1. About Town and Country (T&C) and how you can contact us
Town & Country Mortgage Services Limited (T&C) Our registered address 260 – 270 Butterfield, Great Marlings, Luton, Beds, LU2 8DL. Company registration number 4486778. Registered in England & Wales. You can find out more about us on our website at https://www.tandcmortgages.co.uk/
You can also obtain information and advice from the InformationCommissioner who is the independent regulator appointed by Parliament to oversee compliance with data protection and information rights: www.ico.org.uk
You can contact us:
(a) By post to the postal address given above; (b) Using our website contact form;
(c) By telephone on 01582 421320 or
(d) By email using firstname.lastname@example.org
T&C is registered with the Information Commissioner (registration number Z8360037).
2.What information we collect and how we use it
Information we collect directly
Our core business is acting as a mortgage broker. This involves searching against the lenders we deal with to find the mortgage that best suits your circumstances.We do this when you call us by asking you about your identity and contact details; your product preferences; your property and tenancy history and types and number of occupants and their relationship to you; your lifestyle; nationality and residence status;employment income and expenditure and other financial circumstances. How you answer these questions will determine what other questions we ask you because different lenders serve different parts of the market and have different eligibility criteria. We will always explain the process to you and answer any questions you may have about why certain types of information may be needed.
When you apply for a mortgage through us we will collect your direct debit details to pass on to your lender. If the products you select involve a cost such as a valuation fee, we will ask for your payment information.
Mortgage lenders are data controllers in their own right and have their own privacy notices. However because lenders may automatically profile your information against their lending criteria and against CreditReference Agencies as soon as your information is forwarded to them and this may affect your credit score we will always bring this to your attention as part of the process so that you are forewarned. We will also make you aware in advance when lenders are likely to debit any funds from your accounts.
We routinely offer our mortgage customers life insurance and building and contents insurance. Where customers express an interest in life insurance we will also collect information about health as this is necessary so that the insurers we deal with can determine cover and premiums.
Apart from the information customers provide to us directly we may also record information about potential vulnerabilities where we think thesis appropriate to meet the obligations placed on us by the FinancialConduct Authority (FCA) with regard to vulnerable customers. You can find out more about our obligations to potentially vulnerable customers here: https://www.fca.org.uk/publications/occasional-papers/occasional-paper-no-8-consumer-vulnerability
Updating Your Details
If you are a pre-existing customer we may use the information we have on you to pre-fill forms when you apply for a new product but we will always check that these details are accurate and up to date.
However if you’ve opened an account or policy with another organisation that we introduced you to you will need to contact them separately to update your information.
Marketing and Market Research
We may use your information to contact you about other products that match your profile and may be of interest to you. Where we seek consent to do this we make sure we are clear about what methods we can use to contact you. We make sure that you are able to opt out of marketing communications at any time in a way that is convenient to you,including the method you used to contact us. Where we use online advertising platforms the data you supply to us will be matched by them to any profile they have of you.
We may contact you to conduct market research. We occasionally run promotions, competitions and prize draws but if we ask you for your contact details we will ensure these are not used for marketing unless you are happy to consent to that separately.
Money Laundering and preventing and detecting unlawful acts
We are required by law to submit a Suspicious Activity Report to theNational Crime Agency whenever we detect a risk of money laundering or fraudulent activity. The law also permits us to report suspected crime to the appropriate authorities.
We are also required to disclose personal data where required to do soby law or by the order of a court.
We have discretion to disclose personal data where this is necessary for protecting the public against dishonesty.
Cookies on our website and tracking emails re-marketing and analytics
Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However some features or services on our sites may not function properly without cookies.
Cookies used by our service providers
As a business we monitor what the public are saying about us on social media such as Facebook and Twitter so that we can build these comments into improving our products and the ways we interact with customers.
Training and Testing
We do not use customer data for generalised training or system testing separate from case management and always use dummy data sets for these purposes.
Information that we collect indirectly
When any of our customers apply for a product the law requires us to check their identity. This makes it harder for criminals to use financial systems or to use false names and addresses to steal the identities of innocent people. Checking everyone’s identity is an important way of fighting money laundering and other criminal activities.
To confirm that you are who you say you are we’ll try to verify your name and address by checking your details against databases held by credit reference agencies and the electoral roll. If we can’t verify your name and address in this way we may ask you to provide us with other documents to confirm these details. This does not affect you credit history or status.
If you are a joint mortgage applicant we will record any information you give us about any other persons who are joined to the application.
We use the information we have about you to provide all the aspects of our service you would expect such as contacting you to prompt you with reminders about renewals and to help resolve any complaints or investigations.
We may also disclose information where permitted by law in connection with the resolution and pursuit of legal rights and disputes or complaints.
Automated Decision Making
We do not make fully automated decisions. Our service is to provide the information to lenders and insures so they can make a decision about the product you have selected.
If you give us a good review we may contact you to ask you if you would like to publicise your review.
3. What are the legal grounds for handling personal information?
The law says we must have a legal basis for processing personal data.There are six standard data processing grounds or conditions for processing personal data Where we process what is called ‘special category data’ (information about health genetic or biometric data etc) we must additionally have a special category condition or ground for processing your personal data.
We rely on the following conditions for the activities indicated.
In most cases you’ll provide the information covered in section 2 because you want to use our services. Ordinarily for a business this would mean that the condition for processing is contractual. However,this condition only applies where a legal contract exists between the parties concerned. Because we act as an intermediary this condition is not available. We therefore rely on what is called the ‘legitimate interests’ ground for processing. The law provides we can use your information under this condition where our interest in using it is no out weighed by your privacy rights or interests. This means that we can use your personal data only in ways you would reasonably expect and which have a minimal impact on your privacy or where there is a compelling justification for the processing.
We rely on this condition for the uses we identify in section 2 except where we indicate below that another condition is more relevant.
In the case of mortgage and insurance applicants the legitimate interest condition applies because you have requested the service in question and can withdraw at any time. We also rely on this condition to process any details joint mortgage applicants give us about the other applicants. When we write to the first applicant we provide a link to this Privacy Notice and draw to their attention what they need to say to joint applicants. Applicants should be aware that lenders will not proceed with any mortgage without the written consent of any occupant of the current property who is aged over 17.
Increasingly we base our marketing and market research on consent but where we rely on legitimate interests we think this is fair because we only contact existing customers or people who have contacted us directly and each communication provides an easy to use opt out. We think it is fair to use social media in the way we describe in section 2 because this is publicly available information and we do not use the data to profile or make decisions about individuals. Our interest is in what is said about us not who is saying it.
In order to use your personal data on this basis your consent must be freely given specific informed and unambiguous. We rely on this condition for the following purposes:
- Where we need information to provide you with additional services or features
- Direct Marketing – To let you know about products services and offers from T&C. (We also market to customers who have enquired to use our services under the legitimate interest’s condition)
- Market research – Where we invite you to participate in market research. Any feedback you provide is used only with your consent.
- Administering prize draws, competitions, surveys and other promotional activities.
We need what is called explicit consent where we rely on consent to process what is called sensitive or special category personal data.
- Health data in connection with life policies
Complying with a legal obligation
- Money Laundering reports
Public Interests & Substantial Public Interest Tasks
- Processing health data in connection with vulnerable customers
- Reporting fraud and other suspected crimes to the appropriate authorities.
- Suspicion of terrorist financing or money laundering
- Protecting the public against dishonesty
- Insurance and data concerning the health of relatives of an insured person
4. Who we share your personal information with
To fulfill our contractual obligations we’ll also share your personal data with the following third parties:
- Mortgage lenders
- Mortgage Intelligence Holdings
- Life insurers
- Payment shield for building and contents insurance
- Estate agents (if you were introduced to us by one of our estate agent partners)
- Lead suppliers (if you were introduced to us by a third party) such as a builder or developer or housing association
- Call Credit for identity checking
- Our personally recommended conveyancers where you wish to proceed with a quote.
- Experian to audit our data accuracy
To help you benefit from the services of our expert partners we’ll also share your personal data with the following organisations – but only with your consent:
- Positive Lending
If you no longer wish us to share your data with any of these organisations you may withdraw your consent at any time.
Both the above sets of organisations are each data controllers in their own right and will have their own Privacy Notices that will tell you about how your personal data will be used by them.
We’ll also share your personal data with the following data processors where necessary to fulfill our services and regulatory obligations:
- IRESS to provide life insurance quotations
- IRESS to provide mortgage illustrations
- MBL to provide mortgage illustrations
- Sommers Waste Solutions to destroy our confidential waste
- KP waste Ltd Confidential Shredding to destroy our confidential waste
- Silvertoad and Host my Office to provide our web services
- CI Expert for Critical Illness cover comparisons
- reviews.co.uk for customer reviews
- Trust Pilot for customer reviews
Sharing information with these organisations allows us to better understand your needs.
- Online Advertising Platforms such as Facebook and Google (please seethe part in Section 2 on Marketing and Market Research.
We may disclose information to either the Financial Service Ombudsman or the Financial Conduct Authority where they request this to resolve complaints or our auditors in connection with their duties.
5. Where in the world do we send information?
As a UK based company all the personal information we process is protected by European data protection standards.
The only personal data that is transferred outside the EEA is that processed through Survey Monkey Europe UC who have agreed standard contractual terms to protect transfers to Survey Monkey Inc which is located in the United States. Survey Monkey Inc participates and has certified its compliance with the EU-US Privacy Shield.
6. Your Information Rights
The following is a list of the rights you have under Data Protection legislation. Not all these rights apply in all circumstances but we will be happy to explain this to you at the time you ask. Independent advice about your rights can be obtained from the InformationCommissioner (see Section 1.)
All these rights can usually be exercised free of charge and generally speaking we must respond within one month. If we need longer to respond we will explain why this is necessary within the one month period and tell you more about any rules that affect how you can exercise your rights.
INFORMED – You have the right to be informed in a concise, transparent intelligible and easily accessible way about how we use your personal information. We will explain why we need information (in particular any uses that are not obvious) at the time we collect information from you and make sure that all our data collection forms and letters point you to this Privacy Notice.
ACCESS – You can make what is called a subject access request for a copy of the information we hold about you.
We must also tell you why we have the information what types of information we collect; who we share it with and whether in particular any of those recipients are outside the European Economic Area; how long we will keep your information for; where the information came from if we didn’t collect it from you directly; the details of any automatic decision taking and about your rights of complaint to the Information Commissioner.
PORTABILITY – You have the right in some circumstances to have the data you have provided to us sent to you or provided to another person or business in an electronic machine-readable format. Where this applies we will download the information and send it as a CSV file.
CORRECTION – You have the right to have inaccurate information corrected and incomplete information completed. If the information we need to deliver our services to you changes please tell us about this as soon as possible.
OBJECT – You will normally have the right to object to how we intend to use your information based on your individual circumstances. You have an absolute right to object to us using your personal information for the purpose of direct marketing at any time
RESTRICTION – If you have objected or complained about how we have used your information or its accuracy you may not want it to be deleted until your complaint has been resolved. In certain circumstances you can ask for your data to be restricted or not used until these issues are resolved.
ERASURE – You have a right to have some or all of the information we hold about you erased in some circumstances. This is known as the right to be forgotten.
AUTOMATED – This right only applies where a decision which has a legal or similar effect is DECISION MAKING taken about a person by automated means without any human intervention. Where such decisions are made individuals have a right to ask for the decision to be reviewed and the data controller must make sure appropriate safeguards are in place. HoweverT&C does not make automated decisions about any of its clients.
CONSENT – If we are processing your personal information on the basis of your consent you have the right to withdraw that consent at any time.
COMPLAINT – You have a right of complaint to the Information Commissioner (the Supervisory Authority) if you consider any aspect of T&C’s use of your personal information infringes the law. Section 1 provides the contact details.
HoweverT&C will want to put matters right wherever we can and we would hope that you will contact us in the first instance. You can exercise your data protection rights or complain about how we are processing your personal information by contacting the Data ProtectionOfficer as set out in Section 1.
If your complaint is about the administration or terms and conditions of a product sold by us but provided by a lender/insurer you may need to contact them about it. If needed we’ll forward details of your complaint to the insurer concerned as well as giving you their contact details.
To help make sure you always speak to the right person about your complaint if it looks like another company will be better able to handle your case we’ll let you know how to contact them. We’ll also send details of your complaint to them to get them up to speed.
7. How we keep your personal information secure
At T&C we understand how important it is to keep your personal information secure. We use a variety of technologies and procedures to protect your personal information from accidental or unlawful breaches of security. These include physical organisational and technological measures.
All information we process is encrypted in transit so that your personal and financial information is secure. For example where you share information with us online or we forward this to other organisations online we use HTTPS.
As covered in section 4 we have to share your information with third parties to carry out some of our services including lenders and insurers amongst others. We require every third party that we share information with to apply appropriate security safeguards and comply with all the required laws and standards for protecting personal information.
8. How long do we keep your personal
We only keep your personal information for as long as we need to. This section explains how long the different types of records will be kept.
To ensure that we are able to meet our legal regulatory and customerobligationsT&C will retain client information for the following time periods:
• If you become a client of a lender/insurer as a result of the advice we provide to you we will keep a full record of your interactions with us for your lifetime plus a reasonable period to enable us to meet our regulatory obligations to evidence we gave suitable advice and to enable us to answer any complaints that may arise as a result of our
advice. In practice this means that we will keep your records for no longer than 100 years after you last transact with us
- If as a result of our advice you make an application to a lender/insurer but do not ultimately become a client of that institution, we will keep a full record of your interactions with us for 6-years to meet our obligations under UK Money Laundering regulations.
- If we provide you with advice on a financial product but you do not engage our services to make an application to a lender/insurer we will keep a full record of your interactions with us for 3-years to enable us to meet our regulatory record keeping obligations regarding evidencing suitability of our advice.
- If we collect personal information from you but are unable to provide you with suitable advice then we will keep a full record of your interactions with us for 1-year to facilitate an easier interaction between us if you re-engage our services within this period.
- If you request we contact you in relation to our service by providing us with your name and a contact method (e.g. phone email) through an enquiry form (either on our own or a 3rd party website) we will use our best endeavours to contact you as soon as possible. If we are unable to make contact with you we will retain this information for a period of 90-days from the time we de-activate your lead in our database to ensure we can fulfill our contractual obligations to our lead partners.
9.Changes to this Privacy Notice
We will continuously refine this Privacy Notice to make sure we are complying with our obligations to be transparent about how we use your personal information and that it is as concise, transparent, intelligible and as easily accessible as it can be. However if we make any changes to how we process your personal information in ways that you would not reasonably expect we will contact you and bring these changes to your attention.