About Responsible Life
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:
Units 11-24 4A Mills Bakery
Royal William Yard
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.
What information do we collect about you and why?
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, www.responsiblelife.co.uk. 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.
How will we use this information?
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
Information from other sources
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.
Contact details received from a third-party Introducer or Lead Generator
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:
Date of Birth
The lawful basis on which we use this information
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.
Children’s Online Privacy Protection Act Compliance
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.
Who will it be shared with?
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.
What we will do to ensure the security of personal information
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.
How long will we retain your data?
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.
What are your rights?
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.
Website Banner Marketing
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.
Right to complain
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.
Changes to the information
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.
Or in writing to:
The Data Protection Officer
Responsible Life Ltd
Units 11-21, Mills Bakery
Royal William Yard
The previous Privacy Notice was dated 07/02/2017. This Privacy Notice was last updated on 20/11/2019.
Policy for Responsible Life
What Are Cookies
For more general information on cookies see the Wikipedia article on HTTP Cookies…
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser ‘Help’ for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.
The Cookies We Set
When you submit data to us through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third Party Cookies
This site uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.
For more information on Google Analytics cookies, see the official Google Analytics page.
Third party analytics are used to track and measure usage of this site so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or pages you visit which helps us to understand how we can improve the site for you.
From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst on the site, whilst ensuring we understand which optimisations our users appreciate the most.
The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.
For more information on Google AdSense see the official Google AdSense privacy FAQ.
We use adverts to offset the costs of running this site and provide funding for further development. The behavioural advertising cookies used by this site are designed to ensure that we provide you with the most relevant adverts where possible by anonymously tracking your interests and presenting similar things that may be of interest.
In some cases, we may provide you with custom content based on what you tell us about yourself either directly or indirectly by linking a social media account. These types of cookies simply allow us to provide you with content that we feel may be of interest to you.
Several partners advertise on our behalf and affiliate tracking cookies simply allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately and where applicable allow our affiliate partners to provide any bonus that they may provide you for making a purchase.
Hopefully that has clarified things for you and as was previously mentioned, if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However, if you are still looking for more information you may contact us using the information below.
Or in writing to:
The Data Protection Officer
Responsible Life Ltd
Units 11-21, Mills Bakery
Royal William Yard