Personal & Business
Finance Specialists

Why should you read this document?

While dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances, your financial situation and, in some cases, your health and family health history (Your Personal Data). This document is important as it allows us to explain what we will need to do with Your Personal Data and the various rights you have related to your Personal Data.

What do we mean by “Your Personal Data”?

Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example, your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, such as your employment situation or any other information associated with your cultural or social identity.

In the context of providing you with assistance in relation to your Finance, Commercial Finance/Mortgage or Property requirements, Your Personal Data may include:

• Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.
• Employment and remuneration information (including salary/bonus schemes/overtime/sick pay/other benefits), employment history.
• Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents

The basis upon which our Firm will deal with Your Personal Data

When we speak with you about your Finance, Commercial Finance/Mortgage or Property requirements, we do so on the basis that both parties are entering a contract for the supply of services.

In order to perform that contract and to arrange the products you require, we have the right to use Your Data for the purposes detailed below.

Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided if it is in our legitimate business interest to do so and your rights are not affected.  So, for example, we may need to respond to requests from mortgage lenders, finance providers and our Compliance Service Provider relating to the advice we have given to you or to contact you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator,  or for more comprehensive compliance with any legal or regulatory obligation to which we might be subject.  In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

The basis upon which we will process certain parts of Your Personal Data

Where you ask us to assist you with, for example, your Commercial Finance/Mortgage or Property, we may ask you to provide information about your ethnic origin, your health and medical history (Your Special Data). In addition, we will record and use Your Special Data to make inquiries to finance-related products that may meet your needs and provide you with advice/guidance regarding the suitability of any product that may be available to you.

Suppose you have parental responsibility for children under the age of 13. In that case, it is also very likely that we will record information on our systems that relates to those children and, potentially, to their Special Data.

The arrangement of certain types of finance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (Criminal Disclosures). This is relevant to finance-related activities such as underwriting and fraud management.

We will use unique Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be able to exchange freely between finance intermediaries such as our Firm and the finance providers to enable customers to secure the finance they require.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from various sources, but mainly directly from you. You will usually provide information during our initial meetings or conversations to establish your circumstances and needs and preferences in relation to Commercial Finance/Mortgage or Property. In addition, you will provide information to us verbally and in writing, including email.

We may also obtain information from third parties, such as credit checks, information from your employer, and searches of information in the public domain, such as the voters roll. Suppose we use technology solutions to assist in the collection of Your Personal Data, for example, software that is able to verify your credit status. In that case, we will only do this if we have consent from you or our nominated processor to access your information in this manner. With regards to electronic ID checks, we would not require your consent but will inform you of how such software operates and the purpose for which it is used.

What happens to Your Personal Data when it is disclosed to us?

In the course of handling Your Personal Data, we will:

• Record and store Your Personal Data in our paper files, mobile devices, and computer systems (websites, email, hard drives, and cloud facilities). Employees and consultants can only access this information within our Firm. Therefore, it is only when necessary to provide our service to you and perform any administration tasks associated with or incidental to that service.
• Submit Your Personal Data to Product Providers/Mortgage Lenders/Commercial Lenders and Finance Providers, both in paper form and online via a secure portal. Providing this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and deal with any additional questions or administrative issues that lenders and providers may raise.
• Use Your Personal Data to respond to any queries you may have regarding any Commercial Finance/Mortgage or Property Finance you may take out, or to inform you of any developments regarding those products and/or policies of which we might become aware.

Sharing Your Personal Data

From time to time, Your Personal Data will be shared with:

• Product Providers/Mortgage Lenders/Commercial Lenders and Finance Product Providers.
• Third parties who we believe will assist us with your enquiry or application or who can support your needs as identified. These third parties will include, but may not be limited to, our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors, and valuers (in each case where we believe this to be required due to your particular circumstances).
• The information sent/given to us will be processed by GB Financial Group Ltd and our selected partners/brokers and lenders. Our partners or we will be in touch to discuss your further financial requirements.

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e., to progress your Commercial Finance/Mortgage or Property enquiry and to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you and as otherwise set out in this Customer Privacy Notice.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area, if it does e.g. cloud services may be hosted from outside the EEA)

If data is transferred outside the EEA state whether the transfer is made on the basis of an adequacy decision by the European Commission under Article 45 of the GDPR.  If the transfer is not made on the basis of an adequate decision, give people brief information on the safeguards put in place in accordance with Article 46, 47 or 49 of the GDPR.

Security and retention of Your Personal Data

Your privacy is important to us, and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure postage methods when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years or in instances whereby we have a legal right to such information. After that, we will retain records indefinitely.

Your rights in relation to Your Personal Data

 You can:

• request copies of Your Personal Data that is under our control.
• ask us to explain further how we use Your Personal Data
• ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
• ask us to send an electronic copy of Your Personal Data to another organisation should you wish.
• change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)

How to contact our Firm regarding the use of Your Personal Data

If you have any questions or comments about this document or wish to make contact to exercise any of your rights set out within it, please contact:

Mr. Akmal Siddiq, 11 Burford Road, Stratford, London, E15 2ST

Tel: 0203 8767 301

If we feel we have a legal right not to deal with your request, or to action it in a different way to how you have requested, we will inform you of this at the time.

You should also contact us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data so that we may investigate and fulfil our regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data, you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.