to protecting your privacy
In this Privacy Notice the terms, 'we', 'us' and 'our' are references to Mortgages First Ltd (Mortgages First), company number 05964060 registered at Floor 2, Gateway 2 Holgate Park Drive, York, England, YO26 4GB. Mortgages First is part of LSL Property Services plc (LSL Group). Mortgages First is also an Appointed Representative of PRIMIS Mortgage Network a trading name of First Complete Limited (Our Network).
This Privacy Notice sets out the basis on which any personal data we collect from you or you provide, to us through our website (https://www.mortgages-first.co.uk/) (Our Site), or via other methods which you may use to communicate with us, will be processed. Please read the following carefully;
What information is being collected if you are a prospective or existing customer?
In what circumstances will your Special Data and Criminal Disclosures be collected?
The legal basis upon which we deal with your information
The basis upon which Our Network will deal with your information
Use of the information we collect
What is the source of the information we collect?
Disclosure of information
Third party websites
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws.
By accessing, browsing or otherwise using Our Site you confirm that you have read and agree to this Privacy Notice. If you do not agree with any part of this Privacy Notice, you should not use Our Site or use our services.
We reserve the right to change the contents of Our Site, including this Privacy Notice at any time, by posting such changes on Our Site. It is your responsibility to familiarise yourself with the Privacy Notice regularly to ensure that you are aware of any changes. Your continued use of Our Site following the posting of any such changes will constitute your acceptance of the revised Privacy Notice.
This Privacy Notice was last updated on 31 December 2021
WHAT INFORMATION IS BEING COLLECTED IF YOU ARE A PROSPECTIVE OR EXISTING CUSTOMER?
We may collect personal information from you in connection with your use of Our Site, including such personal information as:
- your name, postal address, phone number and email address when you submit a request to be contacted through our Contact Us page or when you provide a friend’s contact information through the Recommend a Friend page;
- cookie data which relates to your use of Our Site;
- data sent from your browser to our server which may include:
- the time, date and duration of your visit to Our Site;
- the site from which you have come (the referral URL);
- the pages visited on Our Site; and
- your IP address.
We may also collect information from you when we provide you with assistance in relation to your mortgage and/or insurance requirements, including personal information such as:
- your title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and any other identity documents as are necessary to verify your identity and the results of any identity checks which we carry out;
- employment and remuneration information (including salary/bonus schemes/overtime/sick pay/other benefits) including your employment history;
- bank account or credit card details, tax information, loans and other credit commitments, personal credit history, national insurance number, sources of income and expenditure, family circumstances and details of dependents;
- confirmation of whether or not you smoke and alcohol consumption levels;
- any pre-existing mortgage and/or insurance products and the terms and conditions relating to these;
- credit reference checks;
- details of the type of mortgage, insurance and/or protection you require where you are receiving mortgage, insurance and/or protection advice from us;
- details provided to us by the underwriter of your policy relating to any claims made by you once your policy is live. This allows us to monitor claims handling processes and ensure we have the information we need to assist you with the renewal of your policy; and
- responses and feedback which you provide to us in customer surveys, in order that we can monitor the quality of the service we provide and make improvements.
IN WHAT CIRCUMSTANCES WILL YOUR SPECIAL DATA AND CRIMINAL DISCLOSURES BE COLLECTED?
We may collect personal information from you which is of a sensitive nature. Where we do so we treat this information in accordance with the additional protection it is given under data protection laws. Where you ask us to help 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 (including the health and medical history of your family where appropriate) (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.
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 as permitted by UK data protection related laws and regulations from time to time. Information on Special Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as us and insurance providers, to enable customers to secure the important insurance protection that they require.
THE LEGAL BASIS UPON WHICH WE DEAL WITH YOUR INFORMATION
Wherever we collect or use your personal information, we will make sure we do this for a valid legal reason. This will be for at least one of the following purposes:
- because it is necessary to fulfil the terms of our contract with you - if you have entered into a contract with us for example to provide mortgage advice;
- because it is necessary to support the legitimate interests of our business to provide you with an efficient service that meets your needs - for example, we may need to respond to requests from mortgage 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. In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the section on Your Rights below;
- to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities
- where we have obtained a clear consent from you - we will always make it clear when we need your consent and how you can change your permissions at any time thereafter.
If you would like to know more about the legal reasons or legitimate interests that apply to a particular way in which we use personal information you can contact us at any time.
THE BASIS UPON WHICH OUR NETWORK WILL DEAL WITH YOUR INFORMATION
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, protection and/or insurance products, where those products are regulated by the FCA. In the course of doing so, Our Network will process your information, 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 Our 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 Our 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 Our 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 ICO or any other regulatory, law enforcement or governmental body; and
- 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 we have 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 Our Network to fulfil its legal and regulatory obligations.
USE OF THE INFORMATION WE COLLECT
Your information will be used by us in connection with the following purposes:
Providing You with Services:
- To allow us to provide you with the mortgage, protection or insurance services which you have asked us to provide, including:
- offering you advice;
- obtaining quotes;
- assisting you with applications for products by submitting your information to product providers both in paper form and online via 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 the providers may raise; and
- keeping you informed of any developments in relation to any product which we help you to take out;
- to keep our client records up to date;
- to improve our services by analysing your personal information so we better understand how you use our services;
- to process financial transactions relating to your product such as taking payment for services which we provide and processing refunds;
Responding to Your queries:
- to help answer any questions which you have asked one of our agents or staff members;
- to provide you with a quote for our services;
Improving Our Site:
- to analyse cookie and website usage data to keep improving Our Site;
Legal and Regulatory Obligations:
- to comply with applicable laws where we are obliged to retain and/or disclose certain information;
- to investigate or address claims or complaints relating to your use of our services;
- to upload your information along with full details of the mortgage, protection or insurance product discussed with you or which you have taken out, to the computer systems of Our Network;
- for internal and external auditing purposes;
- to carry out anti-money laundering checks; and
- to transfer information to any entity which may acquire rights in us.
WHAT IS THE SOURCE OF THE INFORMATION WE COLLECT?
The majority of the personal information which we collect will have been voluntarily provided by you, however we may also obtain your personal data from other sources including:
- other LSL Group companies;
- third parties including credit reference agencies and law enforcement/regulatory bodies;
- introducers who have referred you to us for the delivery of our services;
- your, estate agent, new homes developer, solicitor and/or mortgage provider; and
- other publicly available sources such as the electoral roll and HM Land Registry.
The personal information that you provide will be retained by us in accordance with applicable laws and our internal Retention Policy. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above. We will only hold your personal information on our systems for as long as is necessary for the relevant purpose for which it was collected. A copy of our Retention Policy is available on request.
DISCLOSURE OF INFORMATION
The information you provide to us will be held in the UK and may be accessed by or given to our staff or to any member of the LSL Group for the purposes set out in this Privacy Notice or for other purposes approved by you. With your consent, we may also provide your personal information to other companies within the LSL Group for the purposes of providing you with additional products and services.
We may also disclose your information to the third parties listed below for the following purposes:
- product and mortgage providers for the purpose of providing us or you with a quotation and to allow them to process your application;
- law enforcement bodies and/or other regulatory entities in order to comply with any legal obligation or court order;
- third parties and their associated companies and sub-contractors we work with as part of providing our services and performing any administration tasks associated with or incidental to those services, including (but not limited to):
- IT administrators;
- software providers; and
- payment service providers;
- our professional advisers, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- with your consent, eSurv where you would like us to arrange for a surveyor to provide you with a quote for their services;
- with your consent, First 2 Protect Limited where you require general insurance advice;
- with your consent one of our panel conveyancing services where you require conveyancing advice
- third parties as necessary in the event of a claim or dispute relating to the use of our services;
- your solicitor, mortgage provider and (where applicable) the agent or new homes developer dealing with a property you wish to purchase, for the purpose of providing them with progress and/or status updates on the services which we are providing to you and/or to liaise with them on your behalf;
- Our Network to allow them to monitor the advice which we provide to you; and
- entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation.
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.
THIRD PARTY WEBSITES
Our Site may contain links to other websites. We accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by our Privacy Notice.
We employ security measures which aim to protect the information provided by you from access by unauthorised persons and against unlawful processing, accidental loss, destruction or damage.
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.
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. Click on the links below to learn more about each right you may have:
- To access personal information
- To rectify / erase personal information
- To restrict the processing of your personal information
- To transfer your personal information
- To object to the processing of personal information
- To object to how we use your personal information for direct marketing purposes
- To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
- To lodge a complaint with your local supervisory authority
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us using the details in the Contact section of this Privacy Notice. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
If you have questions or comments about our Privacy Notice or if you wish to exercise your rights mentioned above, please contact our Data Protection Officer by:
If you have any concerns or complaints as to how we have handled your personal data 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.