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Privacy Notice

Platina Solutions Limited

Last updated 23 May 2018

Your Personal Data – what is it?

Personal Data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the Data Controller’s possession or likely to come into such possession. The processing of Personal Data is governed by the General Data Protection Regulation 2016/679 (the “GDPR”)

Who are we?  

Platina Solutions Limited is the Data Controller (“we”, “us”). This means they decide how your Personal Data is processed and for what purposes.

How do we process your Personal Data?

We comply with our obligations under the GDPR by keeping Personal Data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting Personal Data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect Personal Data.

We use your Personal Data for the following purposes: -

1. To provide our advice and implementation service in respect of financial products, such as mortgages, life assurance, pensions and investments.

2. To keep in contact with our clients about products and services which we believe may be of value to them

3. To inform people of our business and its activities  

What is the legal basis for processing your Personal Data?

We understand that personal information is just that – personal. So when we process your personal data, we make sure we satisfy the conditions prescribed by data protection laws to do so. This section covers what those conditions are.

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

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.

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

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

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

What information we collect and how we use it

We want to give all our customers the best standard of service we can and are serious about protecting your personal information. Please read on to find out what information we’ll need from you, how we use your personal information to make our products and services as effective as possible and how we look after it, including our Cookies policy.

Information we collect directly

Mortgage Customers

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 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 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.

Vulnerable Customers

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:

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.

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.

Extra

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.

Sharing your Personal Data

Your Personal Data will be treated as strictly confidential, and will be shared only with Julian Harris Networks and providers of financial service products, third-party data storage providers and legal or regulatory authorities if obliged to do so.

We keep your Personal Data for no longer than reasonably necessary and we only retain your data for servicing the financial services provided where agreed and in case of any legal claims and for regulatory purposes.

Your rights and your Personal Data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your Personal Data: -

The right to request a copy of your Personal Data which we hold about you;

The right to request that we correct any Personal Data if it is found to be inaccurate or out of date;

The right to request your Personal Data is erased where it is no longer necessary for us to retain such data;

The right to withdraw your consent to the processing at any time;

The right to request that the Data Controller provide the Data Subject with his/her Personal Data and where possible, to transmit that data directly to another Data Controller;  

The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request a restriction is placed on further processing;

The right to object to the processing of Personal Data;

The right to lodge a complaint with the Information Commissioners Office.

Further processing

If we wish to use your Personal Data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

Contact Details

 You can contact us via email at  data@platina.co.uk or telephone 01234 409084, or you can write to us at 18 South Avenue, Elstow. Bedfordshire MK42 9YS.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.