Clark Mortgage

enquiries@clarkmortgage.co.uk

Specialists In: Complex Income, Adverse Credit, Portfolio Landlords, Development

GDPR Customer Privacy Notice

Why should you read this document?

During the course of 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 to you what we will need to do with Your Personal Data, and the various rights you have in relation to it.

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 – e.g. your name, address, date of birth, or National Insurance number.

  • Indirectly – e.g. your employment situation, physical or mental health history, or any other information associated with your cultural or social identity.

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

  • Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses, and documents necessary to verify your identity.

  • Employment and remuneration information (including salary, bonus schemes, overtime, sick pay, or 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.

  • Health status and history, details of treatment and prognosis, and medical reports (further details are provided below regarding the processing we may undertake in relation to this type of information).

  • Any pre-existing mortgage, finance, and/or insurance products and the terms and conditions relating to these.


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

When we speak with you about your mortgage, finance, and/or insurance 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 Personal Data for the purposes detailed below.

Alternatively, either during initial discussions with you or once the contract between us has ended (for whatever reason), we may use Your Personal Data if it is in our legitimate business interest to do so and your rights are not affected.

For example, we may need to:

  • Respond to requests from mortgage lenders, insurance providers, or our compliance service provider.

  • Contact you to seek feedback on the service you received.

We may also use Your Personal Data to fulfil contractual responsibilities to our regulator (the Financial Conduct Authority) or to comply with any legal or regulatory obligations.


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

Where you ask us to assist with your insurance needs (for example, life insurance or insurance related to accident or illness), we will ask for information about your ethnic origin, health, and medical history (Your Special Data).

We will record and use Your Special Data to:

  • Make enquiries with insurance providers.

  • Provide advice or guidance regarding the suitability of products available to you.

If you have parental responsibility for children under 13, we may record information (including Special Data) relating to those children.

In arranging certain types of insurance, you may disclose historic or current criminal convictions or offences (“Criminal Disclosures”). This information will be used in the same way as Your Personal Data, as outlined in this notice.

Special Data and Criminal Disclosures may need to be shared between insurance intermediaries (such as our Firm) and insurance providers to enable customers to secure the insurance protection their needs require.


How do we collect Your Personal Data?

We collect and record Your Personal Data from a variety of sources, primarily directly from you. You will usually provide information:

  • During initial meetings or conversations.

  • Verbally or in writing (including by email).

We may also obtain information from:

  • Third parties (e.g. credit checks, your employer).

  • Public domain sources (e.g. electoral roll).

  • Technology solutions that verify your credit status (with your consent).

For electronic ID checks, your consent may not be required, but we 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?

We will:

  • Record and store Your Personal Data in paper files, on mobile devices, and on our computer systems (email, hard drives, and cloud storage).

  • Restrict access to employees and consultants who require it to perform their duties.

  • Submit Your Personal Data to product providers, mortgage lenders, commercial lenders, and/or insurance providers via secure methods (paper or online).

  • Use Your Personal Data to respond to your queries, manage your mortgage, finance, or insurance policies, and inform you of any relevant developments.


Sharing Your Personal Data

Your Personal Data may be shared with:

  • Investment providers, mortgage lenders, finance lenders, and insurance providers.

  • Third parties who can assist with your enquiry or application, such as:

    • Compliance advisers

    • Product specialists

    • Estate agents

    • Providers of legal services (estate planners, conveyancers)

    • Surveyors or valuers

This sharing is only for the purposes described in this Customer Privacy Notice — to progress your mortgage, finance, and/or insurance enquiry and to provide our services.

Third parties are not entitled to send you marketing or promotional messages.


Security and retention of Your Personal Data

We take your privacy seriously and will:

  • Keep Your Personal Data secure in accordance with legal responsibilities.

  • Take reasonable steps to safeguard it from unauthorised or malicious access.

We also expect you to:

  • Avoid sending confidential information over unprotected email.

  • Password-protect or encrypt email attachments.

  • Use secure postage for original documentation.

We will retain Your Personal Data for a minimum of six years, or indefinitely where we have a legal right to do so.


Your rights in relation to Your Personal Data

You can:

  • Request copies of Your Personal Data under our control.

  • Ask for further explanation of how we use Your Personal Data.

  • Request correction, deletion, restriction, or cessation of use (subject to applicable laws).

  • Ask us to send an electronic copy of Your Personal Data to another organisation.

  • Change or withdraw any marketing consent previously given.


How to contact us

If you have any questions or wish to exercise your rights, contact:

Mathew Rees
📧 info@beneficial-network.co.uk
📞 0203 4767483
✉️ Data Protection Officer, Clark Mortgages Ltd, 1 Grove Street, Wilmslow, Cheshire, SK9 1DU

If we have a legal right not to act on your request, we will inform you accordingly.

If you become aware of any unauthorised disclosure of Your Personal Data, contact us immediately so we can investigate and fulfil our regulatory obligations.

If you have any concerns or complaints, you may contact the UK’s data protection regulator (ICO) via:
🔗 https://ico.org.uk/global/contact-us/
or write to:
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF