Our Privacy Policy - your rights, your information and how we use it

McCrea Financial Services is committed to protecting your personal information.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy; so please check our website for updates from time to time. If there are important changes such as changes to where your personal data will be processed; we will contact you to let you know.

This version of our Privacy Policy was last updated 1 November 2021.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact;

FAO The Data Protection Officer
McCrea Financial Services Ltd.
Moncrieff House
3^rd Floor, 69 West Nile Street
Glasgow
G1 2QB

Email: enquiries@mccreafs.co.uk

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 Investment, Mortgage and Insurance requirements Your Personal Data may include:

•            Title, name, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
•            Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/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, medical reports (further details are provided below specifically with regard to the processing we may undertake in relation to this type of information)
•            Any pre-existing investment, mortgage and 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 investment, mortgage and 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 in the course of 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 mortgage lenders, insurance providers and our Compliance Service Provider relating to the advice we have given to you, or to make contact with 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.

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

Where you ask us to assist you with, for example, your insurance or ethical investments; in particular life insurance and insurance that may assist you in the event of an accident or illness, we may ask you information about your ethnic origin, your health and medical history (Your Special Data). We may record and use Your Special Data in order to make enquiries of insurance or investment providers in relation to insurance products that may meet your needs and to provide you with advice regarding the suitability of any product that may be available to you. 

If you have parental responsibility for children under the age of 13, it is also very likely that we will record information on our systems that relates to those children and potentially, to their Special Data.

The arrangement of certain types of insurance may involve disclosure by you to us of information relating to historic or current criminal convictions or offences (together “Criminal Disclosures”). This is relevant to insurance related activities such as underwriting, claims and fraud management.

We will use special Data and any Criminal Disclosures in the same way as Your Personal Data generally, as set out in this Privacy Notice.

Information on Special Category Data and Criminal Disclosures must be capable of being exchanged freely between insurance intermediaries such as our Firm, and insurance providers, to enable customers to secure the important insurance protection that their needs require.

What are cookies?

A cookie is a small file – it’s saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example - they will remember you've visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don't have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and market our products and services.

• Persistent cookies - these stay valid, and will work until their expiry date (unless you delete them before they expire)
• Session cookies - these expire when you close your web browser

Our cookie policy can be accessed by clicking on the ‘Privacy Policy’ link on our Home Page.

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 the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to investment, mortgages and insurance.  You will provide information to us verbally and in writing, including email.

We may also obtain 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 is able to 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?

In the course of handling Your Personal Data, we will:

•            Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, 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.
•            Submit Your Personal Data to Product Providers/Mortgage Lenders and Insurance Product providers, both in paper form and on-line. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
•            Use Your Personal Data for the purposes of responding to any queries you may have in relation to any investment, mortgage product or insurance policy you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.

Who we may share your information with

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

• Investment providers, Mortgage lenders and/or Insurance providers
• 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 will 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 particular circumstances).

In each case, Your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your investment, mortgage or insurance enquiry and 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. 

Where your information is processed

The majority of your information is processed in the UK and European Economic Area (EEA).

How we protect your information

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.

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 individual rights

You can:

•          request copies of Your Personal Data that is under our control
•          ask us to further explain how we use Your Personal Data

•          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)
•          ask us to send an electronic copy of Your Personal Data to another organisation should you wish

•          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)

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please contact us and we will do our utmost to make things right.

If you are still unhappy, you can complain to our Supervisory Authority. Please contact the UK-ICO on their helpline 0303 123 1113.