Privacy Policy

 

CUSTOMER PRIVACY NOTICE

At City Mortgages Club Ltd  we respect your privacy and the confidentiality of your personal information.

Who are we?

 

City Mortgages Club Ltd (FCA registration Number : 835127) is appointed representative of Rosemount Financial Solutions (IFA) LTD (FCA registration Number: 535515) who are  independent Financial Advising Business regulated by the Financial Conduct Authority.

 

This Privacy Notice explains: 

  • Who we are.
  • What personal information we collect.
  • How we use your personal information.
  • Who we share your information with and why.
  • How we keep your information secure.
  • Your rights.
  • How to contact us.

WHO WE ARE

City Mortgages Club  Ltd provides mortgage and protection advice through experienced and qualified advisers based in the UK.

City Mortgages Club  Ltd determines the purposes and means of processing personal client data relating to giving advice.  This means we are data controllers for these advice giving activities and therefore responsible for managing this client data and ensuring compliance. 

 

WHAT PERSONAL INFORMATION WE COLLECT

Personal information includes your name, address, phone number and other information that is not otherwise publicly available. We collect personal information about you when you contact us about products and services, visit a financial adviser, visit a one of our websites, or register to receive one of our newsletters (if applicable).

The type of personal information we collect will depend on the purpose for which it is collected and includes:

  • Contact details
  • Information to verify your identity
  • Family, lifestyle, health and financial information
  • Your thoughts and preferences regarding financial matters.
  • Payment details

We collect personal information directly from you.  For example, we ask for personal information at the start of our relationship and in subsequent communications in order to check your identity, and protect you from fraud. This is a legal requirement and is important to help safeguard you against potential crime.

SPECIAL CATEGORY INFORMATION

When providing advice, it is necessary to understand a client’s state of health.  This is essential for underwriting purposes when considering any type of life cover.   However, it is also necessary to understand any concerns a client may have about their own health when considering investment time frames, appropriate retirement dates, and what a client would like to happen in the event of their incapacity or death.

This more sensitive type of information is called Special Category Data, and this can include other sensitive lifestyle related information.

It is very important that we collect this type of data, to ensure that our advice is properly tailored to each customer, taking into account their thoughts, preferences and personal circumstances.  

We will need to obtain your consent during the advice process to gather this data and explain what information we require and why it is needed.  Sensitive personal information will always be processed and stored securely.  You can withdraw your consent at any time to us processing this data, however, this may mean that you can no longer advise from quite such an informed position.

DATA RETENTION

We keep your personal information only as long as is necessary for the purpose for which it was collected and to meet regulatory or legislative requirements.  Personal information will be securely disposed of when it is no longer required, in accordance with our Data Retention and Disposal Schedule.  A copy of this is available from the How to Contact Us address, below.

ON WHAT BASIS DO WE COLLECT DATA

The processing of your personal data is allowed under UK law.   The data required for the provision of advice, products and services is processed on the basis there is a contract with you to do so.  Any relevant marketing activity we undertake is done because as a firm we have a legitimate interest to do so.  However, you have rights, as listed below, which impact how we can use and process your data.

HOW WE USE YOUR PERSONAL INFORMATION

We process your information in order to support and maintain our contractual relationship with you and to comply with legal and regulatory requirements.  This includes the following:

  • Providing our advice and recommending products and services to you.
  • Carrying out the transactions you have requested.
  • Confirming and verifying your identity to abide with UK legislation.
  • Credit scoring and assessment, and credit management (where applicable).
  • Detecting and preventing fraud, crime, money laundering or other malpractice.

We also process your data for specific business purposes to enable us to give you the best products and services and the best and most secure experience. For example, we may process your information to send you marketing that is tailored to your specific interests.

Our business purposes include the following:

  • Enhancing, modifying, and personalising our services for the benefit of our customers
  • Providing communications which we think will be of interest to you
  • Market or customer satisfaction research or statistical analysis
  • Audit and record keeping purposes
  • Enhancing the security of our network and information systems
  • To comply with the record keeping rules laid down by our regulators.

You have the right to object to this processing if you wish, please see “YOUR RIGHTS” section below. Please bear in mind that if you object this may affect our ability to carry out the tasks above for your benefit.

We may also process your personal data as part of an acquisition or sale.  Should this happen, you will be notified about any change to processing or data controller arising as a result of this activity.

WHO WE SHARE YOUR INFORMATION WITH AND WHY

We share your information with trusted third parties who perform tasks for us and help us to provide the services you require these include:

  • Third parties to verify your identity, in line with money laundering rules and other requirements (this may involve carrying out checks with credit reference databases).
  • Product providers who need your details to set up a new account or product.
  • With the specialized IT providers we use to record and retrieve our customer information.
  • Other organisations, including regulatory bodies, the police and fraud prevention agencies, to prevent and detect fraud.
  • Third parties where required by law, court order or regulation.
  • Third parties as part of an acquisition or sale.

HOW WE KEEP YOUR INFORMATION SECURE

We are committed to ensuring the confidentiality of the personal information that we hold.  We continue to review our security controls and related policies and procedures to ensure that your personal information remains secure.

When we contract with third parties, we impose appropriate security, privacy and confidentiality obligations on them to ensure that personal information is kept secure.

If we work with third parties in countries outside the EU we ensure these are countries that the European Commission has confirmed have an adequate level of protection for personal information, or the organisation receiving the personal data has provided adequate safeguards. 

In limited circumstances data may be accessed outside of the EEA ie by employees when they travel.  In these circumstances we ensure there are appropriate information security measures in place to safeguard your information

City Mortgages Club  Ltd tries to be as open as it can be in terms of giving people access to their personal information.    This privacy notice was drafted with brevity and clarity in mind, therefore further information can be gathered by contacting us using the details below, or more information about your data protection rights can be found here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

MARKETING

You have the right to opt out of marketing information and tell us what your communication preferences are by contacting City Mortgages Club Ltd Services using the details provided at the end of this notice, or by using the opt out option below or on any email marketing. You may opt out at any time if you don’t want to receive any further communications of this nature.

INDIVIDUAL DATA RIGHTS AND REQUESTS

  • The right to be informed – You can request that we provide ‘fair processing information’, typically through this privacy notice.
  • The right of access – You may request a copy of the personal information we hold about you using the contact details found on the end of this privacy notice.
  • The right to rectification – The accuracy of your personal information is important to us. You have the right to ask us to update or correct your personal information.
  • The right to erasure – You may request the deletion or removal of personal data where there is no compelling reason for its continued processing.
  • The right to object – You may object to the processing of your data based on legitimate interests.
  • The right to restrict processing – You have a right to request we ‘block’ or suppress processing of your personal data
  • The right to data portability – You may request to obtain and reuse your data.
  • The right not to be subject to automated decision-making including profiling.

If you wish to correct, restrict, delete or make changes to your personal information, or any of the data subject rights listed above, please contact us.

HOW TO CONTACT US

If you have questions about this notice, need further information about our privacy practices, or wish to give or withdraw consent, exercise preferences or correct your personal information, please contact us using the following details. 

The Data Protection Officer
City Mortgages Club Ltd

48 Warwick Street, London, W1B 5AW      

Tel:0203 705 1821

 

HOW TO COMPLAIN

If you wish to raise a complaint about how we have handled your personal data, you can contact The Data Protection Officer who will investigate the matter.   If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to our regulator:

Information Governance department
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
0303 123 1113
www.ico.org.uk/concerns

If You Are Not Happy with Our Service

If you have a complaint about your Adviser or any financial advice you have received from your Adviser please contact us:

In writing to:

Complaints Officer
Rosemount Financial Solutions IFA Ltd
Rosemount House
2-4 Chequers Road
Basingstoke RG21 7PU
Email:  Complaints@rosemountfsIFA.co.uk
Tel: 01256 405460

We will be happy to provide you with a summary of the internal procedures for handling complaints, this is available without charge upon request.  If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service (e.g. if we arranged insurance or a regulated product).

The Financial Ombudsman Service can be contacted as follows: The Financial Ombudsman Service, Exchange Tower. London E14 9SR

Telephone: 0800 023 4567
Email: complaint.info@financial-ombudsman.org.uk     www.financial-ombudsman.org.uk

This is the current process. Should it change we will notify you the next time we meet by issuing you with an updated version of this document. If however, you want to have the updated version sooner you can request them at any time and I will provide you with the updated complaints process.

Our Regulator – The Financial Conduct Authority

We are authorised and regulated by the Financial Conduct Authority. Our registration number is 835127.  The permitted business of City Mortgages Club ltd is advising on and arranging mortgages, life assurance and general insurance.

You can check this on the FCA’s Register by visiting the FCA’s website www.FCA.org.uk/register or by contacting the FCA on 0300 500 8082.  The FCA address is: 12 Endeavour Square, London. E20 1JN

Client Classification Levels For Your Protection

The FCA has rules which affect the rights you have as a customer.  In our dealings with you we will be representing you as the customer, rather than acting on behalf of an insurer.   

We classify all our individual customers as ‘retail’ customers.   The range of financial products and investments we recommend are tailored to meet the needs of retail customers.   You will have rights under the Financial Ombudsman Service (FOS) and the Financial Services Compensation Scheme (FSCS).  These rights will apply to the provision of the advice we provide.

In most cases these rights will also apply to the products we recommend. However, there are some exemptions for specialist products such as Enterprise Investment Schemes and Venture Capital Trusts.   Your adviser will let you know if the product recommended will not have rights under the FOS or FSCS.

There are other classifications of customer that don’t have these rights. These are “professional” customers and “eligible counterparties”.  You have the right to be classified as a professional client. Should you feel you have the skills knowledge and experience to be a Professional client and don’t wish to have the same protection afforded to retail clients, please let me know and we will complete the forms necessary to reclassify you.

If you have any questions regarding your classification (e.g. if you are acting on behalf of a large company), please write to Compliance Department, Rosemount Financial Solutions IFA Ltd, 2-4 Chequers Road, Basingstoke, RG21 7PU.   Alternatively you can contact the Financial Ombudsman Service or the FSCS.

Client Money Peace of Mind

We do not handle Client Money.  We never handle cash and will only accept a cheque made out to us in settlement of our own Advice and Service fees.  Our preferred method of payment is via bank transfer.

Your Duty of Disclosure

Any financial advice we provide will be based on your personal financial circumstances and objectives. It is important that the information you give us is both accurate and a true reflection of your current circumstances.

It is your responsibility to provide complete and accurate information to a provider (a provider being for example, an organisation that provides insurance, or investment related plans).

It is important that all statements made on any proposal form, or on any additional documentation are full and accurate.  Please be aware that if you fail to disclose any relevant information, or any change of circumstances to a provider, then the terms of your desired plan may be invalidated (e.g. an insurance claim may not be paid).  We strongly recommend that the information you provide is checked thoroughly prior to submission.

Language

Unless agreed by us at outset all communication will be completed in English.  We will communicate in a manner that is convenient to you, this could include Face-to-Face meetings, Post, E-mail and by telephone. 

Overseas permissions

All advice will be conducted in the EEA. This means that both you and I could be in any EEA country including the UK at the time advice is given.

Timing of Reports

Mortgages : I will send you a Suitability Report setting out the reasons for my recommendation.  This will be provided before implementing any advice that I have recommended.  This will ensure that you will have sufficient time to read the report fully, and to discuss any points before proceeding.

Protection Advice: I will send you a Demands and Needs statement setting out the reasons for my recommendation, before the policy starts.  If I am advising you by telephone, and you need the policy to start on the same day, the Demands and Needs statement will be sent to you by the end of the next working day.

Declaration of Other Interests

Rosemount IFA has a number of arrangements with various product providers to facilitate adviser learning and enhance the outcomes for our customers.  Further details are available on request.

To ensure that customer interests are always put first, we operate a robust Conflict of Interest and Inducements Policy. If a potential conflict of interest does arise it will be actively managed, and we have arrangements in place to ensure that all our clients are treated fairly. If we feel that our interests’ conflict with yours, you will be contacted and we will obtain your consent to proceed.  Our conflict of interest policy is available on request.

 

Addressing Financial Crime

All transactions relating to the services provided by us are covered by The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. The FCA also requires that we have appropriate measures in place to prevent the furtherance of financial crime.

 

Our responsibilities include, but are not limited to, verifying the identity and address of our clients and any third-party making payments on their behalf. If required, you must supply proof of your identity in accordance of the above Regulations.  Identity verification checks may include electronic searches of the electoral roll and the use of credit reference agencies, which will result in a soft ‘foot-print’ on your credit records.   This foot-print is not visible to other financial service providers and does not affect your credit rating in anyway. In accordance with the Data Protection Act 2018 acceptance of these terms and conditions represents your permission for us to access this information.

 

The Financial Services Compensation Scheme (FSCS) Current limits

We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim. i.e. it differs for investments, insurance and bank accounts.

  • Insurance: Insurance advising and arranging is covered without any upper limit.  This is also the case for Pensions where fully regulated investment funds are used.
  • Investment: Most types of investment business are covered up to a limit of £50,000.
  • Deposits: Bank Type Deposits are covered up to a limit of £85,000 per institution.
  • Structured Deposits: Structured deposit advising and arranging is covered up to £85,000
  • General Insurance:  General insurance advising and arranging is covered up to 90% of the claim with no upper limit. Compulsory Insurance is covered without any upper limit.

Further information about compensation scheme arrangements is available from the FSCS.

 

The Law that we operate under

All of our agreements provided are governed and construed in accordance with the laws of England and Wales. In relation to any dispute, for your protection you agree to submit to the non-exclusive jurisdiction of the English courts.

 

The Data Protection Act 2018

The personal information you provide will assist your financial adviser in offering you the best advice as required by the Financial Services and Markets Act 2000. The personal data you provide will be used and stored in accordance with the Data Protection Act 2018 which incorporates the requirements of the General Data Protection Regulation (GDPR) into UK legislation. Before collecting any data from you, you will be issued with a Privacy Notice Document and will be asked to agree to the collecting, storing and use of your Special Category Data.