TMP The Mortgage People (TMP) Registered Office: Aspen House, 13 Medlicott Close, Corby, NN18 9NF. registered in England Number:05559633
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 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, video conferencing, 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:
How do we use your personal data?
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||
||Part of a contract with a Housing Association / Registered Provider)
|To initially engage with you to discuss your requirements||
|To source products, provide indicative quotes, and process and deliver your application for a mortgage or protection product||
||Performance of a contract with you
To comply with a legal obligation
Explicit Consent/appropriate safeguards for the fundamental rights and interest of the data subject
|To manage our relationship with you which will include:
||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, 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||
||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||
||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)||
||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||
||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||
||Necessary for our legitimate interests (to analyse customer usage, update our website, to develop our business and to inform our 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 and we will place any updates on this web page. This Privacy Notice was last updated on 23rd January 2023. 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@example.com
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 firstname.lastname@example.org 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.
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.
Website third-party links
TMP’s 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 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.
Who we disclose personal data 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|
|ID Verification & Licensed Credit Agencies||For the purposes of confirming your identity to comply with Anti Money Laundering requirements (Credas data processing information can be found at https://credas.co.uk/privacy-notices/); and to perform a credit assessment to assess your eligibility; to obtain a Lender’s 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 TMP instructions.
How long is your personal data 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 these retention periods 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 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 to continue processing 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.
Clients 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 TMP processes their data can contact our EU representative DataRep by emailing email@example.com or by visiting their website www.datarep.com/data-request
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 firstname.lastname@example.org 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 TMP 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