Privacy Notice

Last Reviewed August 2020

Who We Are

MortgageKey is a trading style of OSL Financial Consultancy Limited, which is authorised and regulated by the Financial Conduct Authority (FCA) and also registered as a Data Controller as defined under the Data Protection Law with the Information Commissioner’s Office (ICO).

MortgageKey is an independent broker built upon the foundations of a professional and friendly service. We pride ourselves on providing a quality service to our clients and ensuring that they are treated fairly throughout the mortgage and protection process.

Our trading address is POBOX 746, Hull, HU10 9BP.

MortgageKey is a privately owned website and domain which is owned and hosted by Oliver Simon Laver individually - Oliver Simon Laver licenses the brand and domain to OSL Financial Consultancy LTD for the purposes of mortgage brokering. All customers that come through the brand and domain are ultimately property of Oliver Simon Laver and any of his associated Financial Services Companies.

We are committed to ensuring that your information is protected. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this Privacy Notice.

This Notice will be updated regularly to ensure ongoing compliance to associated laws and regulations. Changes to how we use personal data will be updated periodically via this Privacy Notice to ensure transparency in all processing activities.

What information we collect

The personal data processed and retained relating to you includes:

• Basic and contact information (including name, address, date of birth, telephone number and email address),
• Identity information (including national insurance number, passport and driver’s license),
• Employment details (including occupation, place of work and income),
• Bank account details,
• Financial and credit report information,
• Pay slips and bank statements,
• Basic information regarding dependents (age),
• Other information relevant to our service such as mortgage and insurance details.

How we collect your information

We may collect information through the following means:

• Information you give to us when you apply for and/or express an interest in our services.
• Information that we receive from third parties including lenders and credit reference agencies.
• Information that we learn about you during the provision of our services.
• Where you provide information to us on our website.
• Information that you make public on our social media platforms.

Our lawful basis for processing

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

Rationale/Reason for Processing	Lawful Basis for Processing
Information you give to us when you apply for and/or express an interest in our services. Information that we receive from third parties including lenders and credit reference agencies. Information that we learn about you during the provision of our services. Where you provide information to us on our website. Information that you make public on our social media platforms.	Performance of a contract
To retain records of any services or advice provided to you by your adviser. To detect, prevent and investigate fraudulent applications for products. To notify the relevant authorities of any suspicious activity following an investigation undertaken by us into allegations of misconduct and/or criminal offences.	Legitimate interests
To provide you with details of the products and services from us that may be of interest to you in accordance with your preferences (for more information, see the How we use your information section)	Consent Legitimate interests
If we identify special category data during the processing of your personal data, we will obtain explicit consent from you to record this data.	Consent

How we use your information

We require this information to understand your needs and provide you with the best possible service. There are other ways in which we will use your information, including:

• Providing a service
• To respond to queries or complaints that you raise,
• Internal record keeping requirements,
• Improving our products and services,
• Compliance with any regulatory obligations.

Where you have provided consent, we may periodically send promotional emails & text messages about new products, special offers or other information which we think you may find interesting using the email address & phone number which you have provided. You may change your mind at any time by writing to or emailing us at the address provided on our contact page.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or in writing. We may use the information to customize the website according to your interests.

We may share your information with the following:

• Credit Reference Agencies (please see the Credit Checking section),
• Mortgage lenders, to allow us to make a mortgage application on your behalf,
• Third parties involved in the mortgage process, such as solicitors, conveyancers and mortgage clubs,
• Insurance providers, to allow us to make an insurance application on your behalf,
• Software providers for product sourcing purposes,
• Any regulatory/government body or ombudsman in line with our regulatory obligations.

Your data will be shared with all Financial Services companies associated with Oliver Simon Laver & Sally Louise Bradshaw for the use of renewing your mortgage. If the correct marketing consents have been given then we may send promotional Emails and SMS via any associated Financial Services companies with Oliver Simon Laver and Sally Louise Bradshaw.

Credit Checking

Whenever you apply for a mortgage through us, we and/or our lenders will carry out checks with credit reference agencies (“CRAs”), including:

• Equifax Ltd
• Experian Limited
• TransUnion International UK Limited

MortgageKey only use Equifax for our credit search and identification/verification requirements.

We will use this information to:

• Check your identity and verify the accuracy of the data you have provided to us,
• Prevent criminal activity, fraud and money laundering.

If you are making a joint application, or tell us that you have a spouse of financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before contacting us regarding our services.

Our search will be recorded in your credit history, however, will not be visible to other lenders or affect your creditworthiness. This is referred to as a ‘soft search’. To establish how our lenders will use your information, they will have their own separate Privacy Policy, for more information, please refer to them directly.

You can also contact the CRAs directly:

• Equifax Ltd
  Customer Service Centre
  PO Box 10036
  Leicester
  LE3 4FS
  0333 321 4043 or 0800 014 2955
  www.equifax.co.uk/crain
• Experian Limited
  PO Box 9000
  Nottingham
  NG80 7WF
  0344 481 0800 or 0800 013 8888
  www.experian.co.uk/crain
• TransUnion International UK Limited
  Customer Services Team
  PO Box
  Leeds
  West Yorkshire
  LS3 1EP
  03300247574
  www.transunion.co.uk

Data Retention and Storage

Your information is securely stored within the European Economic Area (EEA).

We keep data up to six years for the purpose of renewing mortgages or financial products. We will then dispose your information.

Bank account information will be deleted upon completion.

Sensitive Personal Data

Sensitive personal data includes information about an individual’s health and other categories of personal information which is closely protected. We will only process this information where you have provided explicit consent for us to do so and where the information is relevant and required for application purposes. This information is required to assess your circumstances and help us to ensure we find the most suitable products for your requirements.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect.  

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us to provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Data Profiling

We may use your data for data profiling so we can build lookalike audiences on social media, Google, Bing, Sky and other advertising platforms.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. These sites are not governed by this Privacy Notice, you should exercise caution and look at the Privacy Notice applicable to the website in question.

Your Rights

Under Data Protection Laws, you have rights including:

Your right to be informed – You have the right to be notified of how we collect and process your data. This Privacy Notice is available to provide transparent and clear details of how we do this.

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate, You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us using the following methods if you wish to make a request:

Email:
emma@mortgagekey.co.uk

Mail:
Emma Moore
HR Manager
OSL Financial Consultancy Ltd
POBOX 746
Hull
HU10 9BP

Phone:
01482 306666

We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by using the contact details above.

How to complain

If you have a complaint about how we have handled your personal information you may contact us on the details provided above and we will investigate your complaint.

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113