Data Protection & Complains Policy

How we will handle your personal data and protect your privacy.

A guide to how we meet the requirements of the Data Protection Act.

Making sure personal data is secure and properly dealt with is of paramount importance in our dealings with you. It is therefore important you understand what information we will take, why we need it, and how we will process your details.

Who will process my data?

Later Life Freedom is a trading style of All You Need Mortgages Limited and an appointed representative of HL Partnership Limited which is authorised and regulated by the Financial Conduct Authority. As such, both Later Life Freedom and HL Partnership Limited will process your data in order to provide our services.

What data will you ask me for?

In order to fully understand your financial needs and be able to give good advice, we need to obtain information about you, your family, your personal circumstances, and your preferences. Some of the information will be private and may be sensitive, such as details of your income and expenditure, health, debts and credit commitments, legal proceedings and adverse credit. Much of the information you provide will need to be passed on to the companies whose products you apply for.

Do I have to provide my personal data?

In order for us to be able to give you suitable advice, we need you to provide all the information we ask for as openly and honestly as possible. If you prefer not to disclose some information, please tell us that you prefer not to disclose it and we will assess whether this will alter or impede the work we are doing for you.

How will you use my data?

1. The primary reason we will use your data is to allow us to do the job you’ve asked us to do.

Specifically, we will use your data to:

• Assess and provide advice to meet your needs and circumstances;

• Introduce you to a range of product and service providers in order to meet your requirements;

• Administer cases and assist processing of applications;

• Tell you about any changes to products and service we have arranged for you;

• Inform you about products and services we think may be suitable for you (unless you ask us not to send you this information).

2. We may also process your information in order to meet our legal and regulatory requirements. These may include:

• Complying with the regulations set out by the Financial Conduct Authority and other regulators as required;

• Preventing financial crimes such as money laundering and fraud by passing your details to other relevant bodies such as the police and National Crime Agency where required.

3. We may also process your personal data for our own legitimate interests. Typically, these would be limited to:

• Analysing our business for trends and research how we can improve our services to customers;

• Reviewing the work we have carried out for you to ensure we have met the regulations and quality standards;

• Ensuring we are able to exercise or defend legal challenges in the future.

4. HL Partnership Limited will use your data to monitor and assess our work to ensure we have provided a high standard of service and met our legal and regulatory commitments.

How long we will store your data?

We will only keep your personal information as long as necessary. How long that is depends on the type of data and the nature of the work we have carried out. In most cases, your personal data will be stored for an indefinite period as we need to keep evidence that we have fulfilled our legal and regulatory requirements.

Can I see a copy of my personal data?

Yes. Please write to our Data Controller (details below) and we will provide a copy of any personal data we hold about you within one calendar month of receiving your request. Please note that we may need to verify your identity before providing the information.

What if my data is incorrect or incomplete?

You have the right to have your data corrected or completed by contacting our Data Controller in writing (details below). Please be aware that we need to maintain records of information as it was at the time of the advice or the transaction taking place.

Can I have my data erased?

If we have provided you with advice or processed a transaction on your behalf, we will not normally be able to erase your personal data. This is because we are obliged to maintain records of our advice and transactions to meet our regulatory requirements and in case we need to exercise or defend legal claims in future.

Who is the Data Controller?

How can I get more information?

If you would like further details on how we use your personal information or if you have any data protection queries, please write to:

The Data Protection Officer, HL Partnership Limited, 2nd Floor Unit 1, Southern Gate Office Village, Chichester, West Sussex, PO19 8GR

Telephone: 01903 602664

Email: compliance@hlpartnership.co.uk

If you’d like to make a complaint about how we have handled your personal data…

…please write in the first instance to The Data Protection Officer at the above address.

If you are not satisfied with the Data Protection Officer’s response, you can make a complaint to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

Email through their website at: https://ico.org.uk/concerns/

Important Notes on Protecting your own Data

Please be aware of cybercrime and protecting your own information online, particularly financial information. Do not send unsecure personal information over the internet. We recommend you use encryption software or provide any information to us using the online tools we provide.

Do not respond to emails asking you to pay money. Never make a payment purely in response to an email. Always call the company to validate any payment requests and check the phone number independently from the email (i.e. via a secure web site). If you receive a phone call asking for payment ensure you are satisfied the call is genuine, or else call the company back to check. Neither All You Need Mortgages Limited nor HL Partnership will take responsibility if you transfer money to a fraudster in error.

Later Life Freedom – Customer Complaints Procedure

Hopefully all your dealings with HL Partnership Limited and our Appointed Representatives will be positive experiences. However, sometimes things go wrong and if that happens, we operate a structured Complaints Procedure to ensure we get things back on track as quickly as possible.

This document is a summary of that procedure which is designed to ensure any complaints are dealt with in a professional manner, are handled fairly, effectively and promptly, and are resolved at the earliest possible opportunity.

Our commitment to you…

1. We will endeavour to resolve your complaint as quickly as possible and will work within the following timescales:

• Three Business Days – Once we receive your complaint, if we are able to resolve the matter by close of business on the third working day following its receipt, we will simply do so and advise you in writing with our Summary Resolution Communication.

• Five Business Days – If we are not able to resolve the matter as above, we will write to you within five business days acknowledging your complaint, confirming our understanding of the situation, and providing you with the name of the individual handling the complaint.

• Four Weeks – If we haven’t been able to resolve the complaint sooner, after four weeks we will send you either our Final Response letter (please see below) or a progress report explaining why we are not yet in a position to resolve the complaint.

• Eight Weeks – If we still haven’t been able to resolve the case before hand, at eight weeks we will send you either our Final Response letter (please see below) or an explanation why we are not yet in a position to resolve the complaint, giving the reason for the delay and indicating when we expect to be able to provide a final response.

PLEASE NOTE: A business day is a Monday to Friday between 9am and 5pm, excluding bank holidays. When a complaint is received on a non-business day, or on a business day outside business hours, we will treat the complaint as being received on the next business day.

2. We will ensure the person dealing with your complaint has the required skill, knowledge and authority to respond to your complaint. Our staff are fully trained, and we operate a structured and robust complaints procedure to ensure all complaints are dealt with fairly.

3. We will ensure the letters we send are clear and explain things properly. When we resolve a complaint, you will either receive:

• Summary Resolution Communication – Where we have been able to resolve a complaint within three business days, we will issue a Summary Resolution Communication explaining that we believe the complaint to be resolved. This will include details of how to escalate the case if you remain dissatisfied.

• Final Response Letter – Once we have completed an investigation, we will issue our Final Response Letter to you. This will detail the complaint, explain our investigation, and confirm our findings. The Final Response letter will either ‘Uphold’ your complaint or ‘Reject’ your complaint and explain why. If there is any settlement or redress awarded, an explanation of how this was calculated will also be included.

We will give you access to the Financial Ombudsman Service which is a free service set up by Parliament to sort out individual complaints that consumers and financial businesses are not able to resolve themselves.

If, once we have issued a Summary Resolution Communication or Final Response Letter (or after 8 weeks if we have yet to issue a Summary Resolution or Final Response letter), you remain dissatisfied with the outcome of our investigations, you may have the right to approach the Financial Ombudsman Service within 6 months of the date of the letter.

If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances.

Details of how to get in touch with The Financial Ombudsman Service will be issued with our Summary Resolution and Final Response letters along with a leaflet explaining how the service works. If you require more information, the Financial Ombudsman Service can be contacted as follows:

Address:

Financial Ombudsman Service

Exchange Tower

London

E14 9SR

Telephone: 0300 123 9123

 Website: www.financial-ombudsman.org.uk

Your commitment to us…

In order to help resolve complaints as quickly and fairly as possible, we ask the following:

Tell us what happened – We need to understand the situation as clearly as possible so we may ask you to provide your side of the story or let us have documents and information which may help our investigation. These can be provided by post, email, verbally or through any other means that you prefer.

Help us find the right solution – It is in everyone’s interests to get complaints settled amicably so if there is a particular outcome you believe would be suitable, tell us and we will assess if this is possible. We may not be able to resolve the case the way you would like but we can try. And if we can’t, we will explain why it is not possible and offer an alternative solution.

Respond to us as soon as you can – Hopefully we won’t need to come back to you too often but we may need further information or clarity on certain points. If we do need more information, we simply ask you to come back to us as soon as you can so that we can get things resolved quicker. If you can’t come back straight away, that’s fine too – just let us know.

Treat us with respect – Whilst it can be frustrating if something’s gone wrong, our job is to find out what happened and where appropriate, put things right. Our staff will do everything we can to help so we ask you give them the time to do their work and treat them with respect.

How to Complain

If you wish to register a complaint, you can do so by contacting our Complaints Department using the following methods:

By post:

The Complaints Department

HL Partnership Limited

2nd Floor, Unit 1

Southern Gate Office Village

Southern Gate

Chichester

West Sussex

PO19 8SG

By email: complaints@hlpartnership.co.uk

By telephone: 03300 552 651