Responsible Life Ltd 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), which is applicable from 25 May 2018 and upheld by the Information Commissioner Office (ICO). We are authorised and regulated by the Financial Conduct Authority (FCA) to advise and arrange regulated Lifetime Mortgages, Mortgages and Non-Investment Insurance contracts. This includes processing any personal data lawfully, fairly and in a transparent manner.
We are based in sunny Plymouth, Devon and our Head Office is located at:
Responsible Life
Units 11-24 4A Mills Bakery
Royal William Yard
Plymouth
Devon
PL1 3GE
Responsible Life Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register (https://register.fca.org.uk/) under reference 610205.
We will only collect information from you so that we can advise and arrange regulated Lifetime Mortgages, Mortgages and Non-Investment Insurance contracts that maybe suitable for you. In the financial services industry we call this factfinding which provides us with all the information we need from you in order to provide you a with suitable product that meets your circumstances and requirements.
When obtaining information from you we will do this by phone, email or post and will confirm the accuracy of the data collated. It is important that all the data we hold on you is accurate so that we can advise and arrange suitable products for you.
The types of information we will collect from you includes; contact details, occupation, income and expenditure, credit details, mortgage requirements, existing financial products, solicitors/accountant details and bank details. In addition, we may collect sensitive personal data such as medical conditions or criminal offence data where required to do so to advise and arrange a product on your behalf.
Our Privacy Notice is held on our website for review by customers and partners. In addition we have incorporated information and consent based opt-in measures to our pre advice documentation where required. For instance where our Electronic ID verification provider requires consent, this has been added to our Fact Find and our Customer Declaration to ensure we have positive consent captured.
We ensure that all personal information that we collect about you is used in accordance with all data protection laws.
| How we use your data | Our lawful basis |
| To provide the services you have requested | This is necessary so that we can provide you with your requested service, in accordance with the contract. |
| To maintain our relationship with you | Keeping you informed of the available products and updates to these products, as well as keeping our records up to date, is in our legitimate interest. It is also a requirement to make sure that we comply with the legal and regulatory rules that apply to us. |
| To provide an equity release plan recommendation | In accordance with our contract, it is necessary for us to use this data to provide your recommendation for an equity release plan. We will only process data regarding your health with your prior consent. We will process all data regarding Criminal Convictions, as it is in our legitimate interest to prevent financial crime. |
| To provide information about our services and products | It is in our legitimate interest to provide you with updates to our available services and products via e-mail, post or telephone from time to time. Your data privacy is important to us and you may opt out of any communications at any time. |
| To provide you with estate planning advice (Wills and Lasting Powers of Attorney) | Providing you with advice on a Will and Lasting Power of Attorney is necessary for the contract to be fulfilled. |
| Our online services are improved for you by monitoring our website usage with cookies | It is within our legitimate interest to improve our service offering. |
| To ensure the business is run in a proper way | This is in our legitimate interest to fulfil our legal and contractual obligations, as well as the legal and regulatory requirements that we are held to. |
We may obtain information from other sources such as public records, if required. This is to enable us to verify who you are or facts that you have told us are accurate.
Occasionally we may receive your contact details from a third party who you have expressed an interest to in relation to the products and services we have to offer. Where we use introducers or lead generators we will request from them that they have obtained your consent and have made it clear to you that they will pass your details on to a firm such as ours and that you will be expecting us to contact you. The details shared could be, but are not limited to:
Full Name
Date of Birth
Address
Contact Details
Marital Status
Property Value
How we use your information (detailed above) will always be done using the lawful basis of 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 Lifetime Mortgage, Mortgage and Non-Investment Insurance contracts.
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
As stated above, if you wish to proceed to take out a Lifetime Mortgage, Mortgage and Non-Investment Insurance contracts then we will pass your details on to the product provider with whom the product is to be arranged. The information we pass on will be detailed within the application we complete on your behalf. We may also liaise with your solicitor and the lenders valuers to arrange a valuation on their behalf.
Where required we may forward your details on to 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 forward your details to our electronic identification partner who will process your data for the purpose of verifying your identity. This will include an online search using their own systems and allows us to satisfy our legal obligations.
We may share your data with our partner organisations for the purposes of improving the way we do business, for details of these organisations please contact us on the details set out below.
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.
We will only hold data for no longer than is necessary. We will keep your file including your personal data and any call recordings on record for a minimum of six years, in line with our regulatory obligation with the FCA.
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 any time by contacting our Data Protection Officer using the contact details in the ‘Contacting Us’ section. We do not use automated decision making or profiling systems.
Where we need your consent, we will ask for this separately. 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, please see the ‘Contacting Us’ section for contact details. 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.
We will only send you information about regulated products or services if we have obtained your consent to do so.
If you visit our website, you may receive personalised banner advertisements whilst browsing other websites including, but not limited to, search engines and social networking. Any banner advertisement you will see will relate to products you have viewed whilst browsing our website on your computer or other devices.
These advertisements are provided by Responsible Life Ltd using ‘Cookies’ placed on your computer or other device. You can remove or disable cookies at any time – see our cookies notice for more information.
You may receive advertising based on information about you that we have provided to the social media platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it receives from us.
We hope that the service you receive from us is to the high standard you would expect. If at any point you are unhappy with the way we have used your data then please notify our Data Protection Officer using the contact details in the ‘Contacting Us’ section below. Alternatively, if you are concerned about the way in which we collect or use your personal data, you can raise your concern with the Information Commissions Office (ICO) on 0303 123 1113. For further details you may visit the ICO website www.ico.org.uk.
We will tend to disclose the complainants’ identity to whoever the complaint is about, however if you wish your identity to remain anonymous, we will try to respect that. We will keep your complaint on record for two years once closed or six years if it also relates to how we arranged a product and falls under the FCA ruling.
We regularly review and where necessary update our Privacy Notice. If we decide to change our Privacy Notice, we will post those changes on https://www.responsiblelife.co.uk/privacy-policy. Please check the website regularly for any changes to this Privacy Notice. If we plan to use personal data for a new purpose our Privacy Notice will be updated, and you will be notified.
If there are any questions regarding this Privacy Notice you may contact us using the information below.
Email: privacy@responsiblelife.co.uk
Or in writing to:
The Data Protection Officer
Responsible Life Ltd
Units 11-21, Mills Bakery
Royal William Yard
Plymouth
PL1 3GE
The previous Privacy Notice was dated 07/02/2017. This Privacy Notice was last updated on 20/11/2019.
