This notice explains what personal information we collect about you, why we need it, who we share it with, how long we keep it, and the rights you have over it. It covers both this website and the advice relationship itself.
We have written it to be read, not to be survived. If anything in it is unclear, ask us and we will explain — and we will treat the question as a sign the wording needs improving.
Who is responsible for your information
ProActivLife Ltd is the data controller for the information described in this notice. That means we decide what is collected and why, and we are accountable for it.
Our principal firm
Because we are an appointed representative, our principal firm Financial Expert Partnership Ltd also processes some of your information — principally to supervise the advice we give you, review our client files, and handle complaints. They are a separate data controller for those purposes and have their own privacy notice, which we can provide on request.
What information we collect
How much we hold depends entirely on how far you go with us. A visitor who reads a page leaves almost nothing. A client receiving protection advice necessarily shares a great deal, including information about their health.
If you only browse this website
- Technical information your browser sends — approximate location from your IP address, device and browser type, and the pages you visited.
- If you consented to analytics cookies: aggregated statistics about how the site was used. If you did not consent, none of this is collected. See our Cookie Policy.
- If you arrived through a particular adviser's link, the fact of which adviser — held only for the duration of your visit, so that you stay with that adviser rather than being passed to someone else mid-visit.
If you use the mortgage calculator or contact us
- Your name, email address and phone number.
- The figures you entered into the calculator, and the result.
- What you told us you were looking for.
If you become a client
To give you advice we are required to build an accurate picture of your circumstances. That includes:
- Identity and contact details — name, date of birth, addresses, phone, email, nationality, marital status, dependants.
- Financial information — income, employment, outgoings, debts, savings, credit history, existing mortgages and policies, bank details.
- Health and lifestyle information — medical history, family medical history, height and weight, smoking, alcohol, occupation and hazardous activities. This is special category data and is treated with additional protection — see below.
- Identity verification records — copies of documents we are legally required to see and retain to meet anti-money-laundering obligations.
- Records of our dealings — notes of meetings and calls, the advice given and why, the documents issued to you, and where relevant any support you have asked us to provide.
We may also collect information about other people through you — a partner on a joint application, dependants, beneficiaries, or a trustee. Where you give us someone else's information, please make sure they know, and point them to this notice.
Health information: the special rules
Protection insurance cannot be arranged without health information — the insurer's decision on whether to cover you, and at what price, depends on it. Information about your health is treated by law as special category data under Article 9 of the UK GDPR and needs a stronger justification than ordinary personal data.
We rely on your explicit consent (Article 9(2)(a)) to collect and share your health information, and in the insurance context also on the substantial public interest condition for insurance purposes in Schedule 1, Part 2, paragraph 20 of the Data Protection Act 2018.
You can refuse, and you can withdraw consent at any time. We will not pretend otherwise. But you should know the consequence: without health information we cannot arrange protection cover for you, and an application already in progress may have to be withdrawn. It does not affect mortgage advice.
Health information is only ever shared with the insurer you are applying to, its medical underwriters, and where necessary a doctor providing a medical report. It is not used for marketing, never shared with lenders, and never used to make a decision about you by automated means without your knowledge — see automated decisions below.
Why we use it, and our lawful basis
Under the UK GDPR we need a lawful basis for everything we do with your information. Ours are set out in full below.
| What we do | Why | Lawful basis |
|---|---|---|
| Respond to your enquiry; send you a calculator result | You asked us to | Consent — Art. 6(1)(a). You can withdraw it at any time. |
| Assess your circumstances and give you advice | It is the service you have engaged us for | Contract — Art. 6(1)(b) |
| Submit applications to lenders and insurers on your behalf | To arrange what you have asked us to arrange | Contract — Art. 6(1)(b), and for health data explicit consent — Art. 9(2)(a) |
| Verify your identity; anti-money-laundering checks | We are required to by law | Legal obligation — Art. 6(1)(c) |
| Keep records of the advice we gave and why | FCA rules require us to, and it protects you if you later query the advice | Legal obligation — Art. 6(1)(c) |
| Allow our principal firm to review our files | Regulatory supervision of our advice | Legal obligation — Art. 6(1)(c) |
| Handle a complaint or a claim | To resolve it properly | Legal obligation — Art. 6(1)(c) and legitimate interests — Art. 6(1)(f) |
| Contact existing clients about reviewing cover as circumstances change | Cover that is never reviewed stops being suitable | Legitimate interests — Art. 6(1)(f). You can object at any time and we will stop. |
| Record support needs you have told us about | So you do not have to explain again each time | Consent — Art. 6(1)(a), and Art. 9(2)(a) where it concerns health |
| Send marketing to people who are not yet clients | Only where you have asked to hear from us | Consent — Art. 6(1)(a) and PECR |
| Analytics on this website | To improve the site | Consent — Art. 6(1)(a). Nothing runs unless you accept analytics cookies. |
Where we rely on legitimate interests, we have assessed our interest against your rights and concluded the processing is proportionate and would be expected. You can ask us for that assessment, and you can object — see your rights.
Marketing, and how to stop it
We will only send you marketing by email or text if you have asked us to, or if you are an existing client and it concerns services similar to those we have already provided. Every marketing message has a one-click unsubscribe. You can also email privacy@proactivlife.co.uk and ask us to stop, and we will.
We do not sell your information, we do not rent our client list, and we do not pass your details to third parties so that they can market to you. Not as a matter of current policy — as a matter of principle.
Who we share it with
We share your information only where it is necessary, and only with the categories below.
- Lenders — to submit and progress a mortgage application. Health information is never shared with lenders.
- Insurers and their underwriters — to obtain quotations and submit protection applications. This is where health information goes.
- Medical professionals — where an insurer requires a medical report. You will be told, and asked to consent, before this happens.
- Our principal firm, Financial Expert Partnership Ltd — for supervision of advice, file review and complaint handling.
- Solicitors and conveyancers — where you have asked us to introduce you, or where they need information to complete your purchase.
- Will-writing and estate-planning providers — only where you have asked for an introduction.
- Identity and fraud-prevention agencies — for anti-money-laundering checks. These checks leave a record with the agency.
- Credit reference agencies — where a lender or we (with your permission) carry out a credit search. A full application search may affect your credit score; your adviser will tell you before any search that does.
- Our service providers — the suppliers who run our CRM, email, document storage and telephony. They act on our instructions only, under written contracts that restrict what they may do with your information.
- Regulators, HMRC, police and courts — where we are legally required to disclose, or to prevent or detect crime. Where the law permits us to tell you, we will; sometimes, in the case of a suspicious activity report, the law prohibits us from doing so.
- A buyer of our business — if the firm were sold or transferred, client records would transfer with it. Any buyer would be bound by this notice.
Where your information is held
Your information is normally stored in the United Kingdom or the European Economic Area. Some of our technology suppliers process data outside the UK. Where that happens, we make sure the transfer is protected by one of the safeguards UK law requires — either UK adequacy regulations covering the destination country, or the International Data Transfer Agreement or Addendum approved by the Information Commissioner.
You can ask us which suppliers are involved and which safeguard applies.
How long we keep it
| Information | Kept for | Why |
|---|---|---|
| Website enquiry or calculator result that does not become a client relationship | 12 months | Long enough for you to come back to us; then deleted |
| Marketing consents and unsubscribe records | Until withdrawn, then a suppression record indefinitely | So we can prove we were entitled to contact you, and so an unsubscribe is permanent |
| Mortgage advice files | At least 6 years from the end of the advice relationship | FCA record-keeping rules; the Ombudsman can consider complaints up to six years after the event |
| Protection advice files, including health information | The life of the policy plus at least 6 years | A claim may arise decades after the advice, and the file is the evidence of what was recommended and why |
| Anti-money-laundering identity records | 5 years from the end of the relationship | Money Laundering Regulations 2017 |
| Complaint records | At least 6 years | FCA rules in DISP, and to identify patterns |
| Cookie consent record | Up to 12 months, or until you change it | So we do not ask you on every visit |
When a retention period ends we delete the information or anonymise it so that it can no longer identify you.
Automated decisions and profiling
We do not make decisions about you by purely automated means.
You should know, though, that lenders and insurers do. Mortgage affordability and credit decisions, and insurance underwriting, are frequently made or heavily informed by automated systems and scoring models operated by them, not by us. Where a decision about you is made by a lender or insurer on a solely automated basis, you have the right under Article 22 of the UK GDPR to ask them for an explanation, to contest the decision, and to ask for human review. Your adviser will help you make that request and will tell you who to make it to.
The adviser-matching tool on this site is not an automated decision in that sense — it is a suggestion tool. It sorts advisers by the language you chose and the service you need. It reaches no decision about you, it does not affect what advice you can receive, and you are free to ignore it and contact any adviser you like.
Your rights
You have the following rights over your information. They are free to exercise, and using them will never affect the service you receive from us.
Email privacy@proactivlife.co.uk, or write to the Data Protection Lead at 3 Chester Bridge, Crewe, Cheshire, CW2 7EF, or call 01270 747 989.
You do not need to use particular words or cite the legislation. Tell us what you want and we will treat it correctly.
We will normally respond within one month. If your request is complex we may extend that by up to two further months, and we will tell you why within the first month. We may need to verify your identity first, to make sure we are not disclosing your information to someone else.
Complaining about how we use your information
Please tell us first — email privacy@proactivlife.co.uk. Most problems are a misunderstanding or a mistake and we would rather fix it.
You also have the right to complain directly to the UK's data protection regulator, and you do not have to come to us first:
Online: ico.org.uk/make-a-complaint
Helpline: 0303 123 1113
By post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Complaints about the advice we gave, rather than about your information, go through a different route — see our Complaints page.
Keeping your information safe
We take security seriously because the information we hold about clients — financial position, health history, identity documents — is exactly what a criminal would want. Our measures include access restricted to advisers and staff who need it, encryption of data in transit and at rest, multi-factor authentication on our systems, secure disposal of paper records, written contracts with suppliers, and staff training.
No system is perfect. If a breach occurred that was likely to result in a risk to your rights, we would report it to the ICO within 72 hours, and where the risk to you was high we would tell you directly and explain what to do.
We will never email, text or call to ask for your full password, your card PIN, or a one-time security code. We will never ask you to move money to a "safe account". If you receive a message that claims to be from ProActivLife and asks for any of these, it is not from us — do not reply, and call us on 01270 747 989 using the number on this page rather than any number in the message.
Children
Our services are for adults and this website is not directed at children. We do hold information about children in two situations: as dependants named in a protection plan, and as beneficiaries of a policy or trust. That information comes from the adult client, is limited to what the insurer or trust needs, and is not used for any other purpose.
Changes to this notice
We review this notice at least annually, and whenever we change how we use personal information. The date it was last reviewed is at the top and bottom of this page. Where a change materially affects you — a new purpose, a new category of recipient — we will tell existing clients directly rather than relying on you noticing a new date here.