Privacy Policy

Taking your privacy seriously

 
This Privacy Policy describes how we collect, use and keep your personal information safe. We keep it under regular review and place any updates to it on this web page. This Privacy Policy was last updated on 10th August 2023.

About us

The Retirement Bridge Group of companies, (the ‘Group’) comprise Retirement Bridge Investments Limited and various subsidiary companies, who operate from Suite 4, First Floor, Honeycomb, The Watermark, Gateshead, Tyne & Wear, NE11 9SZ. We own and administer various equity release plans, with legal and beneficial interests in various residential properties in the UK. More information about us can be viewed on our website www.retbridge.co.uk

This policy, and references to “we”, “us”, and “our” apply to all the firms that act as a data controller in our group. A list of those companies can be viewed on our website. See under the ‘About Us’ then ‘Our Group Companies’ tab. A list of those firms can also be provided.
 
References to “you” and “your” are to prospective customers, existing customers, and those who may act under authority on their, or their estate’s behalf. References to "plan(s)" means equity release products.
 
For new customers, your personal information will be collected by a company in our Group.  You will be informed, at the time, which of the group’s companies is collecting your data.
 
If you are making an application to release further equity from your plan, you will be informed at the time which of the group’s companies is collecting your personal information for the application. Such applications must be made by Financial Advisers authorised to do so by the Financial Conduct Authority.
 
Existing customers may contact us to find out which company in our group originally collected your personal information when you entered into your plan. Our Group firm Retirement Bridge Management Ltd is the data processor, and administers customers plans on a day to day basis.

Data Protection law and what this means for you
 
Your personal information will be held by us on a central database that will be accessed by other group companies. We will use the personal information that we collect about you in accordance with all applicable data protection law in the UK.
 
Responsibility for the personal information that we collect
 
For all customers from April 2018, the data controller will be our Group company that you were told is collecting your personal information and which is named on the application form you completed. For existing customers pre-April 2018, the data controller will be available on request from us. This Group company will decide the purposes for which your personal information is used.

The personal information we collect about you and how we collect it
 
The information we collect from you includes your name, address, contact details, date of birth, gender and marital status. Also your e-mail address, should you choose to provide it.

This personal information will be collected from you:
  • At application for one of our plans or to release further equity from it. This information will be collected via the Financial Adviser acting for you and your solicitor where one is engaged.
  • In the course of written or telephone communications with you or other individuals acting on your behalf. Please note we record calls between us and you for training and quality purposes.
  • When you complete forms for us as may be required.
  • Where we have acquired a firm your plan was previously part of, or acquired an interest in your plan and/or property from another firm. The personal information would be provided to us by your previous plan provider/administrator. 
  • In the course of telephone calls with you. Please note we record calls between you and us for training and quality control purposes.
Regarding visits to our website, we do not collect or store personal information about our customers via cookies. Please refer to www.retbridge.co.uk to see a copy of our Cookie policy. 

We will also collect information about you from third parties we may work with including: 
  • Financial Advisers.
  • Plan providers where we are involved in the provisions of the product and/or servicing of the plan.
  • Fraud prevention agencies and/or tracing agents.
  • Solicitors and Land agents.
  • Publicly available information including from the Land Registry.
  • Local Authorities and planning departments.
  • Government and law enforcement agencies.
 
Why we may process special categories of personal information about you
 
Special category data (also known as sensitive personal data) is information about something that is more sensitive and personal in nature. Although we do not set out to collect such information about you, in certain circumstances we may do so. This is most likely to be limited to include information concerning your health. For example where you inform us:
  • You are seeking to make an alteration or adaption to your home on medical grounds or if you apply for funding for an alteration or adaption to your home from a Local Authority by way of a grant or loan and require our permission as legal owner.
  • You are unable to live in the property on medical grounds and your lease must be handed back.
  • Of something such as a health issue where, for example, we may be able to consider adapting how we engage with you.
In addition, if we become aware or believe you have vacated the property and reside in care, we will need to seek confirmation from the care home that you are residing there permanently so we can terminate the lease, sell the property, and ensure any sale proceeds due to you or your estate are paid.  On this, third parties like Land Registry will require evidence when you do not have the capacity to sign the documents relating to the surrender of the lease. To evidence this, Land Registry require confirmation from a medical practitioner/professional that a customer no longer has the capacity to act on their own behalf on legal matters and requires the use of the Lasting Power of Attorney/Enduring Power of Attorney to sign the surrender documentation. When such information from a medical practitioner/professional is sent directly to us, we would maintain a copy of this, to support the transaction to sell the property and to protect against loss of original documents by lawyers involved or by Land Registry. Also to help us exercise or defend a legal claim against you.
 
Criminal Conviction data
 
We may also need to process information about you relating to a criminal conviction. For example, where you are in breach of your lease by vacating the property due to incarceration in prison following conviction. If we need to process such information about you which relates to a criminal offence or conviction data, we will either ask for your consent, or process it because it has manifestly been made public, or it is necessary for us to do so due to legal proceedings, obtaining legal advice or establishing, exercising or defending our legal rights.
 
Why we may process personal information about other people
 
If you give us personal information about another person, for example, someone you wish to act for you, you should tell that person you are going to share it with us. The information will be used in accordance with this Privacy Policy. Please tell that individual about it.
 
People living with you:
If there is another person living at the property with you, you must tell us about them, including their name and age. For most customers, we will write to you each year and ask you to complete a form called a Certificate of Occupancy to confirm you remain living at the property. This form will ask you to give the information referred to about them. We must give our consent for other people not named on the plan to live in the property because we need to make sure they do not create tenancy rights over it.
 
Your next of kin:
The Certificate of Occupancy form will also offer you the opportunity to provide the name and contact information of next of kin. You will not be obliged to provide us this information. If you do so, you are confirming that you have informed this individual and that we may contact them in an emergency. By an emergency we mean, after taking reasonable steps, we have been unable to make contact with you, and we have legitimate concerns as to your wellbeing. We may also need to contact them where we have been unable to make contact with you and we need to establish if you still reside in the property.
 
Power of Attorney:
If someone is appointed to manage your affairs, for example, under a Power of Attorney or similar, we would need to be supplied with the relevant documentation confirming that. This is so we can act on instructions they may give us on your behalf.
 
How we use your personal information
 
We use your personal information in connection with the provision of the plan. Under data protection law we can only use your personal information if we have a proper reason to do so – known as a ‘Lawful Basis’.  These include:
  • We have your consent.
  • It is necessary to enter into or perform a contract with you.
  • It is necessary to comply with a legal obligation.
  • It is necessary in order to protect your vital interests or
  • It is in our legitimate interests.
Below we have set out our reasons for using your personal information:
 
How we use your information Lawful Basis
To manage our relationship with you. This is in our legitimate interests to help us provide our services to you and necessary for the performance of the contract (the plan) we have with you. For example keeping our records up to date.
To assist in the administration of your plan & sale of the property as per the terms and conditions of it. This is necessary for the performance of a contract (the plan) we have with you, to help us undertake occupancy checks and  property inspections where required and ensuring the property sale is conducted correctly with any proceeds due to you/your estate reconciled.
To comply with legal and regulatory obligations we are bound by. This is necessary to help us comply with our legal obligations and for the performance of a contract (the plan) we have with you.
To run our business properly including for planning, analysis, audit and reporting purposes. This is in our legitimate interests to fulfil our legal and regulatory obligations that apply to us.
To manage complaints, feedback and queries. This is in our legitimate interests and to help us in the performance of a contract (the plan) we have with you, helping us respond to you appropriately.
To ensure that we are informed about anyone who may be residing in the property not named on the plan. This is in our Legitimate interests and necessary for the Performance of a contract (the plan) we have with you.  We need to ensure there is nothing to affect or undermine our legal rights in relation to the plan.
To communicate with any third-party individuals, such as your next of kin or Local Authority. This is in our Vital Interests to enable us to deal with a situation where we, acting reasonably, have concerns about your wellbeing.
 
Who we may share your personal information with
 
For the purposes of managing your plan including sale of the property when it ends, your information may be shared with:
  • Our business partners, financial advisers, suppliers and sub-contractors for the performance of the plan.
  • Our professional advisers (including accountants and lawyers) that assist us in carrying out our business activities.
  • Our financial services providers such as banks, lenders and payment processors.
  • Our IT services providers.
  • Property agents, valuers, surveyors and estate agencies for the purpose of inspection, valuation, sales and contractual repairs.
  • Insurers or brokers so that can confirm whether the property relevant to the plan may be adequately insured (where we are obliged to arrange buildings insurance).
  • External agencies and organisations (such as Fraud Prevention Agencies, the Police, the relevant Local Authority, and other Government or law enforcement agencies) for the purpose of complying with applicable legal and regulatory obligations.
  • Tracing agents, for the purposes such as debt recovery, ascertaining whether contrary to the plan the property may no longer be your main residence or to ensue you or your estate receive any sums such as surplus sale proceeds you may be due under the terms of the plan.
  • Regulators such as the Financial Conduct Authority and the Financial Ombudsman Service, for example to help resolve a complaint you make.
  • Other members of our Group of companies. Principally this includes Retirement Bridge Management Ltd to enable them to perform their day to day duties in managing your plan.
  • Investors where they have funded your plan for the purposes of our internal reporting and management. Where such investors are based outside the European Economic Area (EEA) we will anonymise your personal information. For details of who these investors are, please get in touch via the How to contact section below.
 
We will also disclose your personal information to other third parties, for example:
  • In the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets.
  • If we or substantially all of our assets are acquired by a third party, personal information held by us will be one of the transferred assets.
  • Where we, acting reasonably, have legitimate concerns about your safety and wellbeing. For example, in such circumstances we may contact your Local Authority or Social Services agency.
  • Where we, acting reasonably believe you may have vacated the property. For example, where we believe you may be residing in care and may need to end the plan and terminate the lease, ensuring any proceedings due to you or your estate can be properly reconciled.
Processing and overseas transfers
 
We will process your personal information within the European Economic Area (EEA). If we transfer your personal information outside the EEA, we will seek to anonymise it.  If we can't anonymise your personal information, we will take reasonable steps to ensure that your personal information is protected.
 
 Automated decision making
 
We do not use automated decision making in processing your personal information, other than for the purposes of payment card authorisation where you make a payment to us for something by card payment.
 
Your rights
 
You have certain rights with respect to your personal information. The rights will only apply in certain circumstances and are subject to certain exemptions. You have the right to:
  • Request a copy of information we hold about you;
  • Ask us to correct your personal information that we hold where it is incorrect;
  • Ask that your personal information may be deleted in certain circumstances;
  • Restrict or object to the processing of your information;
  • The information we hold about you be provided to you or another organisation in a machine readable format;
  • Withdraw your consent to our processing your personal information where we are relying on consent to process it;
  • Complain to the Information Commissioner's Office (ICO), where you think we have not used or are not using your personal information correctly.
More information about the ICO can be found on their website: How long we keep your personal information
 
We will maintain your personal data indefinitely. This also applies to third parties acting on behalf of customers, complainants, beneficiaries, executors, trustees and attorneys.
 
Data security
 
We maintain strict physical, electronic and administrative safeguards to protect your personal information from unauthorised or inappropriate access.  Our IT systems are manged by a third party professional services company which is ISO 27001 and ISO 9001 certified. Our data is held remotely in UK data centres and our infrastructure, servers and backups are maintained and managed providing the highest security protection.  Your personal information collected, processed, transferred and stored on our database and telephony system is encrypted and protected using compliant, secure methods.

Whilst emails to our trusted third parties are encrypted, we cannot send or receive secure email from you.  We will therefore not include any of your personal information in an email to you unless you give us your consent to do so. We will not accept liability for any damages for any loss of confidentiality of these emails. We will respond by telephone or post where we do not have your consent.

No marketing pledge

Other than for the purposes of servicing your plan, or undertaking our own internal analysis, we or other companies in our group will not contact you for any marketing purposes.  Nor will we pass on your information to other organisations for the purposes of their marketing to you. 
 
How to contact us
Write to us at:
Retirement Bridge, Suite 4, First Floor, Honeycomb, The Watermark, Gateshead, Tyne & Wear,
NE11 9SZ.
 
Telephone us on: 0800 032 2118.
(In order to verify the content of your call and for staff training and monitoring purposes we ensure all calls are recorded).

E-mail us at: enquiries@retbridge.co.uk