- About Us
Responsible Life Ltd is committed to protecting the privacy and confidentiality of all individuals and takes its responsibilities regarding the security of data very seriously. We abide by the rules of the General Data Protection Regulation (GDPR), which is applicable from 25 May 2018 and upheld by the Information Commissioner Officer (ICO). We are authorised and regulated by the Financial Conduct Authority (FCA) to advise and arrange regulated Lifetime Mortgages, Mortgages and Non-Investment Insurance contracts. This includes processing any personal data lawfully, fairly and in a transparent manner.
- What information do we collect about you and why?
We will only collect information from you so that we can advise and arrange regulated Lifetime Mortgages, Mortgages and Non-Investment Insurance contracts that maybe suitable for you. In the financial services industry we call this factfinding which provides us with all the information we need from you in order to provide you a with suitable product that meets your circumstances and requirements.
When obtaining information from you we will do this by phone, email or post and will confirm the accuracy of the data collated. It is important that all the data we hold on you is accurate so that we can advise and arrange suitable products to you.
The types of information we will collect from you includes; contact details, occupation, income and expenditure, credit details, mortgage requirements, existing financial products, solicitors/accountant details and bank details. In addition, we may collect sensitive personal data such as medical conditions or criminal offence data where required to do so to advise and arrange a product on your behalf.
- Contact details received from a third-party Introducer or Lead Generator
Occasionally we may receive your contact details from a third party who you have expressed an interest to in relation to the products and services we have to offer. Where we use introducers or lead generators we will request from them that they have obtained your consent and have made it clear to you that they will pass your details on to a firm such as ours and that you will be expecting us to contact you.
- Information from other sources
We may obtain information from other sources such as public records, if required. This is to enable us to verify who you are or facts that you have told us are accurate.
- How will we use this information?
We will only use your data in ways that you would reasonably expect us to. Below summarises how we will use your data.
We will use the information you provide to us to research the market on your behalf to find a suitable product that meets your circumstances and needs. Once we have carried out research we will provide you with a personalised Key Facts Illustration/Offer detailing the product information. Whilst you consider the Key Facts Illustration/Offer we will remain in touch to answer any questions you may have.
If you are happy to proceed we will then use your data to complete an application form which will be forwarded to the relevant lender. We will then liaise with them on your behalf until the Lifetime Mortgage, Mortgage and Non-Investment Insurance contracts have been arranged.
We will also use your data to assist with handling a complaint if you are not happy with the service you have received.
In the interests of improving our services, telephone calls may be monitored and/or recorded for training purposes and to assist us with handling a complaint. Where we record the call, you will be informed of this.
- The lawful basis on which we use this information
How we use your information (detailed above) we will do so using the lawful basis legitimate interests. We have decided upon this basis as it allows us to meet with the ICO and FCA rules and is the most suitable lawful basis for processing data with a view to arranging a Lifetime Mortgage, Mortgage and Non-Investment Insurance contracts.
- Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
- Who will it be shared with?
As stated above, if you wish to proceed to take out a Lifetime Mortgage, Mortgage and Non-Investment Insurance contracts then we will pass your details on to the product provider with whom the product is to be arranged. The information we pass on will be detailed within the application we complete on your behalf. We may also liaise with your solicitor and the lenders valuer’s to arrange a valuation on their behalf.
Where required we may forward your details onto regulatory authorities or fraud agencies where we have a legal obligation to do so to comply with our regulatory requirements or where fraud is suspected. We may do this under the lawful basis legal obligation.
- What we will do to ensure the security of personal information
We will not share any of the information you provide to third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us regardless of whether the information is in electronic or physical format. We use leading technologies and security measures to safeguard your information and keep strict security standards to prevent any unauthorised access to it.
- How long will we retain your data?
We will only hold data for no longer than is necessary. We will keep your file including your personal data and any call recordings, on record for a minimum of six years, in line with our regulatory obligation with the FCA.
- What are your rights?
You have the right to:
- Be informed about how we use, share and store your personal information;
- Request access to the personal data we hold on you (also known as a Subject Access Request (SAR)). Where a SAR is requested we will respond promptly and within one month from the date we receive the request;
- Request your personal data is amended if inaccurate or incomplete;
- Request your personal data is erased where there is no compelling reason for its continued processing and we don’t have a legitimate interest to retain it;
- Request that the processing of your data is restricted;
- The right to object to your personal data being processed;
- Rights in relation to automated decision making and profiling.
Where the processing of your data is based on your consent, you have the right to withdraw this consent at any time by contacting our Data Protection Officer using the contact details in Section 16. We do not use automated decision making or profiling systems.
Where we need your consent, we will ask for this separately. Your consent must be freely given by positively opting in or making a clear affirmative action that you are giving your consent. We will do our very best to ensure you know exactly what you are consenting to and remind you that you may withdraw your consent at anytime by contacting us, please see Section 16 for contact details. Where consent is obtained a record of this will be made confirming what you have consented to, the time and date, and how consent was obtained.
We will only send you information about regulated products or services if we have obtained your consent to do so.
- Website Banner Marketing
If you visit our website, you may receive personalised banner advertisements whilst browsing other websites including but not limited to search engines and social networking. Any banner advertisement you will see will relate to products you have viewed whilst browsing our website on your computer or other devices.
These advertisements are provided by Responsible Life Ltd using ‘Cookies’ placed on your computer or other device. You can remove or disable cookies at any time – see our cookies notice for more information.
You may receive advertising based on information about you that we have provided to the social media platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it receives from us.
- Right to complain
We hope that the service you receive from us is to the high standard you would expect. If at any point you are unhappy with the way we have used your data then please notify our Data Protection Officer using the contact details in Section 15. Alternatively, if you are concerned about the way in which we collect or use your personal data, you can raise your concern with the Information Commissions Office (ICO) on 0303 123 1113. For further details you may visit the ICO website www.ico.org.uk.
We will tend to disclose the complainants’ identity to whoever the complaint is about, however if you wish your identity to remain anonymous, we will try to respect that. We will keep your complaint on record for two years once closed or six years if it also relates to how we arranged a product and falls under the FCA ruling.
- Changes to the information
We regularly review and where necessary update our Privacy Notice. If we decide to change our Privacy Notice, we will post those changes on https://www.responsiblelife.co.uk/privacy-policy. Please check the website regularly for any changes to this Privacy Notice. If we plan to use personal data for a new purpose our Privacy Notice will be updated, and you will be notified.
- Contacting Us
If there are any questions regarding this Privacy Notice you may contact us using the information below.
Or in writing to:
The Data Protection Officer
Responsible Life Ltd
Units 11-21, Mills Bakery
Royal William Yard
The previous Privacy Notice was dated 07/02/2017. This Privacy Notice was last updated on 03/05/2018.