Privacy Notice

Controller
Interbridge Mortgages Limited is the controller and responsible for your personal data (“Interbridge Mortgages”, “we”, “us” or “our” in this privacy notice).

Contact details
If you have any questions about this privacy notice or our privacy practices, please contact our Data Protection Officer (DPO) in the following ways:

Full name of legal entity: Interbridge Mortgages Limited

Email address: enquiries@ib-mortgages.com

Interbridge Mortgages Limited, Coal House, Dumfries Place, Cardiff CF10 3RJ

Should you have a concern regarding the way we have handled your data, you do have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

This means we may send you an updated copy (depending on whether we are required to do that or not). You can also check the latest notice on our website. For access to historic versions, please contact us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes at any time during your relationship with us.

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 and/or policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

• Your full name and title;

• Your home address, correspondence address (where different from your home address), email address, home and mobile telephone numbers;
• Your address history;
• Your date of birth and/or age;
• Identification documents including document type, date of expiry and country of issue;
• A short video/face identification, verification and recognition technology of yourself when you set up an account with us via a Secure Communications Network;

• Your signature or e-signature;
• Your nationality, if this is necessary for us to comply with our legal and regulatory requirements;
• Records of how you have contacted us and, if you get in touch with us online, details such as your mobile phone location data, IP address and MAC address;

• Details of shareholdings, prominent functions, directorships and/or employment including for instance your occupation, salary, employer and length of service;
• Information about your employment status including whether you are employed/self-employed, retired or receive benefits;
• Performance of your mortgage;
• Where relevant, in relation to adverse credit, information about creditors and supporting references;

• Bank account and payment card details

• Information about your occupier status at the time of your application;
• Information which is relevant for your residency and/or citizenship status, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK;

• For residential customers, your marital status, family, lifestyle or social circumstances if relevant to the mortgage product (e.g. the number of dependents you have or if you are a widow or widower).

• Personal information which we obtain from Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (see the section on ‘Credit Reference and Fraud Prevention Agencies’ below);

• Details of your services with us including for instance application information, affordability assessments, credit history, customer ID number, account number, account balance, account history, security or collateral held by us, and details relating to any other signatories;
• Security identifiers including for instance mother’s maiden name;
• Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Information about how you use our website, mobile device applications, secure messaging, and webchats for products and services.
• Details about payments to and from you and other details of products and services you have purchased from us.

• Information you have provided in receiving marketing from us and/or companies within the Interbridge Group and your communication preferences.

Intermediary interactions

We will collect your personal information via a broker or other intermediary, when they introduce you to us or during interactions that you have with us during the lifetime of your mortgage.

Third party and publicly available sources

In addition, we may obtain your personal information from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, your Employer, Landlord, Other Lenders, HMRC, DWP, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.

Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources. In particular, Credit Reference Agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about Credit Reference Agencies below. We have also mentioned above in the lists of personal information that we process some of the Credit Reference Agencies’ other sources of information (which are our own source of information too).

We may also obtain Technical and Profiling Data (defined in section above) from the following third parties:

• analytics providers such as Google, based outside the UK;
• advertising networks such as, but not limited to Facebook, Google, Bing,  based outside the UK;
• search information providers [such as Google and Bing, based outside the UK;

and other third party analytics and or search providers.

We may also obtain Identity Data in the form of facial verification and recognition technology to verify identity.

In order to set up and administer your account, we as the mortgage lender and your intermediary may use a secure messaging platform to;

• provide (from us to you or you to us) correspondence, data, documentation and personal information as part of joining and applying for a mortgage and prior to and entering into a contract with us;

• provide images of documentation and yourself to support our identification checks, fraud and money laundering controls; and
• To address any queries about your account.

Electronic Signatures  

We utilise electronic signature applications to enable contracts and notices to be signed.  In utilising such tools our employees, brokers acting on our behalf, third party suppliers and you may provide limited personal data for the purposes of:

• business execution and in particular for the conclusion and execution of agreements between us and you;
• for compliance with legal or regulatory requirements including litigation and defence of claims; and
• for the prevention, detection and investigation of fraud.

Automated technologies or interactions

As you interact with us, we will automatically collect some Technical and Profile Data about your equipment, interactions, voice analysis, browsing actions, usage data and patterns. We collect this personal data by using cookies [server logs] and other similar technologies.

We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

We will only use your personal data where the law allows us to. We will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with any legal obligation.

We do not normally rely on consent as a legal basis for processing your personal data, although we will ask for your consent before sending you Interbridge marketing communications or  to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

What we do with your personal information is not generally based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details above. The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about your health or well-being (but these outcomes will be relevant only in cases where we rely on explicit consent for this).    

We will tell the intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.   

To comply with payment services regulations, we have to share some of your personal information with other payment service providers, in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. This is why if you ask to withdraw consent from what we do with your personal information, we may still have to hold and use your personal information where we need to have it in relation to the payment services regulations.

We work hard to protect your personal data. We use both technical and procedural methods to maintain the integrity and security of our databases, encryption for data transfer, firewalls and restricted access to data. 

The safety and security of your data also depends on you. You should never share your account information such as your password or login with anyone else.  If you believe anyone has unauthorised access to your account, you should inform us as soon as possible.

We may share your personal data with the parties set out below for the purposes set out in the table above: 

• Internal third parties including members of the Interbridge Group;  
• External third parties such as but not limited to, Callcredit, Equifax, Experian
• Joint account holders and any person with power of attorney over your affairs (in each case only if relevant to you);  
• Credit reference agencies and fraud prevention agencies (see below); 
• Other payment services providers such as when you ask us to share information about your account with them;  
• Other account holders or individuals when we have to provide your information to them because some money paid to you by them should not be in your account;   
• The intermediary who introduced you to us;  
• Our legal and other professional advisers, auditors and actuaries;  
• Financial institutions and trade associations;   
• Governmental and regulatory bodies (including but not limited to) such as HMRC, the Financial Conduct Authority, the Financial Ombudsman Service, the Information Commissioner’s Office and under the Financial Services Compensation Scheme;   
• Tax authorities who are overseas for instance if you are subject to tax in another jurisdiction we may share your personal information directly with relevant tax authorities overseas (instead of via HMRC);   
• Other organisations and businesses who provide services to us such as debt recovery agencies, Field Agents, Estate Agents, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;  
• Insurers of any asset securing or proposed to secure your liabilities  
• Buyers, counterparties, rating agencies and other relevant parties and their professional representatives as part of any actual or potential restructuring or sale of any or all of our assets (including by way of a securitisation or similar transaction); and 
• Market research organisations who help us to develop and improve our products and services. These firms may get in touch to ask you for your opinions and feedback. Sometimes these firms will combine what you tell them with data from other sources to study it. They will use this to produce reports and advice that help us understand our customers’ point of view, so that we can improve the way we work as a business. 

We are based in the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area. If it is processed within Europe or other parts of the European Economic Area (EEA) then it is protected by European data protection standards. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us.

We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA, which do not have adequate protection under laws that apply to us.       

For more information about suitable safeguards and (as relevant) how to obtain a copy of them, or to find out where they have been made available, you can contact us using the details above.

Credit reference agencies 

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies. Where you take mortgage services from us we may also make periodic searches at Credit Reference Agencies to manage your account with us. To do this, we will supply your personal information to Credit Reference Agencies and they will give us information about you. This will include information from your credit application and about your financial situation and financial history.  Credit Reference Agencies will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.   

We will use this information to:  

• Assess whether you can afford to take the product;  
• Verify the accuracy of the data you have provided to us;  
• Prevent criminal activity, fraud and money laundering;  
• Manage your account(s);  
• Trace and recover debts; and  
• Ensure any offers provided to you are appropriate to your circumstances.   

We will continue to exchange information about you with Credit Reference Agencies, while you have a relationship with us. We will also inform the Credit Reference Agencies about your settled accounts. If you, as a residential customer, borrow and do not repay in full and on time, Credit Reference Agencies will record the outstanding debt. This information may be supplied to other organisations by Credit Reference Agencies. The identities of the Credit Reference Agencies, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the Credit Reference Agencies are explained in more detail which we refer to later on in this privacy notice.  

When Credit Reference Agencies receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.   

If you are making a joint application, or tell us that you have a spouse, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. Credit Reference Agencies will also link your records together and these links will remain on your and their files until such time, as you or your partner successfully files for a disassociation with the Credit Reference Agencies to break that link. 

For further information and full details about how your data is processed please refer to the Credit Reference Agency Information Notice (CRAIN).

Fraud prevention agencies 

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found below.  

Further details of how your information will be used by fraud prevention agencies, and your data protection rights, can be found by accessing the following link: Fair Processing Notices for Cifas’ Databases | Cifas. The full fair processing notice is shown at the end of this document.

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. 

However, most of the personal information is or will be stored by us for a maximum of twelve years after your account is closed, unless a longer retention period is required in case of: queries from you; legal claims by you; and/or legal or regulatory requirements to which we are subject. If you would like further information about our data retention practices, please contact us.  

If your application is unsuccessful  

If your application is unsuccessful or if you decide not to proceed on the rate we have proposed, we will retain some of your personal information related to the application or the pre-application quotation searches (including if you applied through a broker or other intermediary) for the following legitimate interests:  

(a) First, we have a legitimate interest in managing the risk to our business of money laundering, fraud and other crimes and in meeting our legal and regulatory obligations in these circumstances. We have to be able to identify where there is a particular risk of these serious issues arising. For example, if an individual (or individual on behalf of a company) resubmits the application or makes a second enquiry pre-application for a rate quotation, and if he or she does this through a different broker or intermediary amending certain details or circumstances, it would be very important to identify that. Similarly, if our identity checks, anti-money laundering checks, checks with Fraud Prevention Agencies or Credit Reference Agencies pre-application or during the application (as relevant) reveal risk – we would retain the relevant details until we were satisfied that we no longer needed them for the legitimate interest we have mentioned here.  

(b) Secondly, where there is a decision not to proceed on the rate that we offer, we have a legitimate interest in keeping a record of that rate and some of the personal information related to our offer in order to take account of it when an individual (or individual on behalf of a company) resubmits the application or makes a second enquiry. It would be contrary to this legitimate interest if individuals were able to resubmit through another broker or intermediary soon afterwards and if we were unable to identify the rates we had already offered having carefully considered their initial application.  

It is necessary to process and retain personal information for these legitimate interests and we have balanced these against your own interests, rights and freedoms. In circumstances such as these, we do not retain your personal information for longer than necessary and we do not share that information. Your personal information is used for our own strict requirements and in accordance with data protection laws. 

Individuals have a number or rights under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them, we will explain at that time if they apply or not.   

• The right to be informed about your processing of your personal information;  
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;  
• The right to object to processing of your personal information;  
• The right to restrict processing of your personal information;  

• The right to have your personal information erased (the “right to be forgotten”);  
• The right to request access to your personal information and to obtain information about how we process it;  
• The right to move, copy or transfer your personal information (“data portability”);   
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.  

You have the right to complain to the Information Commissioner’s Office, which enforces data protection laws: https://ico.org.uk/ 

If you wish to exercise any of these rights against the Credit Reference Agencies, the Fraud Prevention Agencies, or a broker or other intermediary who is data controller in its own right, you should contact them separately.   

If you wish to access your personal information, please contact us in writing at the following address: Coal House, Dumfries Place Cardiff CF10 3RJ or you can also email us at: enquiries@interbridgemortgages.com

In order to protect your personal information, we may require identification from you before releasing the requested information.

Monitoring here means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.   

We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or in person meetings (as relevant) we will do so.  

Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes. 

We may conduct short term carefully controlled monitoring of your activities on your account(s) where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes.   

Telephone calls, written communication, emails (including mobile device applications, secure messaging, webchats) and/or in person meetings between us and you in connection with your application and/or your account(s), may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes.  

This refers to where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. For instance, in relation to transactions on your account(s), payments into your account(s) from other providers, and triggers and events such as account opening anniversaries and maturity dates. We may do this to decide what marketing communications are suitable for you, to analyse statistics and assess lending risks.

We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) only where the profiling and other automated decision making does not have a legal or other significant effect on you.

In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases, you have the right to obtain human intervention to contest the decision (see ‘rights in relation to automated decision making which has a legal effect or otherwise significantly affects you’ below). Profiling for direct marketing can mean there is a separate right to object (see ‘right to object’ above).  

We may use your home address, phone numbers, email address and social media accounts to contact you.

We may also use “cookie data” from visits to our website to market to you across Google and other search engines, certain websites, social media and other messaging platforms.

We will only ever market to an existing customer in line with your marketing preferences. This means we only do this if we have a legal ground which allows it under data protection laws – see above for what is our legal ground for marketing.

You can stop our marketing at any time by contacting us, by following the instructions on how to do that in the marketing email or other communications we send to you. 

1. Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

2. The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

3. Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.

4. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime

5. We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

6. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

AUTOMATED DECISIONS

7. As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more please contact us using the details above.

CONSEQUENCES OF PROCESSING

8. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
9. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, please contact us on the details above.

DATA TRANSFERS

10. Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

YOUR RIGHTS

11. Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data, request that your personal data is erased or corrected, and request access to your personal data.
12. For more information or to exercise your data protection rights, please contact us using the contact details above.
13. You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.