Privacy Policy

About Us
Connect IFA (The Network) is committed to protecting the privacy and confidentiality of all individuals and takes its responsibilities regarding the security of data very seriously. We abide by the rules of the General Data Protection Regulation (GDPR) upheld by the Information Commissioner Officer (ICO) and are authorised and regulated by the Financial Conduct Authority (FCA). This includes processing any personal data lawfully, fairly and in a transparent manner.

What information do we collect about you and why?
As a Network and as part of our service we will only collect information from you so that we can undertake appropriate due diligence measures on ARs, advisers and introducers (when required) following appointment by the Network. We will also request updated documents on an annual basis as part of the Fit & Proper process.

The types of information we will collect from you includes;

• Contact details
• Proof of address and identification
• Employment history
• Income and expenditure
• Credit details
• Bank statements

In addition, we may collect sensitive personal data such as criminal offence data where required as part of our due diligence.

Information from other sources
We may obtain information from other sources such as

• Companies House
• FCA
• Information Commissioner
• HMRC
• Former Networks
• Credit Reference Agencies

This is to enable us to verify who you are or facts that you have told us are accurate.

As part of verifying your identification we use systems such as Red Flag Alerts & Sanctions Search which are well-known identification sources. Once this check has been completed it will be held on your file to evidence that we have verified who you are. If you would like to know more about the search, please do not hesitate to contact us.

How will we use this information?
We will use your information for the strict purpose of our initial due diligence checks and on an annual basis for the Fit & Proper checks.

These checks are to cover the following three areas of assessment:

• Honesty and integrity
• Competence and capability; and
• Financial soundness

As a Network we are required by the FCA to obtain the above information in order to meet our regulatory requirements.

We also use this information to provide services and support and meet our obligations under the AR Agreement and Operations Manual.

In the interest to improve our services, telephone calls may be monitored and/or recorded for training purposes and to assist us handle a complaint. Where we record the call you will be informed of this.

The lawful basis on which we use this information
How we use your information (detailed above) we will do so using the lawful basis legitimate interests. We have decided upon this basis as it allows us to meet with the ICO and FCA rules and is the most suitable lawful basis for processing data with a view to arranging a policy.

Who will it be shared with?
Your information will not be shared with anyone, except for what is needed to complete the initial due diligence checks and annual Fit & Proper checks using the systems detailed above.

Where required we may forward your details onto regulatory authorities or fraud agencies where we have a legal obligation to do so to comply with our regulatory requirements or where fraud is suspected. We may do this under the lawful basis legal obligation.

We may pass your name and email address to selected associates that we consider may provide products and services that you find useful. You can opt out of this service at any time by contacting:
marketing@connectmortgages.co.uk

What we will do to ensure the security of personal information
We will not share any of the information you provide to third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us regardless of whether the information is in electronic or physical format. We use leading technologies and security measures to safeguard your information and keep strict security standards to prevent any unauthorised access to it.

How long will we retain your data
We will only hold data for as long as it is necessary. We will keep your file including your personal data and any call recording, on record for a minimum of six years following your agreement with the Network ending, in line with our regulatory obligation with the FCA. Where we need to hold your file for longer than this then we will inform you of this.

What are your rights?
You have the right to:

• Be informed about how we use, share and store your personal information;
• Request access to the personal data we hold on you (also known as a Subject Access Request (SAR)). Where a SAR is requested we will respond promptly and within one month from the date we receive the request;
• Request your personal data is amended if inaccurate or incomplete;
• Request your personal data is erased where there is no compelling reason for its continued processing and we don’t have a legitimate interest to retain it;
• Request that the processing of your data is restricted;
• The right to object to your personal data being processed;
• Rights in relation to automated decision making and profiling.

Where the processing of your data is based on your consent, you have the right to withdraw this consent at anytime by contacting us by phone or email. We do not use automated decision making or profiling systems.

Marketing
Where we need your consent we will ask for this separately. We do not use pre-ticked boxes or make assumptions that you have given your consent. Your consent must be freely given by positively opting in or making a clear affirmative action that you are giving your consent. We will do our very best to ensure you know exactly what you are consenting to and remind you that you may withdraw your consent at anytime by contacting us by email or phone. Where consent is obtained a record of this will be made confirming what you have consented to, the time and date and how consent was obtained.

Changes to the information
We regularly review and, where necessary update our Privacy Notice. If we plan to use personal data for a new purpose our Privacy Notice will be updated and you will be notified.