Who is The Key Financial ServicesGroup?
The Key Financial Services Group is a group of limited companies registered in England and Wales.
Key Financial Services (Midlands) Limited – Registration number 04150083
Key Property Services (The Green) Limited – Registration number 04879929
Key Communication Services Limited – Registration number 02857150
Key Estate Agents (The Green) Limited – Registration number 04429339
P O Box 2074
Key Financial Services (Midlands) Limited are regulated by regulated by the
Financial Conduct Authority Number 194318
You can contact us at:
P O Box 2074
What ‘legal basis’ will you process my personal information?
Before we go any further, by process we mean look after and store. The law on data protection sets out a number of different reasons for which a company may collect and process personal information.
We process your personal information in order to provide you with Mortgage and Protection Advice. In this case, the performance of a contract is simple, you ask us for advice on your mortgage and we provide it. We would be unable to provide you with this advice or arrange your mortgage without this information.
We process your personal information in order to provide you with information on property advice on Property Purchase, Sale and Letting. In this case, the performance of a contract is simple, you ask us for advice and information on property and we provide it. We would be unable to provide you with this advice or arrange your mortgage without this information.
We will process your personal information under this condition where our interest in using it is not outweighed by your privacy rights or interests. This means that we can use your personal information only in ways you would reasonably expect and which have a minimal impact on your privacy, or where there is a compelling justification for the processing.
When it comes to staying in touch, we rely on legitimate interests because we only contact existing customers or people who have contacted us directly who are expecting us to do so. Each communication provides an easy to use opt-out.
We may need to process your data in order to fulfil our legal obligations as a Financial Conduct Authority regulated business, as well as being supervised by H M Revenue and Customs for money laundering. For example we may need to verify your identity and comply with anti-money laundering legislation, and co-operate with law enforcement, legal proceedings or regulatory authorities.
What information do you collect?
There are a number of categories of data including Identity Data, Contact Data, Financial Data, Special Category Data (specifically medical history) and Profile and Usage Data.
This involves sourcing the market to find the mortgage that best suits your circumstances. We do this by asking you about your identity and contact details; your product preferences; your property and tenancy history and types and number of occupants and their relationship to you; your lifestyle; nationality and residence status; employment, income and expenditure and other financial circumstances. How you answer these questions will determine what other questions we ask you, because different lenders serve different parts of the market and have different eligibility criteria. We will always explain the process to you and answer any questions you may have about why certain types of information may be needed.
When you apply for a mortgage through us we will collect your direct debit details to pass on to your lender. If the products you select involve a cost, such as a valuation fee, we will ask for your payment information.
Mortgage providers are data controllers in their own right and have their own privacy notices. However, because lenders may automatically profile your information against their lending criteria and against credit reference agencies as soon as your information is forwarded to them this may affect your credit score. We will always bring this to your attention as part of the process so that you are forewarned.
We routinely offer our customers a range of protection solutions. Where customers express an interest in protection, we will also collect information about health, as this may be necessary for the insurers to determine level of cover and premiums.
Estate Agency Customers
We routinely offer our customers a range of housing solutions. We will collect information to allow us to match your housing needs to a product, and also with updates on the housing market, including areas such as current price fluctuations, and where we feel you will be interested in appropriate changes and opportunities. We will collect information that makes the matching of a potential seller and buyer possible, as well as information in relation to the day to day managing of property management.
How will you use my personal information?
As your Mortgage and Protection Adviser, we use your personal information to discuss your personal circumstances with mortgage and protection providers, in order to determine the most appropriate product for your needs. A lender may then undertake credit enquiries upon receipt of your mortgage application. There may be instances where your identity and address is also checked using electronic verification providers.
As your Estate and Managing Agent, we use your personal information to discuss your circumstances with other vendors and buyers in order to view a property and manage the buyer, seller, and tenant and landlord relationship.
Who do we share your personal information with?
We disclose personal information to third parties such as lenders and insurers, but only to a level is necessary to conclude the house purchase, sale, management, mortgage and/or protection contracts and the ongoing servicing of these contracts.
A list of the type of firms this might include is:
A lender, to process your mortgage application
A solicitor or conveyancer, to help process your sale, purchase and / or mortgage application
An estate agent or home builder, again to provide updates to help process your mortgage
application, property purchase or sale
An insurer, to process your protection application
A packager, to help process your mortgage application
A secured loan master broker, if it is felt that a second charge mortgage is more appropriate
for your needs
We will pass your personal information to the Finance Planning Group as they are responsible for the services we provide to you for compliance and monitoring purposes, as detailed our document entitled ‘Important Information About Our Services’.
Also, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations.
For instance, to meet our obligations to the Financial Conduct Authority and when responding to subject access requests, proceedings of a court of law or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.
The personal information you provide will not be passed to any third-party organisation for marketing purposes.
How do you collect my personal information?
Personal data is collected by us using the following methods:
Direct interactions with an adviser in person, by post, phone, email or otherwise when sourcing property and applying for mortgage or protection products.
Automated technologies or interactions with our website, by using the web enquiry form or the quick quote application, QuickStart™.
Third parties or publicly available sources, such as:
Estate agents with whom you may be interacting, but only with your consent. New home builders, as a legitimate interest of the builder in order to assess affordability for the property.
How do we keep your personal information secure?
We understand how important it is to keep your personal information secure. We use a variety of technologies and procedures to protect your personal information from accidental or unlawful breaches of security. These include physical, organisational, and technological security measures.
We also limit access to your personal data to only those Key Financial Services Group staff, appointed representatives, advisers, business partners and suppliers who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you store my information for?
We only retain your personal data for as long as necessary. The list below typically outlines how long data is retained, and depends on the reason the personal data is used for:
Purpose of processing Period
Property Sale, Purchase, Property Management Records – 6 years
Full application, where product goes into force Contract term plus six years
Failed applications, where the product does not proceed 2 years
Enquiries from third parties i.e. an estate agent 2 years
Affordability assessments i.e. property offer validation 2 years
What are my rights?
Here is an overview of your different rights
Your right to access
Access to the personal data we hold about you, free of charge in most cases. The correction of your personal data when incorrect, out of date, or incomplete.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
Right to object
You will have the right to object to how we intend to use your information based on your individual circumstances. If you exercise this right, we may not be able to perform all of our services.
You have an absolute right to object to receiving communications where we do not have a legitimate interest in doing so. For example; you can ask us to stop sending you a quarterly newsletter but we may have a legitimate interest in contacting you during the application process.
Right to complain
You have a right of complaint to the Information Commissioner (The U.K data protection regulatory authority) if you consider any aspect of The Key Financial Services Group’s use of your personal information infringes the law.
Right to data portability
You have the right in some circumstances to have the data you have provided to us sent to you or provided to another person or business in an electronic machine readable format. Where this applies we will download the information and send it as a CSV file.
Right to erasure
You have a right to have some or all of the information we hold about you erased in some circumstances. This is known as the right to be forgotten.
Right of correction
You have the right to have inaccurate information corrected and incomplete information completed. If the information we need to deliver our services to you changes, please tell us about this as soon as possible.
Who can I speak to about my personal information?
If you have any questions or concerns about the way in which we are processing your personal information or would like to exercise one of your earlier mentioned rights, in the first instance please contact our Privacy Officer.
Key Financial Services Group
P O Box 2074
What about when things go wrong?
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113, or go online to ico.org.uk/concerns.
Will this policy change?