Privacy Policy
Your privacy and trust are our top priorities. This policy outlines exactly how we manage, protect, and respect your personal data.
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Protecting your personal data is our top priority.
This Privacy Policy explains what personal data Lloyds Independent Financial Services ("we", "us", or "our") collects, what we use it for, who we share it with, and how we protect it in strict accordance with UK GDPR, the Data Protection Act 2018, and Financial Conduct Authority (FCA) requirements.
1. Who we are
Lloyds Independent Financial Services (LloydsIFS) is the data controller and is responsible for your personal data and this website.
We are authorised and regulated by the Financial Conduct Authority (FCA) under Firm Reference Number (FRN) 628264. We are registered with the Information Commissioner's Office (ICO) under registration number Z3416952.
Our office address is: 19 The Old Orchard, Farnham, Surrey, GU9 8UR, UK.
This document was last updated in June 2026. Previous archived versions can be requested by contacting our compliance officer.
2. What personal information we collect
To provide bespoke, professional mortgage and protection advice tailored directly to your life, we must process a variety of personal data. This enables us to cross-reference multiple lending criteria to deliver accurate recommendations.
We collect, use, store and transfer different kinds of personal data about you which are grouped as follows:
- Identity & Biographical Data First name, maiden name, last name, marital status, title, date of birth, gender, address history, nationality, dependents, and employment/business ownership history.
- Contact Data Residential address, billing address, email address, and telephone numbers.
- Financial Fact-Finding Data Bank statements, income (salaries, company dividends, contractor day rates), monthly outgoings/credit cards, available deposit amounts, property values, credit file metrics (bankruptcies, defaults, CCJs), and details of existing mortgage or protection agreements.
- AI Assistant (MIA) Conversational Transcripts When you interact with MIA, our Mortgage Intelligent Assistant, we collect and store the raw transcripts, baseline numbers provided, and scheduling preferences. This data is securely recorded to assist our human brokers with your consultation.
- Special Category / Sensitive Data Where strictly relevant to arranging specific protection or insurance policies (e.g. Life Insurance or Income Protection), we collect details regarding your physical or mental health, medical histories, height/weight, lifestyle factors (smoker status), and, where mandated for statutory fraud-prevention, data regarding criminal convictions or offenses.
- Technical & Usage Data Internet protocol (IP) address, browser details, time zones, device models, pages visited, and browser behavior tracked while navigating our portal.
Note on Minors: We do not offer products directly to children. However, we collect children’s names and dates of birth when they are dependents affecting mortgage affordability or named on protection policies, as required by lenders.
3. How we collect your personal information
We collect data using several transparent methods, including:
- Direct Interactions: You provide Identity, Contact, and Financial details by filling in application forms, typing messages to MIA on our homepage, uploading documents, or communicating with us by phone, email, video consultation, or post.
- Automated Technologies: As you navigate our website, we automatically collect Technical Data via cookies, server logs, and similar technologies. Please refer to our Cookie Policy for detailed settings.
- Joint Applicants: If you apply for a mortgage with a spouse or partner, we receive information about you from the main applicant. By doing so, you confirm you have authorized the submission of your data.
- Third Parties & Public Channels: We may gather identity, financial, or technical data from credit reference bureaus (e.g. Experian, Equifax, TransUnion), anti-money laundering portals, Companies House, the Electoral Register, or estate agents/new-build developers with whom you have consented to interact.
4. How we use your personal data
We will only process your personal data when permitted by law. Our primary legal bases are:
- Performance of a Contract: To arrange and progress mortgage or protection applications.
- Legitimate Interest: To optimize our advisory processes, manage your enquiries, prevent financial fraud, and maintain outstanding customer support.
- Compliance with Legal & Regulatory Obligations: To adhere to the strict rules enforced by the Financial Conduct Authority (FCA).
- Explicit Consent: Required to process special category medical history files for life protection, or to send out marketing updates.
| Purpose/Activity | Types of Data Involved | Lawful Basis for Processing |
|---|---|---|
| Initial consult, fact-finding, and budget scenarios (MIA chat and advisor booking) | (a) Identity (b) Contact (c) Financial details (d) Transcripts | Performance of a contract, Legitimate Interest |
| Lender sourcing & mortgage application submission | (a) Identity (b) Contact (c) Financial (d) Special category data (if applicable) | Performance of a contract, Compliance with legal obligation |
| Arranging protection & insurance products | (a) Identity (b) Contact (c) Medical/health data (d) Lifestyle | Explicit Consent, Performance of a contract |
| Ongoing client support & deal monitoring (remortgage warnings, SVR prevention) | (a) Identity (b) Contact (c) Financial (d) Marketing choices | Performance of a contract, Legitimate Interest, Consent |
| Troubleshooting, technical administration, security analytics, and fraud protection | (a) Identity (b) Contact (c) Technical (d) Usage Data | Legitimate Interest (running our business, fraud prevention) |
Your rights regarding Consent: Where we process data based purely on your consent, you are free to withdraw that consent at any time. Simply write to us at info@lloydsifs.co.uk.
6. International transfers
We are based in the United Kingdom and store our core CRM data locally. However, some of the cloud technical services or software systems we utilize may be hosted in databases located outside the UK or the European Economic Area (EEA).
Whenever we transfer personal data out of the UK or EEA, we ensure a similar degree of security is provided by implementing at least one of the following protective safeguards:
- We only transfer data to countries that have been officially deemed to provide an adequate level of data protection by the UK government.
- We utilize specific Standard Contractual Clauses (SCCs) and International Data Transfer Agreements (IDTAs) approved for use in the UK, guaranteeing your personal data receives the exact same high standards of protection it has in the UK.
7. Security and retention periods
We have established strict security measures to protect your personal and financial information from accidental loss, disclosure, or unauthorized access. Access to your personal data is limited strictly to qualified brokers and administrative staff who have an absolute business need-to-know, and who are bound by confidentiality clauses.
We retain personal data only for as long as is necessary to fulfill the purposes for which it was originally collected, including the satisfaction of financial compliance audit rules.
| Type of Interaction / Record | Standard Retention Term | Underlying Justification |
|---|---|---|
| Successfully Completed Mortgage & Protection Applications | The active term of the mortgage or protection policy, plus a further 6 years. | FCA compliance, dispute resolution, suitable advisory proof. |
| Incomplete, withdrawn, stalled, or failed applications | 6 years from the date the last advisory check or decision-in-principle was initiated. | Regulatory reference, historical dispute tracking. |
| MIA Assistant Chat Transcripts (Not resulting in full applications) | Up to 12 months from the date of the interaction. | Initial consultation analysis, temporary system optimization. |
| Job applications & CV submissions | Successful: Duration of employment plus 6 years. Unsuccessful: Up to 1 year. | UK Employment legislation. |
8. Your legal rights
Under UK GDPR and the Data Protection Act 2018, you have several powerful statutory rights:
- Request Access (Subject Access Request): You have the right to request a complete copy of all the personal information we hold about you.
- Request Rectification: You can request immediate correction of any incomplete, outdated, or inaccurate information we hold about you.
- Request Erasure ("Right to be Forgotten"): You can ask us to delete your personal data. However, please note that we may not always be legally permitted to erase all data due to overriding FCA compliance rules. We will notify you if this is the case.
- Object to Processing: You have the right to object to us processing your data when we rely on a legitimate interest, or if we use your data for direct marketing purposes.
- Request Restriction: You can ask us to temporarily suspend processing your personal data (e.g., while establishing its accuracy).
- Request Data Portability: We can provide your personal data to you or a named third party in a structured, machine-readable format.
There is **no fee** to access your personal data or to exercise your rights. We aim to process and reply to all verified requests within **one calendar month**.
9. Contact and complaints
If you have any questions about this Privacy Policy, wish to exercise any of your legal rights, or have a concern regarding how your data is handled, please contact us directly:
Lloyds Independent Financial Services
Attention: Data Protection Officer (Mark Lloyd)
19 The Old Orchard, Farnham, Surrey, GU9 8UR, UK
Phone: 01252 714468
Email: info@lloydsifs.co.uk
If you remain dissatisfied with our handling of your data, you have the absolute right to register a formal complaint with the Information Commissioner's Office (ICO), the UK's statutory regulatory body for data protection:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113
Website: www.ico.org.uk