Introduction
Brokers Ireland Network Services Limited is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of Brokers Ireland Network Services Limited in relation to the information we obtain and process about data subjects.
For the purposes of the GDPR we are a data controller of personal data obtained by us from brokers. The personal data will include data of the brokers’ owners, of their staff and of their customers. As data controller our specific contract and other details are:
Corporate Name: Brokers Ireland Network Services Limited
Trading/Business Name: Brokers Ireland Mortgage Services
Registered office and trading address: 87 Merrion Square, Dublin 2.
Tel: 01 4922203
Email: Info@brokersirelandmortgages.ie
When we refer to ‘we’ it is to Brokers Ireland Network Services Limited that we are referring.
Please read this Statement carefully as this sets out the basis on which any personal data we obtain about you, or that you provide to us, will be processed by us.
Who are we?
Brokers Ireland Network Services Limited trading as Brokers Ireland Mortgage Services, formally named PIBA Mortgage Services, is a wholesale brokerage whose primary function is to provide a professionally managed, mortgage packaging service through which brokers, who are members of Brokers Ireland, can access a large number of lending institutions for the purposes of obtaining mortgage product for the brokers’ customers. The brokers using our service can, therefore, provide their customers with greater choice and superior service. We are a subsidiary of the non-profit organisation Brokers Ireland. Brokers Ireland is the largest Insurance and Mortgage Broker representative body in Ireland.
We have appointments with almost all lenders in the Irish Mortgage Market. This means that through their appointments with Brokers Ireland Mortgages Services, brokers can select the most suitable mortgage for their consumers from a wide panel of lenders even if they do not hold a direct appointment with such lenders.
We have invested in the technology to create a system which will give instant analysis of mortgage products, comparison of what lenders will offer the consumer and online submission of mortgage applications for maximum efficiency.
We also have dedicated mortgage underwriting and administrative staff to back up the expertise of the Brokers Ireland Mortgage Services.
Brokers Ireland Mortgage Services, formally named PIBA Mortgage Services, was initially formed under the auspices of the Professional Insurance Brokers Association (PIBA) now referred to as Brokers Ireland. Membership of the mortgage network is exclusive to Brokers Ireland members..
Our and data protection representatives can be contacted directly here:
GDPR@brokersirelandmortgages.ie
01 492 2203
How we collect your information
Brokers
When as an Introducing Mortgage Intermediary you engage the services of Brokers Ireland Network Services, details of your firm and employee contacts within your firm will be retained on our CRM and Online application system. This data will be held on these systems to enable your firm to transact business with Brokers Ireland Network Services.
Client Data
When brokers’ customers’ personal data is given to us, Brokers Ireland Network Services will process the personal data (which may include special categories of personal data) for the purposes of providing the customer with a mortgage.
Customer data is sent to us via our Online Application System or in print format by post or by email. This data is inputted into various lender systems but will only be submitted to a lender with the customer’s prior approval by way of a signed declaration.
Why we are processing your data? Our legal bases.
We process the personal data of customers of brokers because such is necessary for the performance of the contract which the customer has directed the broker to pursue. We process the personal data of brokers and their staff and agents as we have a legitimate interest in doing so in the direct relationships that we have with our broker clients.
The collection and processing of personal data is necessary for submitting applications on behalf of brokers and their customers to lenders.
To process data lawfully, we also rely on one or more of the following legal bases:
- your consent;
- performance of a contract;
- legal obligation (e.g. “Minimum Competency Code”, “Fitness & Probity”, TCA 1997);
- protecting the vital interests of you or others;
- public interest; and
- our legitimate interests or the legitimate interests of a third party (e.g. your employer).
In any event, Brokers Ireland Network Services Limited is committed to ensuring that the information and data that we collect and use is appropriate for this purpose, and does not constitute an invasion of the data subject’s privacy.
How will Brokers Ireland Network Services Limited use the personal data it collects about me?
Brokers Ireland Network Services Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin), we will ensure that specific measures are being taken to safeguard the fundamental rights and freedoms of data subjects. The processing of data concerning health is lawful where it is necessary and proportionate for the purposes of:
(a) a policy of insurance or life assurance,
(b) a policy of health insurance or health-related insurance,
(c) an occupational pension, a retirement annuity contract or any other pension arrangement, or
(d) the mortgaging of property.
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to Brokers Ireland Network Services Limited in the course of dealing with your data. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfill the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Brokers Ireland Network Services Limited procedures.
- The third parties that we pass your personal data to are:
- Lending Institutions, whom you will have consented to us passing on your data to.
- Our parent company, Association of Insurance & Financial Brokers trading as Brokers Ireland
- Data processors: Mortgage Brain & Ergo, both online systems used to process mortgage applications.
We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions. We have also issued Data Processing Agreements to all our processors.
If we transfer personal data to a third party or outside the EU, we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and will ensure that enforceable data subject rights and effective legal remedies for the data subject are available. We can confirm at the time of issuing this privacy notice that no such transfers are in place.
Data Subjects’ Rights:
Brokers Ireland Network Services Limited facilitates data subjects’ rights in line with our data protection policy and our subject access request procedure. This is available on request.
Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party data processor involved as we have indicated in the processing of your personal data.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Brokers Ireland Network Services Limited will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body the Central Bank of Ireland, the Financial Ombudsman and our Internal Governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Brokers Ireland Network Services Limited or how your complaint has been handled, you have the right to lodge a complaint directly with the Data Protection Commission (see below) and Brokers Ireland Network Services Limited.
You may also contact the Data Protection Commission in Ireland to lodge a complaint (details below).
Data Protection Commission
Canal House,
Station Road,
Portarlington,
Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Web: www.dataprotection.ie
Email: info@dataprotection.ie
Failure to provide further information
If we are collecting your data for a mortgage contract and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.
Additional Processing
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.
Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us.
Privacy statement changes
Brokers Ireland Network Services Limited may change this privacy statement from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy statement periodically so that you are aware of any changes. By using our services you agree to this privacy statement.
This privacy statement was last reviewed in April 2018
