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Broker Data Protection Policy

🤝 INTERMEDIARY & BROKER FAIR PROCESSING NOTICE • VERSION: 25/08/2026

Broker Data Protection & Privacy Notice

This Fair Processing Notice explains how Promise Solutions Ltd (trading as Promise Money and Promise Specialist Lending) collects, processes, and protects the personal data of introducers, intermediaries, and network brokers.

Data Controller
Promise Solutions Ltd
Promise Specialist Lending
Data Protection Officer
Mr Stephen Walker
Managing Director
FCA Registration
Firm Ref: 681423
Authorised & Regulated
Intermediary Desk
01902 585020
info@promisesolutions.co.uk

1. Who Are We?

Promise Solutions Ltd (“Promise”) is a financial services company dealing with enquiries from brokers and the general public. We also trade under the names of Promise Money and Promise Specialist Lending.

Registered Head Office & Intermediary Support:
Promise Solutions Ltd, Fullard House, Neachells Lane, Wolverhampton, WV11 3QG
Tel: 01902 585020 • Email: info@promisesolutions.co.uk
Data Protection Officer: Mr Stephen Walker

2. Why Do We Need Your Data?

We hold and process your data in order to provide the intermediary and packaging services anticipated in our Introducer / Intermediary Agreement, including:

  • Informing you about lending products, criteria changes, and packaging services.
  • Obtaining loans, mortgages, and associated specialist finance solutions from our panel of lenders for you and your clients.
  • Recording your involvement in individual cases for regulatory compliance, audit tracking, and paying introducer commissions accurately.

3. What Right Do We Have to Process Your Data? (Legal Basis)

Promise is regulated by the Financial Conduct Authority (FCA – www.fca.org.uk), meaning we are accountable for all products, packaging, and intermediary arrangements. We are legally obligated to maintain detailed transaction records, including full details of who introduced the customer to us.

We process introducer and broker personal data under the following statutory grounds:

Legal Obligation
Processing is necessary to satisfy statutory FCA audit, anti-money laundering, and intermediary governance records.
Contractual Necessity
Processing is necessary to fulfill our commitments set out in our Introducer / Intermediary Agreement and process commission payments.

4. What Do We Do With Your Data?

All personal data we hold about you is processed by our staff based in the United Kingdom.

Your information is stored securely on systems within our office and on secure cloud-based systems whose servers are located within the EEA. Promise acts in a master broking / packaging capacity and uses your data to manage products, packaging workflows, and the overall commercial relationship.

5. Who May We Share Your Data With?

Party Involved Reason For Involvement
Lender Panel Providers To record your details on application packaging systems and on documents generated for your clients.
Your Client If you ask us to inform your customer to contact you using contact details they did not previously have.
Your Company / Network / Club To identify cases you have introduced for commission reporting, network split allocations, and compliance tracking.
Specialist Packaging Brokers On rare occasions where non-standard client applications require specialized co-packaging assistance.
Legal Representatives Solicitors, accountants, or conveyancers acting directly on your client’s behalf during loan completion.
Regulators and Ombudsmen In the event of a regulatory query, audit, or formal complaint investigation.
Telephone & Telecom Providers Telephone calls are securely recorded for quality assurance, staff training, and regulatory audit via cloud storage.
Cookies & Portal Analytics Cookies ensure portal sessions remain authenticated, remember preferences, and improve portal navigation.
Third-Party Technology Providers Sourcing software, secure email gateways, SMS platforms, web chat, and CRM processing tools.
Third-Party Compliance Auditors Independent compliance consultants auditing our business practices and network intermediary records.

6. What Type of Data Do We Ask For?

We ask for professional and personal data (e.g. name, trading address, date of birth, FCA individual registration number, contact telephone numbers, and email addresses).

In addition, if you inform us that you are away from work for an extended period due to ill health, we may note this on our internal system to ensure cases are managed smoothly.

7. Storage, Retention & Credit Checks

We retain broker and introducer records on an indefinite basis to retrieve historical transaction records, satisfy ongoing FCA regulatory requirements, and support new client enquiries seamlessly.

Credit Reference Searches: We do not carry out credit searches on brokers as part of our standard registration process. We will always seek your explicit permission first if a check ever becomes necessary.

8. Your Statutory Rights Under UK GDPR

1. Right to be Informed
Fulfilled directly through this transparent intermediary privacy notice.
2. Right of Access
You can request a copy of all professional records we hold about you.
3. Right to Rectification
You can update or correct contact, network, or bank commission details at any time.
4. Right to Erasure
Subject to statutory transaction retention for completed lending deals.
5. Right to Restrict Processing
You can ask us to pause processing (ongoing client applications may be affected).
6. Right to Data Portability
We can provide your structured electronic broker file upon request.
7. Right to Object
You can manage or reduce marketing preferences directly in your portal account.
8. Automated Decision Making
We do not use broker personal data for automated decision making.

9. Making a Complaint

Complaints should be addressed to our Data Protection Officer:

Promise Solutions — DPO

Attention: Data Protection Officer
Promise Solutions Ltd, 2nd Floor Fullard House,
Neachells Lane, Wolverhampton, WV11 3QG
Tel: 01902 585008 • Email: customercare@promisesolutions.co.uk

Information Commissioner’s Office

If you remain dissatisfied, you can escalate to the UK Regulator:
ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113 • 01625 545 745
Website: www.ico.org.uk

10. Third-Party Organisations

If we pass your details to another organisation (such as a lender preparing a formal quotation for your client), they will record your details for compliance within their systems and issue their own Fair Processing Notice if required. Promise bears no responsibility for the use of data beyond our direct control.

Promise Solutions Ltd (trading as Promise Money and Promise Specialist Lending) is registered in England and Wales (Company No: 04822774).

Authorised and regulated by the Financial Conduct Authority (Firm Reference Number: 681423).