First Mortgage Privacy Policy

First Mortgage. Registered Office 30 Walker Street, Edinburgh, EH3 7HR. Registered in Scotland Number: SC177681

Mortgage Advice Bureau Limited. Registered Office: Capital House, Pride Place, Derby DE24 8QR. Registered in England Number: 3368205

Mortgage Advice Bureau (Derby) Limited. Registered Office: Capital House, Pride 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.

The personal data we collect about you

Personal data collected, used, stored and transferred by us may include:

Identity Data including forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier

Contact Data including home address, email address and telephone numbers

Financial Data including banks statements, payment card details, savings, debts such as loans and credit cards, income & expenditure, employer & pension benefits, and other assets

Special Category Data inc. medical history and trade union / political party membership costs

Transaction Data including payments made for products and services you have purchased from us

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 on the devices used to access our website

Profile and Usage Data including purchases made by you, feedback and survey responses, and how you 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?

Personal data is collected by us using the following methods:

Direct interactions with an adviser in person, by post, phone (including call recordings and voicemail), email, videoconferencing or otherwise when sourcing and applying for mortgage or protection products, processing Identity, Contact and Financial categories of personal data.

Automated technologies or technical interactions with our website, via the My Mortgage Account portal, web enquiry form or the Find A Mortgage function, processing Identity, Contact, Financial and Technical categories of personal data.

Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as:
• Estate agents with whom you may be interacting, but only with your consent;
• New home builders, as a legitimate interest in order to assess affordability for the property;
• Enquiries you may perform on third-party mortgage sourcing websites;
• Your financial information from your bank available via Open Banking with your consent

How do we use your personal data?

Purpose/Activity Type(s) of data Lawful basis for processing
To initially engage with you to discuss your requirements
  • Identity
  • Contact
Consent
To source products, provide indicative quotes, and process & deliver your application for a mortgage or protection product
  •  Identity
  • Contact
  • Financial
  • Transaction
  • Marketing & Comms
  • Special Category
Performance of a contract with you to provide advice services
Special Category data – Explicit Consent (Medical information for protection policies)
To comply with FCA rules including record keeping, consumer duty, vulnerable customers, and to meet Anti Money Laundering legislation, and notifying you about changes to our terms or privacy policy
  • Identity
  • Contact
  • Transaction
Necessary for our legitimate interests
To create and maintain access to the My Mortgage Account portal account
  • Identity
  • Contact
  • Profile & Usage
  • Marketing & Comms
Performance of a contract with you
To manage our client relationship with you which will include:

  • Customer reviews / surveys
  • On-going communications until you are ready to proceed
  • Re-engagement when existing products nears expiry / review protection needs
  • Identity
  • Contact
  • Profile & Usage
  • Marketing & Comms
Necessary for our legitimate interests (as joint data controller with Mortgage Advice Bureau, to re-engage with you to review your existing mortgage / protection needs, to maintain and improve customer service standards, and to communicate with you as part of a nurture journey until you are ready to proceed with a mortgage / protection application)
To respond to case enquiries and input to & defend against complaints
  •  Identity
  • Contact
  • Profile & Usage
  • Transaction
  • Marketing & Comms
  • Special Category
Necessary for our legitimate interests (to ensure that complaints can be responded to accurately)
Special Category data – Legal Claims & Judicial Acts
To perform an affordability check for a property on behalf of an Estate Agent or New Home Builder
  •  Identity
  • Contact
  • Financial
Necessary for our legitimate interests and of the New Home Builder / Estate Agent (to ensure that a property is affordable before the purchase process)
Record appointments to perform checks on the quality of advice our advisers provide to clients
  • Identity
  • Contact
  • Special Category
Consent
Special Category data – Explicit Consent
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • Identity
  • Contact
  • Technical
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  • Identity
  • Contact
  • Profile & Usage
  • Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use cookies, data analytics and other systems to improve our website, products/services, marketing, customer relationships and experiences
  • Identity
  • Technical
  • Profile & Usage
Consent / Explicit Consent
To use systems including AI and automated decision making to support our services and assist with document validation, affordability and product sourcing
  • Identity
  • Contact
  • Financial
  • Special Category
Necessary for our legitimate interests (to assist advisers with the advice process and inform our client re-engagement and marketing strategy)

We only use your personal data for the purposes stated above, unless we reasonably consider that we need to use it for another reason and it is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

Changes to our Privacy Notice

We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 31st May 2024. Historic versions can be obtained by contacting us.

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. However please note that currently no automated decisions are made using such systems that have a legal or similar effect on clients, and all results are reviewed by advisers or administrative staff. If you require any further information about this data processing please contact [email protected]

Marketing communications

You will also have the choice to opt-in to receiving other related marketing information and related products and services. You can opt-out of receiving these types of communications at any time by contacting your adviser, by emailing [email protected] or by clicking on the relevant link in email communications you receive from us. However please note that your personal information will not be passed to any third-party organisation for marketing purposes.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to only those Mortgage Advice Bureau staff, appointed representatives, advisers, business partners and suppliers who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 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.

Cookies

When using our website, you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Website Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those 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.

Sharing of personal data outside of the United Kingdom

Some 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 suppliers in order to provide the same level of protection for personal data as it has in the UK.

Who we disclose personal data to

Type of recipient Reason
Within the Mortgage Advice Bureau network Depending on your requirements, it may be necessary to share your personal data with our network and with specialist product providers in order for suitably qualified advisers to source relevant products and services or to re-engage with existing clients, and to obtain input from specialist trainers within our network to improve advice quality.
Lenders and protection product suppliers To source and submit applications in order to conclude the contract for the mortgage / protection application and the ongoing servicing of these contracts, and to support quality checks and ensure full disclosure of information to lenders and protection providers.
Financial Institutions To source your bank account information via Open Banking with your consent
External suppliers Specialist IT system providers to deliver our service to you (including sourcing of 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). We may also 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 us.
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.
Solicitors / Conveyancers To update the firm of solicitors / conveyancers with whom you are interacting about the progress of your application and confirm your identity / proof of deposit.
Estate agents / new home builders To update the firm of mortgage / protection advisers, estate agents and home builders with whom you are interacting about the results of affordability checks and progress of your application.
ID verification & Licensed Credit Agencies For the purposes of confirming your identity to comply with Anti Money Laundering requirements (GB Group data processing information can be found at https://www.gbgplc.com/en/legal-and-regulatory/products-services-privacy-policy/); and to perform a credit assessment to assess your eligibility; to obtain a Lenders Decision In Principle; and as part of a full application.
Regulators In order to fulfil our legal obligations as a regulated profession, for example with the Financial Conduct Authority, to verify your identity and comply with Anti Money Laundering legislation, and otherwise co-operate with law enforcement, legal proceedings or regulatory authorities.
Others 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

These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of your personal data, and to use your personal data only in the course of providing such services and in accordance with our instructions.

How long is your personal data retained?

 

Purpose of processing Retention
Successful mortgage / protection applications For the full mortgage or protection policy term plus a further 6 years, or for a period of 30 years for historical cases if the original term is not recorded
Withdrawn, stalled, incomplete and failed mortgage / protection applications 2 years from the date the latest application was started, or 6 years from the application submitted date if application was submitted and subsequently rejected or from creation date if advice has been provided but not pursued
My Mortgage Account portal account 2 years from date of last login if not proceeded to full application
Affordability checks 2 years from Decision In Principle if affordability check does not proceed to a full mortgage application
Enquiry data obtained from third parties that do not result in an application 2 years from the date the lead was received from the Introducer
Video recordings of appointments used for quality checking of advice Up to 1 month after the appointment date

After these retention periods if there is no other on-going client relationship your personal data will either be securely deleted or anonymised so that it can be used for statistical purposes but without any method of identifying you individually.

Your legal rights regarding your personal data

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. You can also ask us to delete your personal data where you have successfully objected to the processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to delete the data for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Questions

If you have any questions or complaints relating to how we use your personal data, or if you wish to exercise any of your rights, please contact [email protected] or by writing to us. We will respond to you as soon as is possible, and 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 we have responded to your enquiry, you have the right to complain to the Information Commissioner’s Office (ICO) as the regulator for data protection in the UK.