Client Privacy Notice

 

Brook Financial Services Limited. Registered Office: The Old Courthouse, 60A London Road, Grantham NG31 6HR. Registered in England Number: 07311674

 

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”

 

Brook Financial Services Limited is an Appointed Representative of Mortgage Advice Bureau and Mortgage Advice Bureau (Derby) Ltd. As joint controllers of your data, we comply with Data Protection laws in the United Kingdom. This Privacy Policy details how we process 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 the Mortgage Advice Bureau 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 customer 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 comply with a legal obligation

Necessary for our legitimate interests 

(to recover debts due to us)

Explicit Consent

To manage our client relationship with you which will include:

  • Create and maintain access to your customer portal account

  • Notifying you about changes to our terms or privacy policy

  • Customer reviews / surveys

  • Re-engagement when existing products nears expiry / review protection needs

  • Identity 

  • Contact 

  • Profile & Usage

  • Marketing & Comms

Performance of a contract with you 

To comply with a legal obligation

Necessary for our legitimate interests

(with Mortgage Advice Bureau and Brook Financial Services as joint controllers, to re-engage with you to review your existing mortgage / protection needs, and to maintain and improve customer service standards)

To respond to case enquiries and input to & defend against complaints

  • Identity

  • Contact

  • Profile & Usage

  • Transaction

  • Marketing & Comms

  • Special Category

To comply with a legal obligation

Necessary for our legitimate interests 

(to ensure that complaints can be responded to accurately)

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

  • Profile & Usage

Necessary for our legitimate interests and of the New Home Builder / Estate Agent (to ensure that a property is affordable before proceeding with the purchase process) 

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

To comply with a legal obligation

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 

  • Marketing & Comms 

  • 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 data analytics and other systems including AI and automated decision making to improve our website, products/services, marketing, customer relationships and experiences

  • Identity 

  • Contact 

  • Financial

  • Special Category

  • Technical 

  • Profile & Usage 

Consent / Explicit Consent

Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business, and to inform our client re-engagement and marketing strategy)

 

Change of purpose 

We will 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. Please contact us for an explanation as to how any new processing 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. 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.Changes to our Privacy Notice

We keep our Privacy Notice under regular review. This Privacy Notice was last updated on 4th August 2020. 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 for re-engagement purposes as a legitimate interest to review your existing mortgage and source suitable new products. If you do not wish your data to be used by such systems, please notify us at data.protection@mab.org.uk

 

 

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 data.protection@mab.org.uk 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 to do so.

 

 

Cookies

When using the Mortgage Advice Bureau 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

Mortgage Advice Bureau 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 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 the General Data Protection Regulation (GDPR). This includes the use of standard contractual clauses approved by the European Commission in contracts with external suppliers in order to provide the same level of protection for personal data as it has in the EEA.Who we disclose personal data to

 

Type of recipient

Reason

Within Mortgage Advice Bureau

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 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.

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). 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 Mortgage Advice Bureau. 

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.

Licensed Credit Agencies

For the purposes of confirming your identity to comply with Anti Money Laundering requirements (TransUnion data processing information can be found in the privacy notice on the www.callcredit.co.uk website); to perform a credit assessment to assess your eligibility; as part of an application request for a Lenders Decision In Principle; and to perform a credit assessment with your consent 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 Mortgage Advice Bureau 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

Client Portal accounts

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

 

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.