For details of our firm and how to contact us please refer to our website footer.

Why should you read this document?

During the course of dealing with us, we will ask you to provide us with detailed personal information
relating to your existing circumstances, your financial situation and, in some cases, your health and family
health history (Your Personal Data). This document is important as it allows us to explain to you what we
will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.

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 or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your 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 financial affairs, 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), employment history
  • Bank account 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 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 financial affairs, we do so on the basis that both parties are entering 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 to 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, 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, your health and medical history (Your Special Data). We will record and use Your Special Data in
order to make enquiries of providers in relation to insurance products that may meet your needs and to
provide you with advice/guidance 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, to 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. We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category 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 with you to
establish your circumstances and needs and preferences in relation to your financial affairs. You will provide information to us verbally and in writing, including email. 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 voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

Marketing

We may use personal data that we hold about you to help us identify, tailor and provide you with details of products and services from us or third parties that may be of interest to you in accordance with your preferences.

You can opt-out of receiving marketing material, or you can change your marketing preferences at any time by emailing your instructions to: dataprotection@corbelpartners.co.uk You can also opt-out of marketing by clicking the ‘Unsubscribe’ link at the bottom of any marketing email.

International Data Transfers

The transfer of personal data to countries which are located outside the European Economic Area is generally prohibited unless:

  • the jurisdiction in which the recipient is located is deemed to provide an adequate level of data protection;
  • the data exporter puts in place appropriate safeguards; or
  • a derogation or exemption

Your Rights

You have legal rights under data protection regulation in relation to your personal data as follows:

  • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
  • In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below;
  • You have the right to opt-out of marketing communications that we send you at any time. You can exercise this right by clicking on the “Unsubscribe” or “Opt-out” link in the marketing e-mails we send To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below;
  • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent;
  • You have the right to complain to the Information Commissioners Office about our collection and use of your personal For more information, please see below under the heading ‘Our Supervisory Authority’.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

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 our paper files, mobile devices and on our computer systems for
    example websites, email, hard drives, and cloud facilities. This information can only be accessed by
    employees and consultants within our Firm and only when it is necessary to provide our service to you
    and to perform any administration tasks associated with or incidental to that service.
  • Submit Your Personal Data to Product Providers and Lenders both in paper form and on-line via a
    secure portal. 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 your
    financial affairs, or to inform you of any developments in relation to those products and/or polices of
    which we might become aware.

Sharing Your Personal Data

From time to time Your Personal Data will be shared with:

  • Product Providers / Lenders
  • 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 will include but may not be limited to, our Compliance Advisers, Product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors and valuers (in each case where we believe this to be required due to your particular circumstances).

In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice,
i.e. to progress your enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

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 either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.

Your rights in relation to Your Personal Data

You can:

  • 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 or 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)

Our Supervisory Authority

If you are not happy with the way we collect and use your personal information, you have a right to lodge a complaint with the Information Commissioners Office (ICO). It has enforcement powers and can investigate compliance with data protection regulation.

Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: 0303 123 1113. Fax: 01625 524510. Website: www.ico.org.uk

We ask that you please attempt to resolve any issues with us before referring the matter to the ICO

How to Contact Us

If you are not satisfied with the level of information provided, or you would like to exercise any of the above rights or make a complaint, please email:

  • The Data Protection Officer at dataprotection@corbelpartners.co.uk or write to: The Data Protection Officer 750 Mandarin Court, Warrington, WA1 1GG, with enough information to identify you, g. name, telephone number, email address.

Please also provide proof of your identity and address and explain the information to which your request relates.