Privacy policy

DRAFT — this policy is adapted from the firm's previous published policy and needs a compliance review before publish.

This policy explains what personal information PBS Financial Solutions Ltd holds about you, why we hold it, who we share it with and what you can ask us to do about it. If anything here isn't clear, please ask — we'd rather explain it than leave you guessing.

Who we are

PBS Financial Solutions Ltd is an independent firm of mortgage and financial advisers based at 9 King Street, Lancaster, Lancashire, LA1 1JN. We are authorised and regulated by the Financial Conduct Authority, FRN 624550.

We are the data controller for the personal information described in this policy. That means we decide what information is collected and what happens to it.

What we collect

If you use the call-back form on this website, we collect only what the form asks for: your name, your phone number and a short indication of what you'd like to talk about. That's it — we don't collect anything else from the form.

If you go on to become a client, we will need a good deal more, because giving suitable advice depends on understanding your circumstances properly. Depending on what you're asking us to help with, that can include:

  • Your title, name, date of birth, nationality, marital status, contact details and addresses, plus the documents needed to verify your identity.
  • Your employment and income details, including salary, bonuses, overtime, sick pay and other benefits, and your employment history.
  • Bank account details, tax information, loans and credit commitments, credit history, sources of income and expenditure, family circumstances and details of any dependants.
  • Details of any mortgage, finance, investment or insurance products you already hold.

Where we're helping with insurance — life cover, critical illness cover or income protection, for instance — we will also need information about your health and medical history. Data protection law treats this as a special category of information and gives it extra protection. Certain types of insurance may also require you to tell us about criminal convictions or offences. We handle both in the same careful way as the rest of your information.

To advise you properly we sometimes need information about your partner, spouse or a family member. Please only give us their details if they know about it and are happy for you to do so.

Why we collect it

We collect your information so that we can:

  • Respond to your enquiry and arrange a conversation with an adviser.
  • Understand your circumstances well enough to give you suitable advice.
  • Research the market and approach lenders and providers on your behalf.
  • Submit and progress applications, and deal with the questions lenders and providers raise along the way.
  • Answer your questions about a product you hold and let you know about developments affecting it.
  • Meet the record-keeping and reporting obligations that apply to a regulated firm.

Our lawful basis for using it

When we advise you on a mortgage, a finance arrangement, an investment or an insurance policy, both of us are entering into a contract for the supply of services. Using your information to perform that contract, and to arrange the products you've asked for, is our main lawful basis.

Before a contract exists — during first conversations — and after it has come to an end, we may continue to use your information where it is in our legitimate interests to do so and where your rights aren't affected. For example, we may need to respond to a query from a lender, a provider or our compliance service provider about advice we gave you, or to ask you for feedback on the service you received.

We also use your information where we have to, in order to meet a legal or regulatory obligation — including obligations owed to the Financial Conduct Authority.

For health information and any criminal-conviction information, we rely on the additional grounds that data protection law provides for insurance-related processing. This kind of information has to be able to pass between advisers and insurers for cover to be arranged at all.

How we collect it

Mostly, directly from you — in meetings, on the phone, by email and in writing, and through the call-back form on this site.

Some information comes from elsewhere: credit checks, confirmation from an employer, and searches of public sources such as the electoral roll. Where we use software to verify your credit status, we will only do so with your consent. Electronic identity checks don't require your consent, but we will always tell you how they work and why we're running them.

Who we share it with

We share your information only where it's needed to do the job you've asked us to do. That can mean:

  • Mortgage lenders, finance lenders, investment providers and insurance providers.
  • Others who help us progress your enquiry or application, or who support a need we've identified — our compliance advisers, product specialists, estate agents, and providers of legal services such as conveyancers, estate planners, surveyors and valuers, where your circumstances call for it.

Sharing your details with any of these does not entitle them to send you marketing. Your information is shared so that we can do our job properly, and for no other reason.

We do not expect the service we provide to involve your information being transferred outside the UK.

How long we keep it

We keep your information, electronically or on paper, for a minimum of six years. Where we have a legal reason to keep records for longer, we will.

We take reasonable steps to keep it secure and to protect it from unlawful or malicious access. We'd ask you to take reasonable steps too: avoid sending confidential information by unprotected email, password-protect or encrypt attachments, and use a secure postal method when you send us original documents.

Your rights

You can ask us to:

  • Give you a copy of the personal information we hold about you.
  • Explain in more detail how we use it.
  • Correct it, delete it, or restrict or stop our use of it. We'll tell you at the time how far we're able to go, since some records we're required to keep.
  • Send an electronic copy of it to another organisation.
  • Change or withdraw any consent you've given us for marketing.

Exercising any of these rights costs nothing. If we believe we have a legal right not to act on a request, or to act on it differently from how you've asked, we will tell you that at the time and explain why.

Cookies

A cookie is a small text file a website saves onto your computer or device when you visit. It lets the site remember things between pages and between visits, so you're not repeatedly re-entering the same details.

Cookies are either session cookies, which expire when you close your browser, or persistent cookies, which stay until their expiry date or until you delete them. Cookies don't usually identify you personally, though information we already hold about you could be linked to information obtained from them.

This site uses a small number of cookies: those necessary for the site to work and to keep it secure, and analytics cookies that tell us in aggregate how the site is being used so we can improve it. Analytics cookies don't tell us who you are.

Most browsers let you refuse or delete cookies through their settings, and you can change those settings at any time. Blocking all cookies will affect how many websites behave, including this one.

How to contact us — and the ICO

If you have a question about this policy, or you'd like to exercise any of the rights described above, please contact Paul Brett-Smith:

  • By post: PBS Financial Solutions Ltd, 9 King Street, Lancaster, Lancashire, LA1 1JN
  • By phone: 01524 888877, Monday to Friday, 9am to 5pm
  • By email: advice@pbsfinancial.co.uk
  • Through our contact page

Please tell us as soon as you can if you become aware of any unauthorised disclosure of your personal information, so that we can investigate it and meet our own obligations.

If you have a concern or complaint about how we've handled your personal information, you can raise it with the UK's data protection regulator, the Information Commissioner's Office, through ico.org.uk or by writing to the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.