Introduction

London Mortgage Partners are registered as a data controller with the ICO, which is the UK’s independent body set up to uphold information rights. As a data controller, we must make sure we comply with UK data protection law when we process personal information.

We are committed to protecting your privacy. This Privacy Notice sets out our privacy practices and explains how we collect, process, hold and store (collectively referred to as handle) client data and with whom we share this information with. The information we handle is only that which is required by us so that we may deliver the services you require. Except as provided in this Privacy Notice, we do not supply your client data to any other company for marketing purposes.

You may browse our website without telling us who you are or revealing any personal information about yourself. The information we collect from you during browsing is only that which is required by us so that we may deliver the site functionality, information you have requested or searched for and to provide you with our services.

By proceeding with using our services, you consent to the Company handling your data in line with this Privacy Notice. Our Privacy Notice will be reviewed on a regular basis and may be updated from time to time. We may change or update this Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of changes we make.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice in the ‘How to contact us’ section.

This Privacy Notice explains: –

  • Who we are
  • What is Personal Information/Data
  • What Client Data do we process and why?
  • Our legal basis for processing personal information
  • How do we collect data?
  • Disclosing data to third parties and why
  • Your rights
  • How we keep your information secure
  • Communications
  • How to contact us
  • How to complain

Who we are?

London Mortgage Partners Limited is authorised and regulated by the Financial Conduct Authority. The LMP Group, LMP, LMP Private Clients and LMP Protect are trading styles of London Mortgage Partners.

What is Personal Information/Data

When we refer to personal information, we mean any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. Under data protection legislation it is known as personal data. Some personal information will identify you directly – for example, by giving your name and email address. It may also be possible to identify you indirectly, from information in which your name is not given, for example by naming your job title and employer, or by using another form of identifier such as an online identifier.

We may ask you to provide personal information by filling in forms (hard copy and/or digital) and documents or corresponding with us by phone, e-mail, letter or otherwise or during the course of our meetings with you.

What Client Data Do We Collect and Why?

London Mortgage Partners, LMP, LMP Private Clients and The LMP Group’s 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 needs and circumstances.

LMP Protect arrange Life Insurance for our customers. This involves searching against the providers we deal using “sensitive personal data” to find the protection solution that best suits your needs and circumstances.

The personal information outlined below assists us with providing you with a personalised service whilst complying with our legal and regulatory requirements.

Type of personal informationWhy we collect it
Identity Details including your full name and date of birth.

We may ask for copies of identity documents in which case we may collect details including your place of birth and residential address

To carry out money laundering and financial checks, and for fraud and crime prevention and detection purposes.
Contact Details including your telephone number(s), mobile phone number(s), correspondence address, email address(es).To contact you in order for us to manage and administer/provide our service to you.

To respond to any correspondence and service related enquiries you send to us

To discuss products or services for which you apply, or may be interested in applying for.

To manage any applications you make for products or services via ourselves.

To communicate any updates to you including changes to our services, terms and conditions of any services and any changes to this notice and to our website

To contact you in order to receive your feedback on our services and to participate in related surveys.

Financial information relating to you, including income, bank account balances, credit commitments and payment card details.To enable us to advise you on your financial circumstances and the appropriateness of specific courses of action and products.

To enable you to make payments for our services

To process applications with third parties on your behalf.

Details of your dependants (name, address and date of birth).To enable us to advise you on your financial circumstances and the appropriateness of specific courses of action and products.

To process applications with third parties on your behalf.

Where those dependants are adults, please make sure that you have their permission to provide us with their personal information.

Details of contact that we have had with you such as meetings, fact-finding discussions, documentation, recommendations, referrals, quotes and general correspondence.To allow us to provide a professional service and to contact you with information about other services of ours that we think you may be interested in.
Details of services you have received.
Client experience and other feedback and information you have provided to us.To review your feedback and experience with us so that we can improve our products and services for you and for our other clients.
Information about complaints and incidents
All of the personal information described above.To comply with our regulatory responsibilities.

We may disclose your personal information to third parties where we are required to do so to comply with applicable laws and regulatory requirements including in circumstances where we are required to do so by a Court Order, regulatory authority or any other third party with the lawful right to request and receive the personal information we hold about you (including law enforcement agencies and tax authorities).

We may also use your personal information where it is necessary for us to take legal advice in order to establish our legal rights, to bring a claim against you or any related parties or to defend a claim from you or any related parties.

We collect and process this information for our legitimate business interests including to carry out our own internal business planning, compliance, training, audit and quality assurance purposes.

In some instances, where LMP Protect review your Protection requirements, it is it is necessary to collect information from and about you which the law considers to be sensitive such as data about your physical or mental health, which we refer to as “special category personal data”.  The special category personal data that we may ask you to provide, and the reasons we ask you to provide it are as follows.

Type of personal informationWhy we collect it
Information about your physical or mental health or conditionCertain products and services that you request may require this information. Specifically in order for us to advise you on and to submit applications for health or life insurance products and services. We will need to obtain this information in order to obtain accurate quotes and to advise on the suitability of products (as insurance premiums and eligibility for products will in part depend on your physical and mental health).

We will usually collect this information in the course of our meetings with you, on specific questionnaires or in the process of completing an application form for such products and services

Information about your sex life or sexual orientation.

Information about your racial or ethnic origin

Some providers may ask for this information in the course of your application for their products or services. We will never ask for this information for our own purposes.

We will only process the special category personal data listed above with your explicit consent. We ask for your consent to the processing of this data at the end of this Notice. You may choose not to provide us with this consent. However, please note that if you do not provide us with your consent to collect and process the information listed in the table above:

  • we may not be able to advise you fully in respect of certain products and services which require this information (in particular those relating to health or life insurance).;
  • your application may be rejected by the providers of products and services which require this information; or
  • the quotes for such products and services may be higher than would be the case if this information were provided.

Our legal basis for processing personal information

Our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. In respect of the personal information and the purposes for which we may process your personal information which are set out in this Notice, we have confirmed the legal basis upon which we collect and process your personal information in the ‘What type of personal information will be processed and why?’ section above.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you or with your explicit consent, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.

How do we collect data?

The following outlines the processes we employ to collect information:

  • Contacting Us – we may record, use and store any telephone, postal, e-mail or other electronic communications provided by you. This is to ensure that we can refer back to any instruction you may have given to us as well as to ensure that the information we provide you with is accurate and appropriate to your circumstances.
  • General Statistics – we collect statistics relating to pages visited, paths through the website, search terms used to find us. This is done to improve the visitor experience, understand our customer’s needs and help us improve site design and layout.
  • Online Forms – we collect data that you have entered into our online/contact forms. We have appropriate measures in place to ensure that users’ personal details are not misused, accidentally destroyed, lost or altered within the server environment. No data transmission over the internet can be guaranteed to be totally secure, we cannot ensure, guarantee or warrant the security of any information which you send to us, and you do so at your own (Our website may contain links to enable you to visit other websites. Once you have left our site, you should note that we do not have any control over the other linked website. We cannot be held responsible therefore for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy notice applicable to the website in question).
  • We may also record and/or monitor communications for training and quality assurance purposes but will always ask for your consent before recording communications for these purposes.

Disclosing Client Data to Third Parties:

We may disclose your personal information to the following categories of recipients.

  • Depending on your requirements, it may be necessary to share your personal data with London Mortgage Partner’s network (i.e., our Appointed Representatives) in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients.
  • Third party firms to verify your identity, in line with money laundering or other requirements;
  • To providers of financial services and insurance products and services in respect of whom you request us to submit applications on your behalf and to receive update from such providers in order for us to provide our services to you throughout the lifetime of our relationship with you;
  • We may disclose client data to third parties (this may include but is not limited to, our accountants, contractors and other professional advisors) who may require access to client data in the course of them providing us with these services. We will at all stages ensure that these third parties have appropriate security measures in place when handling any client data;
  • Our suppliers of audit and regulatory compliance support services who may review our records containing your personal information in order to audit and report to us on our compliance with applicable laws and regulatory requirements;
  • Our IT systems providers to assist us with providing you with an efficient and modern professional service;
  • Other financial institutions or regulatory bodies with whom information is shared for money laundering checks, credit risk reduction and other fraud and crime prevention purposes;
  • To any national and/or international regulatory, enforcement body, government agency or court where we believe the disclosure is necessary
    • As a matter of applicable law or regulation (including where we are required by law to provide information to organisations such as HMRC)
    • To exercise, establish or defend our legal rights, or
    • To protect your vital interests or those of any other persons
  • We may disclose specific personal information to another person with your consent where we are permitted to do so by law;
  • We may share aggregated demographic information with our partners, advertisers or other third parties. This will not contain information that can identify any individual.

Mortgage lenders are data controllers in their own right and have their own privacy notices. However, 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 bring this to your attention as part of our process so that you are forewarned.

We will not sell, share or rent your name, email address, or any other client data to any third party for marketing purposes.

Your Rights to Viewing, Changing or Removing Client Data:

You may view all Client Data that we store about you;

You may correct, delete or update your Client Data via your account;

You may withdraw your consent (partial or complete) at any time;

You may object to processing of your personal information, ask us to restrict processing or request portability of personal information.

You may request the transfer of your personal information.

You may opt-out of marketing communications at any time.

You may request that all Client Data held be removed where there is no compelling reason for its continued processing.

You can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.

How We Store Client Data:

We retain personal information we collect from you where we have an ongoing legitimate need to do so, for example:

to provide you with a product or service you have requested us to provide,

to perform our contractual obligations to you;

to comply with applicable legal, tax or accounting requirements;

to defend or manage any claims or complaints between us, you and any relevant third party including taking legal advice in respect of such claims in order to establish, exercise or defend our legal rights or such claims.  This would include complaints and claims which you may bring against us or which are submitted to a court, regulatory authority or ombudsman.

Your data will be stored securely in line with industry best practice at all times. The security measures in place are reviewed annually;

Your data will be stored only on servers in a GDPR compliant environment;

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

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

When we have no ongoing legitimate need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Communications about other products or services

You will have the choice to opt-in to receiving other marketing information and related products and services.

You can opt-out of receiving these types of communications at any time by contacting us using the details below.

How to Contact Us

If you have any 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 as below:

  • Name: London Mortgage Partners Limited
  • Address: Unit 109 Drysdale Street, London N1 6ND
  • Telephone Number: 02038651049
  • Email: enquiries@londonmortgagepartners.co.uk

How to Complain

If you wish to raise a complaint about how we have handled your personal data, you can contact our 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 Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113

www.ico.org.uk/concerns