- Mortgage Distributor
- Mortgage Packager
- Mortgage Broker
INTRODUCTION
1. This is a notice to inform you of our policy about all the information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
2. If there are one or more points below with which you do not agree with, are unsure about, you should advise us immediately and we can provide an explanation as appropriate.
WHO WILL PROCESS INFORMATION ABOUT YOU?
Your Personal Information will be initially processed by Impact Specialist Finance Limited who will process your personal data in accordance with this Privacy Notice
WHY IS YOUR PERSONAL INFORMATION REQUIRED?
Your Personal Data is essential to enable us to take steps at your request prior to entering into a contract, or to perform such a contract. This may include reviewing assets and liabilities, bank account validation, identity and age verification checks, credit checks, preventing and detecting fraud, money laundering or other crimes and any other requirements in accordance with rules set by the Financial Conduct Authority (FCA) or other applicable legislation.
WHAT HAPPENS IF WE WANT TO PROCESS YOUR INFORMATION FOR OTHER REASONS?
Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about we will notify you.
WHAT ARE THE CONSEQUENCES IF YOU DO NOT WISH TO PROVIDE YOUR PERSONAL INFORMATION?
Your Personal Data is essential to enable us to take steps at your request prior to entering into a contract, or to perform a contract to which you are a party. Without this information, we will not be able to proceed to provide any financial service.
WHAT MAKES THE PROCESSING LAWFUL?
Because the processing is necessary:
KEEPING YOUR INFORMATION UP TO DATE
We will record your information exactly as you provide it. You may ask us to update it at any time and we will action your request promptly and where possible notify relevant third parties of any changes,
WHAT ABOUT SENSITIVE PERSONAL DATA?
Unless we are processing because it is necessary for reasons of substantial public interest, we will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific and informed consent for specific processing activities. In such cases you will be asked to sign a separate consent form to evidence this and that you understand the purpose(s) of the processing of such data. Your consent may be withdrawn at any time.
HOW WILL WE FURTHER USE YOUR PERSONAL INFORMATION (OUR LEGITIMATE INTERESTS)?
You have the right to object to processing for these purposes and we shall cease unless we can show we have compelling legitimate grounds to continue.
PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST
We will use the information provided to protect members of the public against dishonesty, money laundering or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group PLC or CreditSafe BusinessSolutions Ltd
WHAT INFORMATION IS REQUIRED?
We only collect information that is necessary to carry out the purposes listed above. This includes information you supply and data we receive from reference agencies. Where practical and lawful e will inform you about any personal data we receive about you from third parties that you may be unaware of.
HOW SECURE WILL YOUR DATA BE?
We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security measures will be in place to prevent unauthorised access, alteration, disclosure, loss, damage, or destruction of your information. If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we'll make sure they give reassurances regarding appropriate security measures in place and only process your information in the way we've authorised them to. These organisations won't be entitled to use your personal information for their own purposes. If necessary our security team will check them to make sure they meet the security requirements we've set.
WILL WE SHARE YOUR INFORMATION WITH ANYONE ELSE?
We may share your information with:
TRANSFERRING DATA OUTSIDE THE EUROPEAN UNION
We do not usually transfer any of your personal data outside of the EU except when we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies, like Creditsafe Business Solutions Ltd, may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases, Creditsafe encrypts any data it sends to other agencies and only transfers information necessary to carry out checks.
(A list of countries used to perform checks include Germany, Netherlands, Belgium, France, Sweden, Norway, Finland, Luxembourg, Switzerland, Liechtenstein, Spain, USA, Estonia, Latvia, Lithuania, Poland, Slovakia, Czech Republic, Hungary, Slovenia, Bosnia, Serbia, Montenegro, Croatia, Macedonia, Kosovo, Albania, Bulgaria, Romania, Ukraine, Austria, Denmark, Moldova, Portugal, Italy, Canada, Brazil, Greenland, China, India, Australia, Russia, South Korea, Taiwan, Mexico, South Africa, New Zealand, Hong Kong, UK.)
WHAT ABOUT DIRECT MARKETING
We will use the information provided now and in the future to carry out direct marketing activities as these are legitimate interests pursued by us. Sometimes this includes with your consent, sharing data with product providers for their marketing activities. You can choose which method you'd prefer us to use to contact you (by email, telephone, SMS or post) and you have the right to object at any time to the use of your personal data for this purpose and we will cease marketing activity. Just let the person who gave you this form know about your preferences.
AUTOMATED DECISION-MAKING PROCESSES
We sometimes us automated processes when making decisions but you will not be subject to a decision based solely on automated processing, including profiling.
TELEPHONE CALL RECORDING
In line with The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 we may record incoming or outgoing telephone conversations for the following purposes.
HOW LONG WILL WE KEEP YOUR INFORMATION FOR?
The Financial Conduct Authority lays down rules relating to how long information should be held for and we will keep your information to meet those requirements. We will not keep your information for longer than necessary.
REQUESTING A COPY OF THE INFORMATION WE HOLD
You may at any time ask for a copy of the information we hold about you - it is your legal right. We will provide you with a copy of any non-exempt personal information within one month unless we ask you for an extension of time. To protect Your Personal Data, we will ask you to verify your identity before we release any information. We may refuse your request if we are unable to confirm your identity.
IMPORTANT RIGHTS
You have the right, on grounds relating to your situation, at any time to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. We will no longer process your data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defense of legal claims.
You have the right to object at any time to processing your personal data for marketing activities. In such a case we must stop processing for this purpose.
WHAT ARE YOUR OTHER LEGAL RIGHTS?
In addition to the rights above the additional following rights:
To exercise any of these rights please contact us (details below)
HOW TO CONTACT OUR DATA PROTECTION OFFICER
You can contact our data privacy office/data protection officer* about any data protection or marketing issues:
By writing to:
The Data Protection Officer,
Impact Specialist Finance
20 Barttelot Road
Horsham
West Sussex
RH12 1DQ
By telephone: 01403 272625
By emailing: GDPR@impactsf.co.uk
HOW DO YOU MAKE A COMPLAINT TO THE REGULATOR
By writing:
Information Commissioner's Office,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF
By telephone: 0303 123 1113
By emailing: casework@ico.org.uk
By using their website: https:ico.org.uk/for-organisations/report-a-breach
version 1.1 22/02/2023
2.1 The client agrees to provide Impact Specialist Finance Limited (impact sf) with full and frank details about their personal, financial and other circumstances including knowledge and experience, risk appetite, ability to tolerate losses, capacity to accept losses and the client’s aims and objectives in respect of any financial needs. The client has the legal capacity to enter into this agreement.
2.2 impact sf confirms that it has the necessary delegated regulatory permissions to provide advice and services in those areas disclosed in impact sf’s About Our Services and Fees document.
2.3 The client agrees to appoint impact sf as their agent.
2.4 impact sf agrees to act as the agent for the client in relation to the services agreed at clause 3 below.
2.5 Unless otherwise confirmed in writing, impact sf agrees to treat the client as a Retail Client.
3.1 impact sf agrees to conduct an analysis of the personal information provided by the client at the time of entering into the agreement and determine, based upon this information, that all existing arrangements held in the name of the client are still suitable and, in the client’s, best interest or not, and report to the client details of this analysis.
3.2 impact sf will provide advice having assessed the clients demands and needs (in respect of Mortgages and non-investment protection) and conduct a holistic analysis of the client’s mortgage and non-investment protection plans that fall within the regulated permission of impact sf, and make personal recommendations in these areas.
3.3 impact sf will use the information provided by the client and cannot be held responsible for any non-disclosed details that may subsequently effect the application or lender decision where it would be reasonably expected for the client to make impact sf aware of such information.
3.4 The lender's decision is always final and is based upon receipt of a completed application form or Decision in Principle form and supporting documents.
3.5 impact sf recommends that clients should not instruct solicitors and incur costs until case has been fully agreed by the lender in question.
4.1 A processing fee (including valuation fee) will be required with the mortgage application. Our actual fees are available in PDF format on request.
4.2 Payments for services will be made to In Partnership or impact sf and not to a named individual.
7.1 impact sf are an appointed representative of In Partnership which is authorised and regulated by the Financial Conduct Authority. In Partnership’s Financial Conduct Authority registration number is 192638.
The address of the Financial Conduct Authority is:
12 Endeavor Square,
London,
E20 1JN
7.2 In Partnership’s permitted business is advising, arranging (bringing about) transactions in home purchase plans, home reversion plans, investments, P2P agreements, pension transfers, pension opt outs, regulated mortgages, consumer buy to lets, business buy to lets and non-investment insurances.
7.3 9.You can check this on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/register or by contacting the FCA on 0800 111 6768.
8.1 impact sf will always act honestly, fairly and professionally when conducting business with you.
8.2 impact sf will make you aware of the existence of any conflict of interest that we are aware of, which arises between the work we are doing for you and any of our other clients or ourselves, and obtain your consent to continue before we carry out your instructions.
8.3 impact sf will take all reasonable steps to prevent conflicts of interest and to ensure your fair treatment where one does arise. A copy of our conflict of interest policy is available upon request.
9.1 impact sf meets the requirements of the FCA rules regarding financial resources, including provisions regarding holding and maintaining appropriate professional indemnity insurance.
9.2 We are also covered by the Financial Services Compensation Scheme (FSCS). You may be entitled to compensation from the scheme if we cannot meet our obligations. The value of this compensation depends on the type of business and the circumstances of the claim, as follows:
Insurance - Insurance advising and arranging is
covered for 90% of the claim without any upper limit. For compulsory
classes of insurance, insurance advising and arranging is covered for
100% of the claim, without any upper limit.
Home Finance Products - Mortgages, Home Purchase Plans and Equity Release advising and arranging is covered up to a maximum limit of £50,000.
9.3 Further information about compensation scheme arrangements is available from the FSCS.
11.1. Some or all of the information supplied to impact sf in connection with an Enquiry, Decision in Principal or Application will be held on computer and paper and will comprise Personal Data (as defined by the DPA / GDPR). Unless required to do so by law, we will not disclose such information to anyone else other than the lender and their third parties to assist in the provision and servicing of your application.
11.2. Please note that telephone calls may be recorded or monitored for security or training purposes.
11.3 We will only contact you for Marketing purposes as mentioned in 6.1.
13.1 If you wish to register a complaint please contact us, or alternatively you may contact:
In Writing:
The Compliance Department,
In Partnership
On-Line House, 50-56 North Stret,
Horsham,
West Sussex,
RH12 1ED
By Phone:
01403 241 200
By email:
complaints@inpartnership.net
Further details of how we handle complaints are available on request. (For information on our customer complaint handling process, Click here.)
13.2 If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service. Their contact details are:
In Writing:
The Financial Obudsmen Services,
Exhange Tower,
London,
E14 9SR
By Phone:
0800 023 4567
In Writing:
Impact Specialist Finance
20 Barttelot Road
Horsham
West Sussex
RH12 1DQ
By Phone:
01403 272625
By email:
info@impactsf.co.uk
v1 01/04/2018