Legal info, Privacy statement and Cookie policy

Short version

Your home may be repossessed if you do not keep up repayments on your mortgage.

Mortgage Broker Reading is a website owned by Des Tourick, who is a Director and mortgage and insurance adviser of 1st Call 4 Mortgages (UK) Ltd.

Directors: Desmond Tourick and Paul Butler. 

Registered address: 78 Hilmanton, Lower Earley, Reading, Berkshire, RG6 4HN.

Registered in England and Wales under number 09333010.

1st Call 4 Mortgages (UK) Ltd is regulated and authorised by the Financial Conduct Authority under number 676588 in respect of mortgage, insurance and consumer credit mediation activities only.

The information contained within this website is subject to the UK regulatory regime and is therefore primarily targeted at consumers based within the UK.

Long version

TREATING CUSTOMERS FAIRLY

We are committed to offering our customers the highest possible standards of service.

In so doing, we are pleased to support the Financial Conduct Authority’s initiative ‘Treating Customers Fairly’.

We recognise that both we and our customers have everything to gain if we look after your best interests and treat you fairly in all aspects of our dealings with you.

Our commitment to you

We will:
• provide you with clear information about the products and service we offer, including fees and charges
• ascertain your individual needs, preferences and circumstances before recommending a mortgage
• only recommend a mortgage that we consider suitable for you and that you can afford – and always the most suitable from the available options
• not recommend a mortgage if we can’t find one we consider suitable
• encourage you to ask if there’s something you don’t understand
• give you access to a formal complaints procedure should you become unhappy with our service

How you can help us

To help us give you the most appropriate advice, we will ask you to:
• tell us as much as possible about your income and outgoings, to enable us to properly assess how much you can afford
• let us know about changes that might affect your ability to repay a mortgage
• let us know if there is any aspect of our service, or of a product we have discussed or recommended, that you don’t understand
• tell us if you think there are ways we can improve our service

Through TCF, we aim to deliver improved outcomes for our clients.

Once we have completed our business together, and we have successfully arranged your mortgage and/or protection arrangements, we ask you to complete a short survey to give us feedback about your experiences of using our services.

PRIVACY STATEMENT

 
Introduction

1st Call 4 Mortgages (UK) Ltd is one of the UK’s leading mortgage advice brokers.

1st Call 4 Mortgages (UK) Ltd takes your privacy seriously and takes every reasonable precaution to safeguard the personal information you supply to us.

1st Call 4 Mortgages (UK) Ltd recognizes that your privacy and the protection of your personal information are important to you – this statement discloses how 1st Call 4 Mortgages (UK) Ltd helps to protect your personal information.

1st Call 4 Mortgages (UK) Ltd is registered at the Information Commissioner’s Office under registration number ZA124100.  To find out more information about data protection, you can visit: http://www.informationcommissioner.gov.uk

 

1ST CALL 4 MORTGAGES (UK) LTD – Data Protection Policy

 

CONTENTS

1. Introduction

2. Why this Policy Exists

3. Data Protection Law

4. Responsibilities

5. Data Protection Impact Assessments (DPIA)

6. Individuals’ Rights

7. Subject Access Request (SAR)

8. Complaints9 Data Use

9. Data use

10. Data Security and Storage

 

  1. Introduction

1st Call 4 Mortgages (UK) Ltd needs to gather and use certain information about individuals.

This can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

  1. Why this policy exists

This data protection policy ensures 1st Call 4 Mortgages (UK) Ltd:

  • complies with data protection law and follows good practice
  • protects the rights of all individuals’ data
  • is open about how it stores and processes individuals’ data in line with individuals’ rights
  • protects itself from the risks of a data breach
  1. Data protection law

The General Data Protection Regulations  (GDPR) describe how organisations — including 1st Call 4 Mortgages (UK) Ltd— must collect, handle and store personal information.  These rules apply regardless of whether data is stored electronically or otherwise.

To comply with the law, personal information must be;

 

  • processed lawfully, fairly and in a transparent manner in relation to individuals;
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
  • adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  • processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Record Keeping:

A range of information must be detailed in our internal records of processing activities. Such areas include;

  • name and details of the organisation
  • include, if appropriate, details of other data controllers, the organisation’s representative and data protection officer
  • purposes of processing the data
  • description of the categories of individuals and the categories of personal data
  • categories of the recipients of personal data
  • details of transfers of data to third parties or abroad, including details of safety mechanisms
  • retention schedules
  • technical and organisational security measures

1st Call 4 Mortgages (UK) Ltd ensure that records of these activities are kept and are updated accordingly. Individuals’ data is kept on file for 6 years in line with the Financial Conduct Authorities record keeping rules. After which point, personal data is retracted to the point it is unidentifiable and used for statistical purposes only.

  1. Lawful Basis for Processing Data

 Under GDPR, it is a requirement that 1st Call 4 Mortgages (UK) Ltd has a valid lawful basis to process personal data, this should be documented. Most lawful bases require that processing is ‘necessary’.

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever 1st Call 4 Mortgages (UK) Ltd process personal data:

For Processing of data to be lawful under GDPR, 1st Call 4 Mortgages (UK) Ltd use;

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

1st Call 4 Mortgages (UK) Ltd has chosen this basis for processing data as it is requested from the individuals that we capture data before entering into a contract (e.g. provide a quote for finance).

Special categories of data may be captured by 1st Call 4 Mortgages (UK) Ltd for example, information about an individual’s:

  • race;
  • ethnic origin;
  • religion;
  • biometrics (where used for ID purposes);
  • health;

You need to identify both a lawful basis for general processing and an additional condition for processing this type of data.

If you are processing criminal conviction data or data about offences, you need to identify both a lawful basis for general processing and an additional condition for processing this type of data.

  1. Responsibilities

 1st Call 4 Mortgages (UK) Ltd acts as a data Controller and Data Processor. All staff are responsible for ensuring that the highest data standards and best practices are met on a continual basis.

Although a Data Protection Officer (DPO) has not been appointed as 1st Call 4 Mortgages (UK) Ltd does not fall within the scope, the Directors are accountable and responsible for compliance with GDPR and will take on the tasks appointed to them as if they were a DPO.

  1. Data Protection Impact Assessments (DPIA)

1st Call 4 Mortgages (UK) Ltd has a general obligation to implement technical and organisational measures to demonstrate that data protection is integrated into our processing activities. A Data Protection Impact Assessment is conducted each time 1st Call 4 Mortgages (UK) Ltd consider implementing using new technologies

The DPIA will pertain at least;

  • a description of the processing operations and the purposes, including, where applicable, the legitimate interests pursued by the controller;
  • an assessment of the necessity and proportionality of the processing in relation to the purpose;
  • an assessment of the risks to individuals;
  • the measures in place to address risk, including security and to demonstrate that you comply.
  1. Individuals Rights

Individuals now have more rights under GDPR, these are;

  • the Right to be Informed
  • the Right of Access
  • the Right to Rectification
  • the Right to Erasure
  • the Right to Restrict Processing
  • the Right to Data Portability
  • the Right to Object
  • rights in relation to automated decision making and profiling.

1st Call 4 Mortgages (UK) Ltd provide every customer with a Privacy Notice at the point data is captured.

The information supplied in this notice demonstrates how 1st Call 4 Mortgages (UK) Ltd is transparent over our data processing. The notice is;

  • concise, transparent, intelligible and easily accessible;
  • written in clear and plain language, particularly if addressed to a child; and free of charge.

We include details of (but not limited to);

the Data Controller, the lawful reason for processing data, if any third parties have legitimate interests, categories of personal data, categories of recipients such as banks and credit unions, the data retention periods,

the individuals’ rights; including the right to withdraw, where the individual can complain about how the data is processed with a supervisory authority, a source of data when it comes from a third party and where personal data is part of a contractual requirement or obligation.

Rectification

Individuals are entitled to have personal data rectified if it is inaccurate or incomplete. 1st Call 4 Mortgages (UK) Ltd has disclosed the personal data in question to third parties, then we will inform them of the rectification where possible.

1st Call 4 Mortgages (UK) Ltd will respond to this request within one month or extended by two months where the request for rectification is complex.

Erasure

Individuals have a right to have personal data erased and to prevent processing in specific circumstances;

  • where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
  • when the individual withdraws consent.
  • when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
  • the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).
  • the personal data must be erased to comply with a legal obligation.
  • the personal data is processed in relation to the offer of information society services to a child.
  • under the GDPR, this right is not limited to processing that causes unwarranted and substantial damage or distress. However, if the processing does cause damage or distress, this is likely to make the case for erasure stronger.

1st Call 4 Mortgages (UK) Ltd may refuse to comply with a request for erasure where the personal data is processed for the following reasons;

  • to exercise the right of freedom of expression and information;
  • to comply with a legal obligation for the performance of a public interest task or exercise of official authority.
  • for public health purposes in the public interest;
  • archiving purposes in the public interest, scientific research historical research or statistical purposes; or
  • the exercise or defence of legal claims.

If 1st Call 4 Mortgages (UK) Ltd has disclosed the personal data in question to third parties, a notification will be sent, informing them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.

Restrict processing

1st Call 4 Mortgages (UK) Ltd will restrict the processing of personal data in the following circumstances;

  • where an individual contest the accuracy of the personal data, you should restrict the processing until you have verified the accuracy of the personal data.
  • where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and you are considering whether your organisation’s legitimate grounds override those of the individual.
  • when processing is unlawful, and the individual opposes erasure and requests restriction instead.
  • if you no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim.

If any data has been disclosed to third parties, 1st Call 4 Mortgages (UK) Ltd will notify them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so.

Portability

For personal data an individual has provided to a controller; where the processing is based on the individual’s consent or for the performance of a contract; and when processing is carried out by automated means, 1st Call 4 Mortgages (UK) Ltd must provide the personal data in a structured, commonly used and machine-readable form. Open formats include CSV files. Machine-readable means that the information is structured so that software can extract specific elements of the data. This enables other organisations to use the data.

1st Call 4 Mortgages (UK) Ltd must provide this service free of charge.

If the individual requests it, we may be required to transmit the data directly to another organisation if this is technically feasible. 1st Call 4 Mortgages (UK) Ltd will respond without undue delay, and within one month or extended by two months where the request is complex or receive many requests.

Objecting

If an individual has objected to processing data or direct marketing, 1st Call 4 Mortgages (UK) Ltd will cease to process the data.

Individuals must have an objection on “grounds relating to his or her particular situation”.

1st Call 4 Mortgages (UK) Ltd will stop processing the personal data unless;

  • compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or
  • the processing is for the establishment, exercise or defence of legal claims.

This is brought to the attention of the data subject at the first point of communication and in our privacy notice. This is separated out from any other information.

Direct marketing purposes

As soon as an objection is received, 1st Call 4 Mortgages (UK) Ltd will stop processing personal data for direct marketing purposes.  This will be actioned at any stage and is free of charge.

Automated decision making including profiling

1st Call 4 Mortgages (UK) Ltd understand that any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse, or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour falls under this right. Where this is conducted, the rules and guidance of the ICO will be adhered to and followed. To date, 1st Call 4 Mortgages (UK) Ltd does not conduct automated decision making including profiling.

  1. Subject Access Requests (SAR)

Individuals who are the subject of personal data held by 1st Call 4 Mortgages (UK) Ltd are entitled to;

  • confirmation that their data is being processed;
  • access to their personal data; and
  • other supplementary information – this largely corresponds to the information that should be provided in a privacy notice

Individuals contacting the company requesting this information, this is called a Subject Access Request.

1st Call 4 Mortgages (UK) Ltd will provide a copy of the information free of charge. However, a ‘reasonable fee’ may be charged when a request is manifestly unfounded or excessive, particularly if it is repetitive.

A reasonable fee may also be charged to comply with requests for further copies of the same information. The fee is based on the administrative cost of providing the information only.

Once the identity of the person making the request has been verified, the information will be provided within 1 month, this will be extended to 2 months if the request is complex. Notification will be made to the individual if this is the case.

  1. Complaints

It is made clear that data subjects who wish to complain about how their personal data has been processed can raise this with 1st Call 4 Mortgages (UK) Ltd complaints procedure. If the data subject is still not happy, then the complaint can be referred to the Information Commissioners Office.

  1. Data Security and Storage

When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see or have access to it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason;

  • when not required, the paper or files should be kept in a locked drawer or filing cabinet.
  • employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer;
  • data printouts should be shredded and disposed of securely when no longer required.

When data is stored electronically, it must be protected from unauthorised access, accidental deletion, and malicious hacking attempts;

  • data should be protected by strong passwords or encryption products;
  • if data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used;
  • data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service;
  • servers containing personal data should be sited in a secure location, away from general office space;
  • data should be backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures;
  • data should never be saved directly to laptops or other mobile devices like tablets or smart phones;
  • all servers and computers containing data should be protected by approved security software and a firewall.

The point that personal data is accessed is when it can be at greatest risk of loss, corruption, theft, unlawful access, 1st Call 4 Mortgages (UK) Ltd will;

  • when working with personal data, employees should ensure the screens of their computers are always locked when left unattended;
  • personal data should not be shared informally. It should never be sent by email, as this form of communication is not secure.
  • data must be encrypted before being transferred electronically.
  • personal data should never be transferred outside of the European Economic Area unless contractual arrangements are in place highlighting adequate safeguards and protection to the rights of individuals.
  • employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Changes to this Privacy Statement

1st Call 4 Mortgages (UK) Ltd will occasionally update this Privacy Statement. When we do, we will also revise the “last updated” date at the top and bottom of the Privacy Statement. 1st Call 4 Mortgages (UK) Ltd will obtain your opt-in consent for any updates to this Privacy Statement that materially expand the sharing or use of your personal information in ways not disclosed in this Privacy Statement at the time of collection.

Contact information

If you have questions regarding this Privacy Statement, please write to us at:

1st Call 4 Mortgages (UK) Ltd, 78 Hilmanton, Lower Earley, Reading, Berkshire, RG6 4HN

or email to: compliance@1stcall4mortgages.co.uk

Last Updated: May 2018

USE OF COOKIES

What Are Cookies

As is common practice with almost all professional websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the site’s functionality.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases, there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

  • Site preferences cookies in order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

Third Party Cookies

In some special cases, we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site.

  • This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.For more information on Google Analytics cookies, see the official Google Analytics page.
  • From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.
  • The Google AdSense service we use to serve to advertise uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you. For more information on Google AdSense see the official Google AdSense privacy FAQ.
  • We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work the following social media sites including; {List the social networks whose features you have integrated with your site?:12}, will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

More Information

Hopefully, that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.

However, if you are still looking for more information then you can contact us through one of our preferred contact methods:

  • Email: compliance@1stcall4mortgages.co.uk
  • By writing to: Compliance Dept, 1st call 4 Mortgages (UK) Ltd, 78 Hilmanton, Lower Earley, Reading, Berkshire, RG6 4HN

Changes to this Privacy Statement

1st Call 4 Mortgages (UK) Ltd will occasionally update this Privacy Statement. When we do, we will also revise the “last updated” date at the top and bottom of the Privacy Statement. 1st Call 4 Mortgages (UK) Ltd will obtain your opt-in consent for any updates to this Privacy Statement that materially expand the sharing or use of your personal information in ways not disclosed in this Privacy Statement at the time of collection.

If you choose to use our referral service to tell a friend about our site, we will ask you for your friend’s name and email address. We will send your friend an email inviting him or her to visit the site. 1st Call 4 Mortgages (UK) Ltd stores this information for the sole purpose of sending this email and tracking the success of our referral program.

Your friend may contact us to request that we remove this information from our database.

COMPLIANTS PROCEDURE

We always aim to provide excellent customer service and when that doesn’t happen, we want to know. Listening to you and learning from what you have to say will help us get it right next time, and we appreciate your help to do this. If you are not happy with service that you have received, or you want to make a complaint, please contact: Complaints Department, 1st Call 4 Mortgages (UK) Ltd, 78 Hilmanton, Lower Earley, Reading, RG6 4HN. Telephone: 0330 606 1455.Should you be unhappy with the resolution to your complaint you may contact the Financial Ombudsman Service, who can be contacted at the following address: Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR. Telephone 0845 080 1800.

CONTACT INFORMATION

If you have questions regarding any information on this page, please write to us at:

1st Call 4 Mortgages (UK) Ltd, 78 Hilmanton, Lower Earley, Reading, Berkshire, RG6 4HN