How we act for you
TCF Financial Planning Limited is authorised and regulated by the Financial Conduct Authority. Our Financial Services Register number is 574501. You can check this on the Financial Services Register by visiting the FCA’s website www.fca.org.uk/register or by contacting the FCA on 0800 111 6768. The FCA is the independent watchdog that regulates financial services. Use this disclosure document to decide if our services our right for you. It explains the service we offer and how you will pay for it.
We “TCF Financial Planning Limited” can act for you “the Client” if you live in the UK. There may be restrictions on how we can advise you if any of the following apply:
- You don’t live in the UK;
- You are currently staying in the UK, but normally live abroad; AND
- You are currently staying in the UK and plan to move abroad or return to another country.
Please ask us for details if you think this may apply to you.
Our service and permitted business includes advising and arranging mortgages and insurance products as stated below.
All information we provide will be made clear and accessible to you. You will also be given the choice to receive the information relating to any insurance products in paper format, free of charge. If you would like a paper copy at anytime then please let us know.
Our Services – Insurance
We act as an Independent Intermediary on behalf of our customers. We will advise and make a personal recommendation to you after we have assessed your insurance needs.
We advise on products from a fair and personal analysis of the market for term assurance, critical Illness and income protection. We also advise products from a limited number of insurers for buildings and contents, accident sickness and unemployment and private medical insurance. Ask us for a list of insurers we offer insurance from
Our Services – Mortgage
We will advise and make a recommendation to you on residential mortgages, further advances, consumer buy to lets after we have assessed your needs.
We offer a comprehensive range of mortgages from across the market, but not products that you can only obtain by going direct to a lender
Alternative Finance Options
Note: If you are looking to increase your borrowing on an existing mortgage then there are a few options available to you, including:
- Further advance with your existing Lender;
- Second charge regulated mortgage;
- Unsecured lending, such as a personal loan.
We are required to inform you of the alternative options available to you so that you can consider them against your personnel circumstances. We will not provide advice on whether Second Charge Regulated Mortgages or unsecured lending are more suitable for you. We will however provide advice on further advances.
Communications
If we need to contact you, we can write, email, fax, SMS or phone you. Please let us know which method you prefer. If you verbally ask us to do some thing for you, we will confirm this to you in writing to ensure that we have understood your instructions correctly. If we give you advice, we will normally confirm it to you in writing.
How we are paid for our services
A fee of £250 will be payable on completion of the mortgage. So it matches the disclosure statement at the foot of the home page. We will also be paid commission from the lender. You will receive a European Standardised Information Sheet (ESIS) when considering a particular mortgage which will tell you about any fees relating to it. It will also include the actual amount of commission we will receive.
In providing the service we do not charge a fee for Insurances; once the application is accepted and cover commences we are remunerated a percentage of the total premium from the Insurer. In the event that you do not maintain your premiums or cancel your policy within 48 months we may have some of that remuneration reclaimed by the Insurer. In this event we will charge you an amount equal to the remuneration which has been reclaimed.
Provision of information by you
We seek to ensure that any personal information we hold about you should remain accurate and up to date; as this could affect the advice we give you. Therefore, please let us know if there are any significant changes to your personal details, when they occur.
I must advise you of your duty when instructing us to place or renew insurances on your behalf, to answer questions fully and accurately. Failure to disclose facts that are likely to influence an Insurer’s decision whether or not to accept the risk and on what terms and at what premium (such as, but not limited to, pre-existing medical conditions) could result in the non payment of claims and voidance of your policy.
If you have any doubt about whether a fact would be important in the acceptance of your application and before your cover starts, please include it.
We recommend that you keep a record of all information supplied to us. You are also entitled to ask for a copy of our standard terms of business and a copy of your completed application form at any time.
It is your responsibility to provide complete and accurate information to us and Insurers when you take out an insurance policy, throughout the life of the policy and when you renew your insurance. Failure to disclose facts; pertaining to your insurance, or any inaccuracies in information given, could result in your insurance being invalid or cover not operating fully. It is important that you ensure all statements you make on Proposal Forms, Claim Forms and other documents are true, full and accurate. If a form is completed on your behalf, you should check that the answers shown to any questions are true and accurate before signing the document.
A credit search on behalf of the chosen mortgage lender will be submitted and may leave a footprint on your credit profile. The mortgage application will not be submitted until all the supporting documentation is received. The implication on any delays with the supporting documentation may involve Interest rate changes and potentially change of mortgage lender.
Termination of Authority
You or we may terminate our authority to act on your behalf at any time, without penalty. Notice of this termination must be given in writing and will take effect from the date of receipt. Termination is without prejudice to any transactions already initiated, which will be completed according to the Terms of Business unless otherwise agreed in writing. You will be liable to pay for any transactions made or carried out prior to termination and any fees which may be outstanding. You have 30 days from the date you receive this information to cancel your policy. If you cancel your policy your cover will cease with no further action.
Data Protection
The information you have provided is subject to the Data Protection Act 1998 (the “Act”). You have provided your consent during our telephone conversation for us or any company associated with us (such companies include, for the avoidance of doubt, Life Assurance and General Insurance product providers) to process, both manually and by electronic means, your personal data for the purposes of providing advice, administration and management.
“Processing” includes obtaining, recording or holding information or data, transferring it to other companies associated with us, product providers, the FCA or any other statutory, governmental or regulatory body for legitimate purposes including, where relevant, to solicitors and/or other debt collection agencies for debt collection purposes and carrying out operations on the information or data.
We may also contact you (including by telephone) with details of any other similar products, promotions, or for related marketing purposes in which we think you may be interested
We will NOT pass on your details to other (third party companies) for marketing purposes.
The information provided may also contain sensitive personal data for the purposes of the Act, being information as to your racial or ethnic origin; physical or mental health condition; the commission or alleged commission of any offence by you; any proceedings for an offence committed or alleged to have been committed by you, including the outcome or sentence in such proceedings; your political opinions, religious or similar beliefs, sexual life; or your membership of a Trade Union.
You have confirmed your consent to us or any company associated with us processing any such sensitive personal data
You have confirmed that you are happy for us to contact you for marketing purposes by e-mail, telephone, post or SMS
If at any time you wish us or any company associated with us to cease processing your personal data or sensitive personal data, or contacting you for marketing purposes, please contact The Data Protection Officer on 0845 0543898 or in writing at TCF Financial Planning Limited, The Old Rectory, Main Street, Glenfield, Leicestershire. LE3 8DG
Complaints Handling
It is our intention to provide you with a high level of customer service at all times. If there is an occasion when we do not meet these standards and you wish to register a complaint please contact us by:
…in writing: Write to TCF Financial Planning Limited’s Complaints Department The Old Rectory, Main Street, Glenfield, Leicestershire LE3 8DG
…by phone: Telephone 0845 054 3898
If you cannot settle your complaint with us, you may be entitled to refer it to the Financial Ombudsman Service. www.financialmbudsman.org.uk
Financial Services Compensation scheme
We are covered by the FSCS. You may be entitled to compensation from the scheme if we cannot meet our obligations. This depends on the type of business and the circumstances of the claim.
Insurance advising and arranging is covered for 90% of the claim, without any upper limit.
Where the firm has not taken steps and caused a contract not to be effected by an Insurer on a Pure Protection Policy or General Insurance claim arising from the death or incapacity of the policyholder owing to injury, sickness or infirmity, then 100% of the claim is covered.
Mortgage advising and arranging is covered up to a maximum limit of £50,000.
Further information about the compensation scheme arrangements is available from the FSCS.
Client Consent
These terms of business will be interpreted and construed in accordance with English law and is subject to the exclusive jurisdiction of the English courts, except if your address is in Scotland, when the courts of Scotland shall have non-exclusive jurisdiction.
This is our standard Terms of Business upon which we intend to rely. For your own benefit and protection you should read the terms carefully. You have confirmed your acceptance to the terms contained within this document during our telephone conversation, including the transfer of information between parties as described above. If there are any terms within this agreement that you do not understand, please ask for further information.
What information do we collect about you and why?
As a Brokerage and as part of our service we will only collect information from you so that we can advise and arrange products that maybe suitable for you. In the financial services industry we call this factfinding which provides us with all the information that we need from you in order to provide you with a suitable product that meets your circumstances and requirements.
When obtaining information from you we will do this by phone, email or post and will confirm the accuracy of the data collated. It is important that all the data we hold on you is accurate so that we can advise the most suitable products to you.
The types of information we will collect from you includes; contact details, occupation, income and expenditure, credit details, mortgage requirements, insurance requirements, existing policies, solicitors/accountants details, bank details. In addition, we may collect sensitive personal data such as medical conditions or criminal offence data where required to do so to arrange a policy on your behalf.
Where you provide your personal data on our website it will be taken as a positive action that you would like us to contact you for the purpose as set out on our website.
Contact details received from a third party lead generator
We may obtain information from other sources such as public records, if required. This is to enable us to verify who you are or facts that you have told us are accurate.
Information from other sources
We may obtain information from other sources such as public records, if required. This is to enable us to verify who you are or facts that you have told us are accurate.
How we will use this information
We will only use your data in ways that you would reasonably expect us to. Below summarises how we will use your data.
We will use the information you provide to us to research the market on your behalf to find a suitable policy that meets your circumstances and needs. Once we have carried out research we will provide you with a personalised illustration detailing the product information. Whilst you consider the illustration, we will remain in touch to answer any questions you may have.
If you are happy to proceed we will then use your data to complete an application form which will then be forwarded to the relevant Lender or Insurer. We will then liaise with them on your behalf until the policy has been arranged.
We will then contact you at renewal or when your policy is due to be reviewed so that we can continue to ensure that the policy you have in place remains suitable. Where your circumstances or personal information have changed we will update our records and notify the Lender or Insurer to do the same.
We will also use your data to assist you handle any claim you have on your policy or with handling a complaint if you are not happy with the service you have received.
As part of our service we like to keep our customers up to date with new products or offers that are available and maybe of interest. Therefore, we may contact you from time to time through email marketing, phone, text or other types of marketing material. If you wish to opt out of this at any point, then please let us know.
In the interest to improve our services, telephone calls may be monitored and/or recorded for training purposes and to assist us handle a claim or complaint. Where we record the call, you will be informed of this.
The lawful basis on which we use this information
How we use your information (detailed above) we will do so using the lawful basis legitimate interests. We have decided upon this basis as it allows us to meet with the ICO and FCA rules and is the most suitable lawful basis for processing data with a view to arranging a policy.
Who will it be shared with?
As stated above, if you wish to proceed to take out a policy then we will pass your details on to the Lender or Insurer the policy will be arranged with. The information we pass on will be detailed within the application we complete on your behalf. We may also liaise with your Solicitor and/or Accountant where relevant to arrange a product on your behalf.
If you are interested in using a credit facility to pay for your insurance, then we will provide credit provider with your details and arrange payment through them. Where we assist you with a claim on your policy then we will liaise with the Insurer and Loss Adjuster appointed to your case.
Where required we may forward your details onto regulatory authorities or fraud agencies where we have a legal obligation to do so to comply with our regulatory requirements or where fraud is suspected. We may do this under the lawful basis legal obligation.
What will we do to ensure the security of personal information
We will not share any of the information you provide to third parties for marketing purposes or store any of your information outside of the European Economic Area. The information you provide will be held securely by us regardless of whether the information is in electronic or physical format. We use leading technologies and security measures to safeguard your information and keep strict security standards to prevent any unauthorised access to it.
How long will we retain your data
We will only hold data for no longer than is necessary. Where we have arranged a policy on your behalf we will keep your file including your personal data and any call recording, on record for a minimum of six years, in line with our regulatory obligation with the FCA. Where we need hold your file for longer than this then we will inform you of this.
What are your rights?
You have the right to:
- Be informed about how we use, share and store your personal information;
- Request access to the personal data we hold on you (also known as a Subject Access Request (SAR)). Where a SAR is requested we will respond promptly and within one month from the date we receive the request;
- Request your personal data is amended if inaccurate or incomplete;
- Request your personal data is erased where there is no compelling reason for its continued processing and we don’t have a legitimate interest to retain it;
- Request that the processing of your data is restricted;
- The right to object to your personal data being processed;
- Rights in relation to automated decision making and profiling.
Where the processing of your data is based on your consent, you have the right to withdraw this consent at any time by contacting us by phone or email. We do not use automated decision making or profiling systems.
Marketing
Where we need your consent, we will ask for this separately. We do not use pre-ticked boxes or make assumptions that you have given your consent. Your consent must be freely given by positively opting in or making a clear affirmative action that you are giving your consent. We will do our very best to ensure you know exactly what you are consenting to and remind you that you may withdraw your consent at any time by contacting us by email or phone. Where consent is obtained a record of this will be made confirming what you have consented to, the time and date and how consent was obtained.
Customers: Our customers are important to us however we appreciate that on some occasions you may wish to look elsewhere. If you do, we would like to stay in touch and therefore will ask for your consent in order for us to do so.
Potential Customers: Where you have expressed an interest in a product but have then decided not to proceed we would like to keep in touch therefore will ask for your consent to do so in case a product maybe of interest to you at a later date.
Non-Customers: We will only send you information about regulated products or services if we have obtained your consent to do so.
Right to complain?
We hope that the service you receive from us is to the high standard you would expect. If at any point you are unhappy with the way we have used your data then please notify: Joseph Ferns by either email, post or phone below. If you remain concerned about the way we collect or use your personal data, you can raise your concern with the Information Commissions Office (ICO) on 0303 123 1113. For further details you may visit the ICO website www.ico.org.uk
We will tend to disclose the complainants’ identity to whoever the complaint is about, however if you wish your identity to remain anonymous, we will try to respect that. We will keep your complaint on record for two years once closed or six years if it also relates to how we arranged a policy and falls under the FCA ruling.
Changes to information
We regularly review and, where necessary update our Privacy Notice. If we plan to use personal data for a new purpose our Privacy Notice will be updated, and you will be notified
How to contact us
If you wish to contact us about the above or any other matter, then please contact us at:
Mr Joseph Ferns
TCF Financial Planning Ltd
The Old Rectory
Main Street
Glenfield
Leicester
Leicestershire
LE3 8DG
Tel: 0800 0141932
Email:jferns@tcffp.co.uk
Website: www.tcffp.co.uk