First Mortgage. Registered Office: 30 Walker Street, Edinburgh, EH3 7HR. Registered in Scotland, number SC177681.
Mortgage Advice Bureau Limited. Registered Office: Capital House, Price Place, Derby, DE24 8QR. Registered in England, number 3368205.
Mortgage Advice Bureau (Derby) Limited. Registered Office: Capital House, Price Place, Derby, DE24 8QR. Registered in England, number 6003803.
Companies known together in this document as “Mortgage Advice Bureau”, “we”, and “us”.
Here at First Mortgage, we care about our customers, and this care is extended to protecting the security of your data in both online, and offline environments.
First Mortgage are an Appointed Representative of Mortgage Advice Bureau Ltd and Mortgage Advice Bureau (Derby) Ltd. As joint controllers of your data, we comply with Data Protection laws in the United Kingdom, and the EU General Data Protection Regulation. This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
Why do we collect your personal data?
We collect personal information about you in order to:
- Allow us to provide suitable advice taking into account your personal circumstances, and to process your application for the advised mortgage or protection product.
- With First Mortgage and Mortgage Advice Bureau acting as joint data controllers, to review your mortgage and protection as part of an on-going client relationship with us as your adviser.
- Respond to complaints and case enquiries.
- To administer and protect our business, including complying with out legal obligations.
Your personal information is required to enter into any contract you may undertake with us as your adviser for a mortgage or protection product, and for us to provide information on relevant products and services. Without this information, it would not be possible for us to provide these services.
We will only use your personal data for the purposes stated above, unless we reasonably consider that we need to use if for another reason ands it is compatible with the original purpose. If we need to use your personal data or an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Agreement to ongoing service and re-engagement
We would also like to keep in touch to review your mortgage, insurance needs and current arrangements, in particular when your mortgage product is nearing expiry. This is important as, for example, it will be an opportunity to check that you are not paying more than you need to and whether your existing arrangements are still appropriate as your circumstances and needs change. You may withdraw from these arrangements at any time by contacting us.
What personal information do we collect?
The personal information we collect includes (but is not limited to):
- Your personal information, such as name, date of birth, gender, martial status.
- Your personal contact details (including address, e-mail and telephone number).
- Income & employment details.
- Financial information (Bank Statements, Income & Expenditure details, Details on savings, debts such as loans and credit cards, other assets, and employer & pension provisions).
- Special categories of personal data such as medical history for protection products and possibly trade union / political party membership costs as part of Fact Find information.
- Other related information to support your application and confirm your identity (such as UK residency status and retirement age).
- Technical data including internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology when using our website.
- Profile and Usage Data including purchases made by you, feedback and survey responses, and how your use our website, products and services.
- Marketing and Communications Data including your preferences in receiving marketing from us and our business partners, and your communication preferences.
How do we collect your personal data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to mortgage and protection.
We may also receive information from third party sources such as solicitors, and new home builders should you have consented for them to provide this information to us.
Who do we disclose your personal information to?
Within our network
Depending on your requirements, it may be necessary to share your personal data with Mortgage Advice Bureau’s network and specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients.
Lenders & Providers
We disclose personal information to third parties such as lenders and protection product suppliers, but only what is necessary to conclude the mortgage and/or protection contracts, the ongoing servicing of these contracts, and to support quality checks and ensure full disclosure of information to lenders and protection providers.
We may disclose personal information in order to source your bank account information via Open Banking, but only with your consent.
Licenced Credit Reference Agencies
To verify your identity, we will complete an Anti-Money Laundering check through CallML (TransUnion https://www.transunion.co.uk/legal-information/bureau-privacy-notice. Personal information is shared with this credit reference agency in order to carry out this check.
Under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, to meet our obligations to the Financial Conduct Authority (FCA) and when responding to subject access requests, proceedings of a Court of Law or similar legal process, to protect against fraud, and to otherwise co-operate with law enforcement or regulatory authorities.
Estate Agents, New Build Developers and Solicitors / Conveyancers
Basic milestone updates on the progress of your application will be shared with the above. No personal or sensitive information will be shared within the updates provided.
Housing Associations / Registered Providers
If applicable, to confirm your identity / proof of deposit to the Housing Association / Registered Provider with whom you are interacting, to provide updates on the progress of your application, and to provide a copy of the mortgage offer to support your application.
Specialist IP system providers to deliver our service to you (including sourcing products, providing continuing advice, sharing of documentation, payment processing, informing you about relevant products and services, service & advice quality checking and improvements, and to request feedback on customer service standards). It may also be necessary to share your personal data with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to First Mortgage and Mortgage Advice Bureau.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
How long is your personal information retained?
If we complete a transaction with a lender or provider on your behalf, we will keep a full record of your interactions with us for the lifetime of the advised product plus a further 6 years to enable us to meet our regulatory obligations and to enable us to answer any complaints that may arise as a result of our advice.
Personal information provided during initial exchanges prior to business being transacted will be deleted from our system after 24 months if no further contact is made. It will be assumed that you do not wish to proceed with our services, and as such we no longer have a requirement to retain this information.
Security of your personal information
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party. We also limit access to your personal data to only those who have a legitimate business need to know. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Some of our external suppliers are based overseas so their processing of your personal data will involve a transfer of data outside of the UK. In such cases data is transferred under conditions to provide protection to personal data equivalent to UK data protection standards. This includes the use of standard contractual clauses in contracts with external suppliers in order to provide the same level of protection for personal data as it has in the UK.
All copies of paperwork provided to us are uploaded to our secure Customer Management system, with all hard copies being disposed of in confidential waste and destroyed on site at regular intervals.
Our website may include links to third-party websites, plug-ins and applications. Clicking on these links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Use of AI and Automated Decision Making
We may use your data in AI and automated decision making systems as a legitimate interest for re-engagement purposes to review your existing mortgage and source suitable new products, to confirm your identity, to validate documents you provide and to assess the affordability of products based upon your requirements. If you do not wish your data to be used by such systems, please notify us at [email protected]
Your rights regarding your personal information
You have the right to access your personal information to check whether it is accurate and up-to-date, you also haver the right to receive a copy of the personal information that we process for you.
You have the right to withdraw your consent for us to retain your personal information, however, this information can only be removed should the statutory timescales for retaining the information have lapsed.
You also have the right to object to us processing your persona information under our legitimate interest, and you have the right to request we restrict the processing of your persona information under certain circumstances.
You can also ask us to transfer your personal information to you or to a third party. We will provide you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to the automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Clinets who reside within the European Union retain their data subject rights under the EU General Data Protection Regulation. EU-based clients with queries regarding how Mortgage Advice Bureau processes data can contact our EU representative DataRep by emailing [email protected] or by visiting their website www.datarep.com/data-request
Changes to our Privacy Notice
We keep our Privacy Notice under regular review. If we make any changes to how we process your personal information in ways you would not reasonably expect, we will contact you and bring these changes to your attention. Our Privacy Notice was last updated on 2 September 2021.
If you have any questions or complaints relating to how we use your personal information, or if you wish to exercise any of your rights regarding your personal information, please contact [email protected] or write to us at Data Protection, First Mortgage, 30 Walker Street, Edinburgh, EH3 7HR
We will respond to you as soon as is possible. The length of time will depend on the type and complexity of the request, but you will receive a response no later than one month from the initial request.
What if I am still not satisfied?
If you are not satisfied with how the First Mortgage has responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.