Broker Portal - Privacy Notice
This notice describes how we collect, store, use and share personal information.
It applies to personal information provided to us, both by you and by others on your behalf. It also explains the rights you may have in relation to the personal information that we hold about you.
Some of the information listed in this notice won't be personal information, as it will apply to your firm. However, where you are a sole trader or a non-limited liability partnership, your business information would be classed as personal to you. Therefore, to ensure we're transparent, we've included our use of firm-level information in this notice.
1. Who we are
When we say ‘we’ or ‘us’ in this notice we’re referring to Royal London Equity Release” which is a trading name of Responsible Lending Limited. Responsible Lending Limited uses Royal London branding under licence from Royal London Marketing Limited. “Royal London”, the “Royal London logo” and “Royal London Equity Release” are registered trademarks of The Royal London Mutual Insurance Society Limited. Responsible Lending Limited is authorised and regulated by the Financial Conduct Authority and is entered on the Financial Services Register under reference 763158. Registered in England and Wales under company number 09801855.
2. What kinds of personal information can we hold about you?
We may collect and process the following:
- Personal information - for example name and date of birth.
- Contact information – for example email address, fax and phone number(s). We may also have your home address, if you’ve provided this on application forms or this is your correspondence address.
- Information about your business – for example business name, business address, FCA registration number, remuneration address, phone, fax, email and website.
- Financial information – for example bank account details and credit checks.
- Contractual information – for example details of your agency agreement with us and remuneration preferences.
- Transactional information – details of the business you place with us.
- Online information – for example cookies and IP address (your computer’s internet address), if you use our websites or tools.
- Audio recordings – for example voice recording when you contact us. Calls may be recorded for training and monitoring purposes to help us continually improve our customer service and also to protect you and your client’s information.
- Directors’, partners’ and principles’ additional information – for example position at your firm, any other agencies you are or have been linked with and details of your professional standing such as any history of debt, fraud or other criminal offences.
When we collect your information, we’ll let you know if any of it's optional. If it is, we’ll explain why it would be useful to us, and you can decide whether it’s something you’re happy for us to have.
3. How we use your personal information?
We use the information we obtain directly from you for a number of reasons:
Setting up and administering your agency.
Completing any client quotes, applications, amends or requests you make.
Verifying your identity and preventing fraud.
Researching our advisers’ opinions and exploring new ways to meet your needs.
Assessing and developing our products, systems, prices and brand.
Fulfilling any legal or regulatory obligations.
Sending you marketing information
Monitoring the use of our websites.
Where do we get your information from?
Most of the information we receive comes directly from you, or at your instruction from your network, your service provider or industry service providers. We may also get personal information about you from other sources, including:
Financial Conduct Authority – we’ll get information from the Financial Services Register to check the authorisation and permissions of your firm, as well as details of the approved persons(s) under your firm.
Credit reference agencies - we use Experian for sole traders and Creditsafe for companies and networks to verify your identity and conduct a credit check when setting up new brokers and for ongoing due diligence checks. This is to meet our anti-money laundering obligations and to protect against other conduct risks.
Third party cookies - to collect information on how visitors use our website. Our cookie policy can give you more information.
Companies House or other companies who provide access to financial accounts - if we need to verify information on directors, owners or your business, we may obtain information from Companies House or similar companies.
Online resources - if we lose touch with you, we may search for information such as contact details online, so we can get back in touch.
5. What are our legal grounds for using your personal information?
Data Protection gives organisations a number of different conditions to allow us to process your information lawfully.
We’ll only use your personal information when one of these conditions has been met. Below you can see how we use your information and the legal grounds for processing this:
| How we use your information | Legal grounds |
|---|---|
|
Cookies On our website we use 'third party' cookies that collect information about how you use our website. Please see our cookie policy for further information. |
Consent
Your personal information may be processed when we receive your consent. |
|
Setting up and administering your agency This covers:
If we lose touch We may source information such as contact details so we can get back in contact. |
Necessary for the performance of a contract |
|
Verifying your identity and checking creditworthiness
We'll need to check your identity and conduct credit checks when we first start our relationship or where risk indicators are flagged, in an attempt to protect against money laundering or other conduct risks. |
Necessary to protect vital interests |
|
We may disclose your information to the police or other authorities if we have serious concerns about your wellbeing. |
Necessary for compliance with a legal obligation |
|
When an agency applies to join us as an approved adviser, we ask if any of the directors, partners or principals have been convicted of or subject to an investigation relating to fraud, dishonesty or bribery, or been investigated by a professional body. |
Necessary for preventing or detecting unlawful acts |
|
Necessary for Legitimate Interests We also use your information when we have a “legitimate interest”, and that interest isn’t outweighed by your privacy rights. Each activity is assessed, and your rights and freedoms are taken into account to make sure that we’re not being intrusive or doing anything beyond your reasonable expectation. We’ll assess the information we need, so we only use the minimum. If you want further information about processing under legitimate interests, you can contact us using the details below. You also have the right to object to any processing done under legitimate interests. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason, we may still continue to use your information. We use legitimate interests for the following: |
|
|
How we use your information |
Legitimate interest(s) |
|
Assessing and developing our products, systems, prices and brand Our products are developed with a particular set of clients but also with advisers in mind. In order to make sure our plans are still suitable for clients and are working as we intended, we’ll combine customer records, which includes your information as their adviser, to analyse and segment it. We may use your adviser segment details as part of this analysis (see section 10 for more details on adviser segmentation). We also analyse and monitor the business advisers submit. |
We need to be able to identify groups of clients and advisers who might be interested in any new products or services we’re considering. We need to develop those products and services, and make sure they suit yours and your clients’ needs, that they are performing as expected and that our product charges are fair. We need to understand the business that we’re selling to make sure we’re reaching our target markets. We need to make sure we’re treating your clients fairly and check the plans you recommend remain suitable for them. |
|
Researching our advisers' opinions and new ways to meet your needs We may conduct research before we launch new products or before we make changes or improvements to existing products to make sure it’s the right thing to do. we might also conduct research to ask advisers what they think of royal london equity release, our products and our services. |
We need to make sure our products are suitable for the intended audience and to identify gaps in the market. We need to see how many categories of advisers we have and to tailor our products and services accordingly. We need to make sure our communications are easy to understand and that our products are being sold to the correct audience. We need to make sure our research is efficient and connects with the right types of people, so we can be confident of any decisions we make based on the results. |
|
Marketing We market our products to you, so you are able to provide the right advice to your clients. Where these communications are marketing and therefore optional, we’ll make it clear you can opt out. In the future, we'll be looking to
Before we start any new activity, we'll assess how we do this to make sure it’s fair, and that your rights (including your right to object to marketing) are respected. |
We need to grow and sustain our business and develop our brand. |
|
Monitoring the use of our websites On our websites we use a variety of technologies that collect information about how visitors use our website. |
We need to make sure that our websites are secure and work well. |
6. Who do we share your personal information with?
As you’d expect, our employees will access your records in order to use your information for the purposes mentioned above. However, only those employees who need access to particular information are given it. For example, our customer service staff need access to your details to support you when you get in contact, and our research teams will need access to a subset of your information to perform their analysis. We regularly check who has access to our systems.
We may also share your personal information with these third parties:
Our service providers and agents, for example mailing houses for printing, offsite storage companies, confidential waste disposal and IT companies who support our technology.
Our professional advisers: auditors and legal advisers.
ID authentication and fraud prevention agencies.
HM Revenue & Customs, who have powers to ask us for a return detailing all payments to advisers.
Regulators such as the Financial Conduct Authority and other authorities like the Information Commissioner’s Office.
Market research agencies.
Data Brokers, for example Experian, Creditsafe
Your network or service provider, if we've identified unethical behaviour.
7. Overseas Transfers
We do not transfer personal data outside the United Kingdom or the European Economic Area (EEA). In the event that such transfers become necessary in the future, we will ensure that all data remains within the EEA or is subject to appropriate safeguards in compliance with applicable data protection laws.
8. Security
We take the security of information, infrastructure and applications very seriously. Our commitment to Information Security is demonstrated through the implementation of policies, controls and procedures, which are externally certified and audited to international information security standards.
We ensure all suppliers who process your data on our behalf are also certified to suitable information security standards including but not limited to ISO27001:2013.
We have contractual arrangements in place with all of our service providers who process personal data which are compliant with data protection laws. We regularly check that our service providers are complying with their contractual commitments. This includes assessing and reporting on our service providers’ information security controls to check their compliance using questionnaires and/or on-site audits.
9. How long do we keep personal information for?
We’ll keep your personal information for as long as it’s considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your relationship with us has ended.
In the absence of specific legal, regulatory or contractual requirements, information relating to you in our adviser records will be retained for seven years after the end of your relationship with us. Your information which is included within your client’s mortgage will be kept for seven years after the client’s mortgage has ended, where we deviate from this, we will advise you accordingly.
10. Do we make solely automated decisions about you or profile you?
Automated decisions are where a computer makes a decision about you without a person being involved. We do use credit reference agencies to check your credit report, which we then score using our own rules, but there's always a person involved in this assessment.
11. What are my rights?
Your rights are outlined below. The easiest way to exercise any of your rights would be to contact our Data Protection Officer using the contact details below in section 15 – Contact us. We’ll provide a response within 30 days, if not sooner. There’s normally no charge for exercising any of your rights.
Accessing your personal information
You have the right to find out what personal information we hold about you, in many circumstances.
Correcting or adding to your personal information
If any of your details are incorrect, inaccurate or incomplete you can ask us to correct them or to add information.
Data portability
In some circumstances you can ask us to send an electronic copy of the personal information you have provided to us, either to you or to another organisation.
Objecting to the use of your personal information for legitimate interests
You also have the right to object to any processing done under legitimate interests. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason, we may still continue to use your information.
Objecting to direct marketing
You have a specific right to object to our use of your information for direct marketing purposes, which we’ll always act upon.
Restricting the use of your personal information
If you’re uncertain about the accuracy or our use of your information, you can ask us to stop using your information until your query is resolved. We’ll let you know the outcome before we take any further action in relation to this information.
Right to erasure
In some circumstances you can ask us to delete your personal information, such as if your agency agreement has ended and we don’t need to keep your information for legal or regulatory reasons. If we’re using consent to process your information and you withdraw it, you can ask us to delete your information.
12. Right to complain to the supervisory authority
If you’re unhappy with how we’re using your information, you have the right to complain to the Information Commissioner’s Office. We’d encourage you to contact us first, so we can help with your concerns.
The Information Commissioner’s Office can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
13. Changes to the way we use your information
If we want to use your personal information for a new purpose which we haven’t previously told you about, we’ll contact you to explain the new use of your information. We’ll set out why we’re using it and our legal reasons.
14. Changes to our privacy notice
Making sure that we keep you up to date with privacy information is a continuous responsibility and we keep this notice under review. We’ll update our notice as changes are required.
This privacy notice was last updated March 2024.
15. Contact us
If you have any questions or comments regarding this privacy notice, or if you’re not happy with the way we use your information, please contact us using the details below.
Post: Data Protection Officer, Royal London Equity Release, Customer Support, Royal London, P.O. Box 277, Sheffield, S98 1RP
Email:info@royallondonequityrelease.com
Phone:0330 124 3914