Privacy Notice

Who we are?

Fiducia Commercial Network is a trading name of The Fiducia Network Ltd, a company registered in England & Wales. Our register address is Unit 6 Aura Business Centre, Manners Road, Newark NG24 1BS. Our company registration number is 12060834. We are Authorised and Regulated by the Financial Conduct Authority under FRN 917537. We are a credit broker, not a lender.

Fiducia Commercial Network are a data processor and a data controller.

Why should you read this document?

During 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 Your Personal Data.

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, for example your name, address, date of birth, national insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, your physical and mental health history, or any other information that could be associated with your cultural or social identity.

In the context of providing, you with assistance in relation to your Commercial Finance requirements.

Your Personal Data may include:

  1. Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.
  2. Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history.
  3. Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependents.
  4. Health status and history, details of treatment and prognosis, medical reports (further details are provided below specifically about the processing we may undertake in relation to this type of information)

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

In most instances, we will rely on one of the following legal basis’s for collecting and processing Your Personal Data:

  • Contractual necessity
  • Legitimate interest
  • Legal obligation

Alternatively, either during initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided 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 lenders, insurance providers and our Compliance Service Provider, or to contact you to seek feedback on the service you received.

On occasion, we will use Your Personal Data for contractual responsibilities we may owe our regulator, The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.

How do we collect Your Personal Data?

We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during our initial meetings or conversations with. You will provide information to us verbally and in writing, including email.

We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. If we use technology solutions to assist in the collection of Your Personal Data for example software that can verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but 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?

While handling Your Personal Data, we will:

  1. Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (email, hard drives, and cloud facilities). This information can only be accessed by employees and consultants within our firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
  2. Submit Your Personal Data to Regulators and appropriate third parties, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made.
  3. Use Your Personal Data for the purposes of responding to any queries you may have, or to inform you of any developments or regulatory requirements we might become aware.

Sharing your personal data

From time to time Your Personal Data will be shared with:

  1. Regulators, e.g. The Financial Conduct Authority.
  2. Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties may include but may not be limited to, our compliance advisers, product specialists, estate agents, providers of legal services such as estate planners, conveyancing, surveyors, and valuers (in each case where we believe this to be required due to your circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e., to provide you with our professional services.

Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.

We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.

Security and retention of Your Personal Data

Your privacy is important to us, and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.

We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.

Your Personal Data will be retained by us either electronically or in paper form for a minimum period of 6 years following the advice/service you receive from us, although your data could be held for a longer period where this may be needed to meet the requirements of our regulatory bodies.

Your rights in relation to Your Personal Data

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

You can also:

  1. request copies of Your Personal Data that is under our control.
  2. ask us to further explain how we use Your Personal Data.
  3. ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request).
  4. ask us to send an electronic copy of Your Personal Data to another organisation should you wish.
  5. change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety).
  6. Please contact us at compliance@fiduciagroup.co.uk, 01636 614060 and/or Aura Business Centre, Manners Road, Newark NG24 1BS if you wish to make a request.

How to contact our Firm in relation to the use of Your Personal Data

If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:

Compliance Department: compliance@fiduciagroup.co.uk 

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

 

You should also contact us as soon as possible on you becoming aware of any unauthorised

disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.

If you have any concerns or complaints as to how we have handled Your Personal Data, you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Data subject consent form

I hereby grant The Fiducia Network Limited permission to process my personal data for the purpose stated in the Customer Privacy Notice above.

Marketing consent

I, hereby grant The Fiducia Network Limited permission to process my personal data for the purpose of Marketing. By providing your consent, you agree that you have given your express permission for us to

market you regarding products and services that we think may be of interest to you and by any means of

communication that is suitable at the time.

IMPORTANT NOTES: Marketing by our Firm

If you do not indicate your agreement for us to contact you, we may be unable to provide you with details of products and/or services that may suit your needs and circumstances.

 

We would like to maintain a record of your express consent for us to contact you by post, telephone, SMS, email and instant messaging for marketing our products or services that we think may be of interest to you.

 

Please indicate your consent to us contacting you by any of the means specified below:

  • Post
  • Phone
  • SMS
  • Email
  • Instant Messaging – Whatsapp or Similar service