PRIVACY AND COOKIE POLICY

The Openwork Partnership ("We") are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting www.theopenworkpartnership.com you are accepting and consenting to the practices described in this policy.

Data Protection

Collecting information and protecting your privacy

Our aim is to offer advice that helps you plan your financial future. To provide such advice, we need to know about your personal situation and your Adviser may request sensitive and private information about you, for example, your income, current financial arrangements, health, family commitments and any legal proceedings you may be involved in. Much of the information you provide will, as part of your application, be passed to the company whose products you apply for and details of how they use your information are included in their data protection literature.

If you are unable or unwilling to provide some, or all, of this information your Adviser will be unable to provide you with advice suitable for your circumstances. We do not collect personal information from third parties.

We are committed to protecting your privacy. As we would like you to be a lifetime client, we need to earn your trust and assure you that we will keep your personal information confidential and secure and only for as long as is necessary. The criteria we use to determine how long this period is can be obtained from Openwork’s Data Protection Officer at the address below.

We will use it with care and it will only be shared in the ways explained here, or if we are required to by Law or the Financial Conduct Authority (FCA).

Your personal information will only be held for as long as necessary and collected for the purposes of providing advice in respect of the range of products and services outlined in the Initial Disclosure Document or Client Proposition Brochure provided by your Adviser. In addition, we will make every effort to ensure that the information you provide is recorded accurately and that it is only passed to companies who comply with the General Data Protection Regulations (GDPR). If it is required to send your information abroad, we will only do so to countries within the European Union (EU) or to a third country that the EU has determined provides an adequate level of protection and where you are able to exercise your rights to access your personal information under the GDPR.

Controlling and using your personal information

A Data Controller is someone who determines the purposes for and the manner in which your personal data should be processed. Openwork, its Appointed Representatives (your Adviser) and the companies whose products you buy are all Data Controllers. Your Adviser will have given you their contact details and Openwork’s contact details are shown below.

We use your information in a variety of ways:

• To introduce you to a range of products and services offered by the companies we are associated with (or may be associated with in the future).
• To help with administration.
• To contact you with details of changes to products you have bought.
• For business analysis and research.
• For marketing products and services we think may be suitable for you (unless you ask us not to send you this information).
• To comply with the Law and/or FCA requirements.
• To verify your identity by searching publicly available records held by credit reference agencies.
• To prevent fraud and money laundering we may pass your details to other companies, public bodies including the police or to an insurer’s database. Insurance companies can search databases for any relevant information that exists about you.

We therefore process your data because it is necessary for:

• the performance of a contract to which you are a party.
• compliance with legal obligations to which we as the controller are subject.

None of the information gathered about you will be used in automatic decision making.

Your health details

If you apply for some types of insurance (eg. life insurance, pensions, sickness etc.) you will be required to provide details of your health. Under the GDPR, this is regarded as sensitive personal data.

Your Adviser will have access to your medical details unless you prefer to complete a medical statement of health in private. If this is the case, please send it with your application marked for the attention of the “Consultant Medical Officer” in a sealed envelope.

We do need your explicit consent to collect and process your health details, which of course you may withdraw at any time.

Mortgage credit checking

If you apply for a mortgage your information will be passed to the lender, who will carry out a credit check. You will also have to provide details of any criminal convictions you may have had. These details will be passed to the lender to carry out any necessary checks.

Marketing and sharing your information

The information you give us will be added to any other details we hold about you. Openwork will never sell your details to a third party, but we may share your information with carefully selected companies we are associated with. Therefore, we (or they) may contact you (by post, email, telephone or other appropriate means) to tell you about products, services or offers we believe may interest you. The products and services may not be related to financial services. You can ask us not to contact you for this reason, at any time, by writing to us at our Head Office. This will not affect your relationship with your Adviser.

We may have to pass your details to another Adviser if, for example your Adviser is ill or you need advice in a different product area. If your Adviser leaves we may pass your details to another Adviser so that we can continue to provide you with a high standard of service.

We may send your information to third parties that are carrying out work on our behalf.

Your Data Protection rights

You have certain rights under the GDPR. These include the right to:

• Ask for a free copy of your personal information in a portable format.
• Stop us sending you marketing material about products and services.
• Have any incorrect information we hold about you corrected.
• Ask us to restrict processing of your personal data.

As the processing of your personal information is necessary for a legal obligation placed upon us by the FCA and may be required for the establishment, exercise or defence of legal claims, we will not be able to permanently delete your personal information until the end of the period we have deemed necessary.

How to 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
The Openwork Partnership
Auckland House
Lydiard Fields
Swindon
SN5 8UB

You may receive more information about data protection from the companies that we have introduced you to.

We may record telephone calls so we can check we have acted on your instructions correctly and to ensure we are giving you appropriate service. We may also monitor calls for security and training purposes.

Complaints

If you have any complaints about the way we or your Adviser have handled your personal information, please contact the Data Protection Officer at the address given above.

You also have the right to refer your complaint to the Information Commissioner.

The Openwork Foundation

The Openwork Foundation takes data privacy very seriously. Please click here for details of their privacy policy and how they use any data you may provide to the Openwork Foundation.

 

Non-personally identifiable information we collect. 

Cookies. A Cookie is a file of letters and numbers. These types of files are either stored in the memory of your computer or other device such as mobile phones or tablet devices (these cookies are generally known as session cookies) or are placed on the hard drive of your device (generally known as persistent cookies).

For more details about cookies and details of how to delete and disable cookies you can visit www.allaboutcookies.org and also see our section on more information and turning cookies off below.

How do we use cookies? 

• For site performance - Google Analytics
• For embedded videos - YouTube 
• For Social media feeds - Twitter

 

Google Analytics

Google Analytics cookies: utma, utmc, utmb, utmz

We may use these cookies to track the use of our site to help us determine which webpages are visited and where the traffic comes from around the world. This is an anonymous cookie and does not collect any user personal information. The Information Commission considers this to present a low level of intrusiveness or risk of harm. We see this cookie as essential to ensure the website content is relevant and accurate. If you do not wish to accept the cookie please do not use our web site. See the Google site for further information http://www.google.com/analytics/learn/privacy.html.

YouTube

Youtube cookies: VISITOR_INFO1_LIVE, use_hitbox, PREF

We may use YouTube to host video content. When you view a web page on our site with an embedded YouTube video, YouTube creates at least three cookies. For further information on these cookies please visit: www.youtube.com

Web server logs: We will utilise standard technology called web server logs to collect information about how the website is used. Information gathered through web server logs may include the date and time of visits, the pages viewed, time spent at our website, the websites visited just before and just after our website and the IP address of the device being used. This information is analysed by us on an aggregate basis to give information on how the website is used, we do not use this information to track individual behaviour. We delete web server logs after a period of three months. We keep the weblog analysis for a longer period, but this analysis will not contain information that identifies you as an individual.

 

Technical information we collect.

We collect certain information regarding the device from which you access the website. This includes details of the operating system, browser, and screen resolution.

We may request and collect information for the following purposes:

• internal record keeping;
• to improve our products and services this may involve using the information in training sessions;
• to follow up, either by e-mail, phone, fax or mail, as part of our customer care procedures;
• to periodically send promotional e-mails from us (or on behalf of someone else) about new products, special offers or other information which we think you may find interesting using the e-mail address which you have provided;
• From time to time, to contact you for market research purposes. We (or an organisation appointed by us) may contact you by e-mail, phone or mail. If you would prefer not to receive marketing information, you may opt out by clicking on the link at the bottom of each email to manage your preferences or by emailing marketing@mortgage-brain.co.uk
• to share within our group of companies for the purposes set out above.

We may also disclose your information to our appointed third party agents and suppliers in order to process your order. These third parties will only have access to your information in order for them to perform specific tasks related to your order and they may not use it for any other purposes.

We may also pass your information on to financial organisations, credit reference agencies and tracing agencies.

We may disclose your information to our professional advisers for the purpose of obtaining professional advice or to other third parties if we have a legal obligation to do so. We may also disclose your information to a purchaser in the event of a sale of the whole or a relevant part of our business. We reserve the right to monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, regulation, legal process or governmental request.

We may disclose your information to other organisations whose business is the processing of information. We may also pass information on to the media.

We may provide access to your personally identifiable information when legally required to do so by law.

This website is operated wholly within the United Kingdom and no personal data collected by this website will be exported outside the United Kingdom.

 

How long do we keep the information?

We will keep your information for a period of 6 years after it has been collected.

 

How do I manage my information?

Should you wish to check what personal information we hold, please email GDPR@mortgage-brain.co.uk

 

Data Security

We take all reasonable steps to maintain the security of the personally identifiable information that we collect. The service is operated on our behalf by one of our internet service providers from a data centre with industry standard physical and logical access controls. However, no data transmission over the Internet can be guaranteed to be completely secure. Accordingly, we cannot ensure or warrant the security of any information that you transmit to us, so you do so at your own risk.

 

Security

We are committed to ensuring have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect on line.

 

Other Websites

This website may contain links to third party sites as well as to other sites owned and/or operated by us. Please be aware that we are not responsible for the privacy practices of any third party sites. This Privacy Policy applies solely to information collected by this website.