Privacy Policy


1. What information we collect and how we use it

This section summarises what information we collect from you when you contact us, what information we collect from elsewhere, and how this information is used.

Mortgage Customers

One of our core businesses 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 Credit Reference 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.

Insurance Customers

We routinely offer our customers life insurance, critical illness as well as building and contents insurance. Where customers express an interest in life or critical 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 this is appropriate to meet the obligations placed on us by the Financial Conduct Authority (FCA) with regard to vulnerable customers. You can find out more about our obligations to potentially vulnerable customers here:

Financial Conduct Authority

2. 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.

We are working with partner services such as Experian to enable us to pre-populate our on-line data collection forms with information about you that is available from accessible sources. This means there is less information for you to type in. But you have control and can change any answer.

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.

Telephone calls

We may record incoming and outgoing calls so that we can be sure that we have captured the information you have given us accurately. This helps us to prevent fraud and resolve any disputes.

3. Profiling, Marketing and Market Research

We may use your information to contact you about other products that match your profile and may be of interest 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.

Quite separately, if you have taken out either a mortgage or an insurance product through us we will contact you when your product is coming to an end to ensure that you are protected and can access the best rates on a new deal. If you do not want us to do this you can ask us at any time to mark your records 'do not contact'.

4. Money Laundering and preventing and detecting unlawful acts

We are required by law to submit a Suspicious Activity Report to the National 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 so by 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, tracking emails, re-marketing and analytics

We use services such as Google Analytics to track how visitors use our website, to understand trends and how the business works and so that we can improve the user experience. But the reports we produce do not identify individuals. The Cookies Section of this Privacy Notice explains what cookies we use and how you can turn off and control any advertising cookies (subject to your browser functionality).

We use email tracking technology to capture information such as (but not limited to) the time and date our emails are opened, the type of device used and any links within the email clicked on. We may share this information with the organisations listed in Section 5 (for example, mortgage lenders) for the same purposes, but stipulate that they may not use your details for direct marketing unless they have your consent or an existing relationship with you and you have not previously opted out.

We also use telephone tracking technology to capture information such as (but not limited to) the time and date a call is made, the type of device used and the source and page on our website that a customer called from.

5. Social Media

As a business we monitor what the public are saying about us on social media such as Facebook, Instagram and Twitter, so that we can build these comments into improving our products and the ways we interact with customers.

6. 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.

7. 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 your 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.

If you are referred to us by an Estate Agent our data collection form includes a free form data field that some Estate Agents use to add comments about potential purchases.

Ancillary

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.

8. 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.

Legitimate Interests

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 not outweighed 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.

Consent

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 LIFELINE. (We also market to customers who have enquired to use our services under the legitimate interests condition) or
  • • 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

Explicit Consent

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
  • • Incidental data supplied by applicants as proof of income that may reveal special category data such as trade union membership

Complying with a legal obligation

  • • Money Laundering reports

Public Interests 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

Substantial Public Interest

  • • 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

Contract

  • • Processing personal data in connection with contracts that we hold with contractors, suppliers and staff.*

9. Who we share your personal information with

To fulfil our contractual obligations, we'll also share your personal data with third parties such as lenders, insurance providers, credit reference agencies.

If you no longer wish us to share your data with any of these organisations, you may withdraw your consent at any time.

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.

10. Your 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 Information Commissioner (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 automated decision

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 DECISION MAKING

This right only applies where a decision which has a legal or similar effect is 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. However, LIFELINE 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 LIFELINE’s use of your personal information infringes the law. Section 1 provides the contact details.

However, LIFELINE 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 Protection Officer 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 lender/insurer concerned, as well as giving you their contact details.

11. How we keep your personal information secure

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

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.

12. How long do we keep your personal information for

To ensure that we are able to meet our legal, regulatory and customer obligations, LIFELINE 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 retain a full record of your interactions with us 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 the term of the product applied for plus an extra 6 years.

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 the 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 through 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 180-days from the time we de-activate your lead in our database, to ensure we can fulfil our contractual obligations to our lead partners.

Where our retention schedules indicate a record is otherwise no longer required but you are subscribed to marketing, we delete the record of events and attachments associated with the case but maintain the case record itself so that we know what messages are relevant to you.

We anonymise data against these retention periods on a programmed basis. A back-up copy of the data is retained for a set period to enable the anonymisation process to be validated.

13. Use of Cookies

Why do we use cookies and what do they do?

A cookie is a small piece of data (text file) that a website asks your browser to store on your device in order to remember information about you when you visit the site; such as your language preference or login information. As an example, when you visit the LIFELINE website, we record the time you signed in and assign you a unique ID number that is stored in an encrypted cookie on your hard disk.

The most important cookies are categorised as ‘essential cookies’, which allow our website to work properly and help keep it secure. We also use additional ‘non-essential’ cookies to help us understand how people use the website, make the site easier to use by remembering information that you've entered, improve your experience by showing you information that's relevant to you, and assist us with our marketing.

Essential cookies are always turned on, but we will always obtain your consent for all non-essential cookies. The granularity of this consent can be managed anytime through a dashboard on our website. To access this simply click on the ‘Shield’ icon. Please note though that if you choose to disable certain categories of non-essential cookies, this may impact your experience as our site may no longer work as we intended it to.

In most cases cookies have a limited lifespan and will automatically be deleted after a set period of time, session cookies are used to store data on our server that is individual to you and when you log out, these session cookies will be deleted from your computer (see our cookie tables for more information on the lifespan of our cookies). If you do not wish to wait for them to expire, you can manually remove them from your device (see below for further information on how to clear old cookies from your device.

We use first-party cookies (that are set by us) and also third-party cookies (cookies not placed by LIFELINE). If you want to understand more about the cookies we use, then please read on.

Performance Cookies

Performance cookies are placed on your hard disk by our websites or by third parties who provide specialist information to us.

For instance, when people access our websites or apps we use our own technology, and technology supplied to us by partner companies, to collect and analyse information about how our websites are being used. We need to use cookies or similar technologies to do this.

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Marketing Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They are based on uniquely identifying your browser and internet device. These cookies help make sure the adverts you see on your screen are relevant and useful to you.

Some of our marketing cookies are placed on your hard disk by our websites, and others are placed by third parties, including advertisers. For example, we use call tracks to find out where on our site calls were made from.

We use Third Party cookies to manage the content and advertising shown on devices that you might use or that may relate to the same household more relevant and useful. These third parties may also provide insight reporting as part of their service. As part of this process they use cookies and may receive information about the kind of device you use as well as your IP address, location data, device user agent string or information about websites where your device has previously displayed advertising. By accepting marketing cookies, you consent to the processing of data about you by these third parties for the above purpose and for the profiling of audiences bearing similarities to your data.

Essential Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Clearing old cookies from your computer

There are a number of different reasons why you may want to clear your browser’s cookies.

For example, if you have changed your mind about which types of cookies you are willing to accept and have changed your settings in our preference centre, though your new preferences will be respected as you continue to browse our website, this does not automatically remove all pre-existing cookies that have already been saved to your device.

Whether for privacy reasons or general computer maintenance and clean up, most browsers make clearing your cookies a fairly easy task.

Note: Before performing the below actions, please bear in mind that clearing cookies from your computer may mean a reduction in usability or even functionality (such as embedded video files) for certain pages of our website.

Please note the following are generic instructions which should enable you to find the required options in most common browsers (if you need more specific instructions for your particular browser you should be able to find these using a standard internet search):

1. Open your browser
2. Locate and open the More/Settings Menu (often found top right as a 'cog' or '...' icon or similar)
3. Locate the browsers Privacy/Security tool
4. Follow the instructions on the screen to clear cookies/browsing data (if there are multiple options listed only select the option that mentions cookies unless you also wish to clear other types of stored data as well)



Your Property will be repossessed if you do not keep up with your mortgage payments