Who are we?
First Financial Solutions (Wales) is the controller and is responsible for your personal data.
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What do we mean by Your Personal Data?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date of birth or National Insurance number. Your Personal Data may also identify you indirectly, for example your employment situation, 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, insurance and/or finance requirements Your Personal Data 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) and employment history;
- bank account details, debit/credit card 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, insurance and/or finance products and the terms and conditions relating to these.
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your mortgage, insurance and/or finance requirements we do so on the basis that both parties are entering into a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data for the purposes detailed 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 Personal Data 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 Compliance Service Provider relating to the advice we have given to you, or make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, the Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data 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 Personal Data
Where you ask us to assist you with, for example, your insurance requirements, 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, health and medical history (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 13, it is also very likely that we will record information on our systems that relates to those children and, potentially, 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.
Information on Special 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 Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations, to establish your circumstances and needs and preferences in relation to mortgage, insurance and/or finance requirements. You will provide information to us verbally and in writing, including email, text and instant messaging (such as WhatsApp) and may also provide information to us via our website: https://www.firstfinancial.solutions/ (usually initial contact only).
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 electoral roll).
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- record and store Your Personal Data in (i) our paper files, mobile devices and computer systems (email, hard drives and cloud facilities), and (ii) on our on-line CRM/case management system (which is sourced from a third party provider). This information will only be accessed by our Firm when it is necessary to provide our service to you and/or perform any administration tasks associated with or incidental to that service;
- submit Your Personal Data to mortgage lenders, insurance product providers, finance providers and commercial lenders, both in paper form and on-line via secure portals. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise;
- use Your Personal Data for the purposes of responding to any queries you may have in relation to any mortgage, insurance and/or finance products or policies you may take out, or to inform you of any developments in relation to those products or policies of which we might become aware.
Sharing Your Personal Data
From time to time, Your Personal Data will be shared with:
- mortgage lenders, insurance product providers, finance providers and commercial lenders; and
- 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. These third parties include our Compliance Service Provider, product specialists and aggregators, 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).
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
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 being sent to us.
Your Personal Data will be retained by us only as is necessary and in accordance with our legal rights.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control;
- ask us to further explain how we use Your Personal Data;
- ask us to correct/delete, or require us to restrict/stop, using Your Personal Data (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 Personal Data 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 Personal Data
Chris Davies – Principal
First Financial Solutions (Wales)
Address: 43 Alfred Street, Neath, SA11 1EH, Wales
Telephone number: +44 (0) 1639 262222
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 Personal Data, so that we may investigate and fulfil our own regulatory obligations.
We hope that we will be able to resolve any privacy concerns you may have, but 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 Information Commissioner’s Office, who can be contacted via its website at: https://ico.org.uk/global/contact-us/ or by writing to: Information Commissioner’s Office (Wales), 2nd Floor, Churchill House, Churchill Way, Cardiff, CF10 2HH, Wales.