Astute Mortgages Ltd Privacy Policy


Astute Mortgages Ltd is authorised and regulated by the Financial Conduct Authority (FCA No. 974763). Astute Mortgages Ltd is registered in England & Wales (Company No. 12727722). Registered Office: 3–5 Fernwood House, 45 London Road, Cowplain, Waterlooville, Hampshire, PO8 8DH. ICO Registration No. ZB079654.


Why are we asking you to read this document?


During the course of dealing with us we will ask you to provide detailed personal information relating to your existing circumstances, financial situation and, in some cases, your health and family health history (“Your Information”).

This document explains what we will do with Your Information and the rights you have in relation to it.


What do we mean by “Your Information”?


Your Information means any information describing or relating to you. This may identify you directly, for example your name, address, date of birth and National Insurance number, or indirectly through information relating to your employment, financial circumstances or health history.


In the course of providing mortgage and/or insurance services, Your Information may include:


  • Name, address, date of birth, contact details and identification documents
  • Employment and income information including salary, bonuses and benefits
  • Bank account details, credit history, loans and financial commitments
  • Sources of income and expenditure
  • Family circumstances and details of dependants
  • Existing mortgage and insurance arrangements
  • Health information where relevant to protection insurance
  • Online identifiers such as IP address and cookie identifiers where you engage with our services online


The basis upon which we process Your Information


When we speak with you about your mortgage and/or insurance requirements we do so on the basis that a contract for services is in place between us.


In order to provide our services and arrange products suitable for your needs, we will process Your Information:

  • To fulfil our contractual obligations to you
  • To meet our legal and regulatory obligations
  • Where it is in our legitimate business interests to do so and your rights are not adversely affected
  • Where you have provided your consent


Examples of legitimate interests may include responding to enquiries from lenders or insurers, handling complaints, quality monitoring, compliance reviews and contacting you regarding services you have previously received.


Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

  • Your consent
  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate interests


You can withdraw your consent at any time by contacting us using the details within this notice.


Special category data and criminal disclosures


Where you ask us to assist with protection insurance or certain insurance products, we may collect information relating to your health, medical history or ethnic origin (“Special Category Data”).


Certain insurance products may also require disclosure of criminal convictions or offences (“Criminal Disclosures”).

We process this information only where necessary to arrange suitable insurance products and in accordance with UK data protection laws and regulations.


Automated decision-making and profiling


We may use automated systems such as credit scoring or affordability tools to assist in assessing applications.


You have the right not to be subject solely to automated decision-making, including profiling, where this produces legal or similarly significant effects concerning you. You may request that any such decision is reviewed by a person.


How we collect Your Information


We collect Your Information from a variety of sources, including:


  • Directly from you during meetings, telephone calls, emails and online forms
  • Credit reference agencies
  • Your employer or accountant where relevant
  • Publicly available sources such as the electoral roll
  • Identity verification and affordability assessment systems


Where technology solutions are used to access information such as bank account transactions or identity verification data, your consent will be obtained before access is granted.


What happens to Your Information when it is disclosed to us?


In the course of handling Your Information we may:


  • Store information electronically and in paper files
  • Use secure cloud-based systems and software providers
  • Submit applications to mortgage lenders and insurance providers
  • Respond to enquiries relating to products arranged on your behalf
  • Contact you regarding your mortgage or insurance arrangements
  • Carry out compliance and quality monitoring procedures


Access to Your Information is restricted to employees, consultants and contractors who require access in order to provide services to you.


Sharing and transferring Your Information


From time to time Your Information may be shared with or transferred to:


  • Mortgage lenders
  • Insurance providers
  • Mortgage clubs
  • Product specialists
  • Estate agents
  • Conveyancers and legal service providers
  • Surveyors and valuers
  • Software providers and administrators who assist in delivering our services


Information is shared only where necessary to progress your enquiry, application or ongoing service requirements.

These parties may be located within or outside the UK. Where information is transferred internationally, we will ensure appropriate safeguards are in place to protect Your Information.


Sharing Your Information for these purposes does not permit third parties to send you unrelated marketing communications.


Marketing communications


You may receive marketing communications from us where you have provided consent or where we are otherwise permitted to do so by law.


You can withdraw your consent to receive marketing communications at any time by emailing info@astutemortgages.co.uk.


Security and retention of Your Information


Your privacy is important to us and we take reasonable steps to safeguard Your Information from unauthorised access, loss, misuse or disclosure.


Your Information will be retained either electronically or in paper format for a minimum of six years, or longer where required due to legal or regulatory obligations or the duration of our relationship with you.


After this period, electronic records will be securely deleted and paper records confidentially destroyed.


Your rights in relation to Your Information


Under data protection law you have rights including:


  • The right to request copies of Your Information
  • The right to request correction of inaccurate information
  • The right to request deletion of Your Information in certain circumstances
  • The right to restrict or object to processing
  • The right to request transfer of Your Information to another organisation
  • The right to withdraw consent where processing is based on consent

You are not usually required to pay any charge for exercising your rights. We will normally respond within one month.


How to contact us


If you have any questions regarding this notice or wish to exercise any of your rights, please contact:


Astute Mortgages Ltd
3–5 Fernwood House
45 London Road
Cowplain
Waterlooville
Hampshire
PO8 8DH

Telephone: 02394 311 110
Email: info@astutemortgages.co.uk


How to complain


If you have concerns regarding how we use Your Information, you can contact us using the details above.


You also have the right to complain to the Information Commissioner’s Office (ICO):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Website: ICO Website