Privacy Policy

The Mortgage People (TMP) are an Appointed Representative of Mortgage Advice Bureau Ltd and Mortgage Advice Bureau (Derby) Limited and are authorised and regulated by the Financial Conduct Authority.

The personal information we receive

As the controller of your data, TMP comply with Data Protection Laws in the United Kingdom. This Privacy policy details how TMP processes your personal data.

The personal data we collect about you

• • • 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 bank 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 TMP 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 marketing and communication preferences in receiving information and marketing from us and our business partners, and recordings of all communications by telephone

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, call recordings, or otherwise when sourcing and applying for mortgage or protection products, processing Identify, Contact and Financial categories of personal data
    • Automated technologies or technical interactions with our website, via the customer portal, web enquiry form, processing Identity, Contact and Financial categories of personal data
    • Third parties or publicly available sources (processing Identity, Contact and Financial categories of personal data) such as:
      • Housing Associations with whom you may be interacting but only with your consent;
      • New home builders, as legitimate interest of the builder in order to assess affordability for the property;
      • Estate agents with whom you may be interacting but only with your consent
      • Enquiries you may perform on third-party mortgage sourcing websites/Housing Association websites
      • Your financial information from your bank available via Open Banking with your consent

If we are working on behalf of a Housing Association or Registered Provider who are the data controller, they may share some or all of the following data to TMP as the data processor in order to initiate contact:

The personal information we receive

• • • 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

The personal information we then process about you

After contacting you, the personal information TMP processes 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
    • Profile and Usage Data including purchases made by you, feedback and survey responses, and how you use our website, products and services

How do we use your personal information?

We use your personal information in the following circumstances:

Purpose/Activity	Type(s) of data	Lawful basis for processing
To assess and process your application for a Housing Association/Registered Provider property	Identity Contact Financial Profile & Usage Marketing & Comms	Part of a contract with a Housing Association / Registered Provider) Legal Obligation
To initially engage with you to discuss your requirements	Identity Contact Marketing & Comms	Consent
To source products, provide indicative quotes, and process and deliver your application for a mortgage or protection product	Identity Contact Financial Special Category Transaction Marketing & Comms	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 relationship with you which will include: 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 (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 new build property on behalf of an Estate Agent or New Home Builder	Identity Contact Profile & Usage Marketing & Comms	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 (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 to improve our website, products/services, marketing, customer relationships and experiences	Technical Profile & Usage	Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our 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 or an explanation as to how any new processing 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 and we will place any updates on this web page. This Privacy Notice was last updated on 13th February 2020.  Historic versions can be obtained by contacting us.

Marketing communications

Your personal information collected as part of an application for a Housing Association / Registered Provider property will not be used for the purposes of 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 chirpy@tmpmortgages.co.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 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.

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.  Where we use providers based in the US, we may transfer data to them if they are registered with the EU-US Privacy Shield scheme which requires them to provide protection to personal data equivalent to the General Data Protection Regulation (GDPR), and have extended their registration to cover data shared with the UK once the UK leaves the European Union.

Who we disclose personal information to?

Your personal information may be shared with third parties for the following purposes:

Type of recipient	Reason
Internally within Mortgage Advice Bureau Group	Depending on your requirements, it may be necessary to share your personal data with Mortgage Advice Bureau’s 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 facilitate the sourcing of products, to provide continuing advice, to inform you about relevant products and services, and to request feedback on customer service standards. It may also be necessary to share your personal information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to TMP
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
Housing Associations / Registered Providers/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; and to provide a copy of the mortgage offer to support 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 Lender’s Decision in Principle; and to perform a credit assessment with your consent as part of a full application
Regulators	Sharing of information may be necessary to fulfill 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 information, and to use your personal information only in the course of providing such services as specified by TMP.

How long is your personal information retained?

Purpose of Processing	Retention
Data processed for Housing Association/Registered Provider applications	6 years from the date of application as part of a legal obligation
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	6 years from the date the latest application was started
Client Portal accounts	2 years from date of last login if not proceeded to full application
Affordability assessments	6 years from Decision in Principle if affordability check does not proceed to full mortgage application
Enquiry data obtained from third parties (Estate Agents, websites) that do not result in an application for a mortgage/protection product	6 years from the date the lead was received from the Introducer

After this retention period if there is no other on-going client relationship your 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 information

You have the right to:

• • • Access your data, to receive a copy, and to check it is being processing lawfully
    • Request correction so any incomplete or incorrect data is updated
    • Request erasure where there is no reason for us to continue processing it, or if it has been processed unlawfully, or you have successfully objected (see below). Please note however we may not always be able to delete the data if a legal reason exists for us to continue processing it
    • 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 feel it impacts on your fundamental rights and freedoms. 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 if (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 the use of your personal information, or if you wish to exercise any of your rights regarding your personal information, please contact chirpy@tmpmortgages.co.uk or write to Data Protection, TMP The Mortgage People, Aspen House, 13 Medlicott Close, Corby, NN18 9NF.  You will receive a response 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 your enquiry has been dealt with, you have the right to complain to the Information Commissioner’s Office (ICO), who is the regulator for data protection in the United Kingdom.