Higham Critchley Barrows Ltd. Registered Office: 10 Manor Park, Banbury, OX16 3TB.
Higham Critchley Barrows Ltd is also known in this document as “Higham Critchley Barrows“, “we” and “us”.
The personal data we collect about you
Personal data collected, used, stored and transferred by us could include:
- Identity – Including current and previous names, address history, date of birth, gender, marital status.
- Contact Data, including address, email address and telephone numbers
- Financial Data including bank statements used for income and expenditure assessments, proof of deposit etc., payment card details for any lender fees, details of any credit commitments, employment history & pension details and any other assets and liabilities
- Special Category Data such as medical history. This is used only for applications for Insurance.
- Transaction Data including payments and premiums for mortgages and insurance sold by us
- Marketing and Communications Data including your preferences in receiving marketing from us and our business partners and your communication preferences
How do we collect your personal data?
Personal data is collected by us using the following methods:
- Direct interactions with an adviser in person, by post, phone, email.
- Interactions with our website, social media or our Bookings page
Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as Estate agents with whom you may be interacting, but only with your consent;
How do we use your personal data?
We use your personal data in the following circumstances and relying on the following lawful basis for processing:
|To initially engage with you to discuss your requirements
|To process an application for a mortgage or protection product
||Identity, Contact, financial, special category, transaction, marketing
||Performance of a contract with you,
Necessary for our legitimate interests
Re-engagement when existing products nears expiry/ review protection needs
Profile & Usage Marketing
|Performance of a contract with you
To comply with a legal obligation
Necessary for our legitimate interests
|To respond to case enquiries & defend against complaints
Profile & Usage Transaction Marketing
|To comply with a legal obligation
Necessary for our legitimate interests
Change of purpose
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Changes to our Privacy Notice
We keep our Privacy Notice under regular review and we will place any updates on this web page. This Privacy Notice was last updated on 25th May 2018.
You will also have the choice to opt-in to receiving other related marketing information and related products and services.
You can opt-out of receiving these types of communications by clicking on the relevant link in email communications you receive from us or by contacting us on 01295 252199 or firstname.lastname@example.org.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only staff of Higham Critchley Barrows, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Who we disclose personal data to
Your personal data may be shared with third parties for the following purposes:
|Lenders and protection product suppliers
||To submit applications in order to conclude the contract for the mortgage/ protection application.
|Estate agents/ builders
||We may share information about the progress of your application with the firm estate agents and builders with whom you are interacting.
||Sharing of information may be necessary to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise cooperate with law enforcement, legal proceedings or regulatory authorities.
||Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice
These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with our instructions.
How long is your personal data retained?
We will keep information for a reasonable amount of time to perform the purposes
listed above. We only keep your information for as long as necessary. We generally keep personal
information for 7 years after last contact with you. However we reserve the right to keep information for longer if we feel that this is in the legitimate interests of Higham Critchley Barrows.
You have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also to ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact the Information Security & Data Protection Manager by emailing email@example.com or by writing to us. We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
What if I am still not satisfied?
If you are not satisfied with how we respond to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.
Please call us on 01295 252199 if you have any queries.