- 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.
- The personal data you have provided, we have collected from you, or we have received from third parties will be will be used to prevent fraud and money laundering, and to verify your identity.
- Details of the personal information that will be processed, for example:
- date of birth,
- contact details,
- financial information,
- employment details,
- device identifiers including your IP address
- We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
- Fraud Prevention Agencies 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.
- 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.
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 or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; 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 provided.
Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us and data we collect when you use our services, or from third parties we work with.
We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.
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 that of known fraudsters or money launderers; 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
- If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, or we may stop providing existing services to you.
- 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 provided.
Sharing Personal Information
We may share your personal information with:
- Credit reference agencies, fraud prevention and other agencies that carry out certain activities on our behalf, our approve suppliers to help with repossessions, solicitors or surveyors;
- Regulators, law enforcement, the Financial Ombudsman Service; other regulators, HMRC;
- Mortgage Brokers, Packagers, advisers and organisations that introduce us to you; and
- If we decide to sell, transfer or merge our business / assets eg your mortgage, we will share your information with these parties but only if they agree to keep your data safe and private.
Data Transfers Out of the EEA
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
Sending Data Outside of the EEA
If your personal data is transferred outside the EEA it will only be as a result of your instructions, to comply with a legal duty or to agents /advisers to help run the account and services. If the data is transmitted outside the EEA it will only be to a country with privacy laws that give the same protection as the EEA, have signed a contract that they will abide by the same protections as the EEA and if sent to the USA only to those companies with a Privacy Shield.
- 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; request access to your personal data or ask that an automated decision is reviewed by a person.
- You have the right to withdraw any consent you have given at any time.
- For more information or to exercise your data protection rights please, please contact us using the contact details provided.
- You also have a right to complain to the Information Commissioner's Office which regulates the processing of personal data.
How the Law Protects You
Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Foundation Home Loans. The law says we must have one or more of these reasons:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
The majority of the work we do for you is to fulfil a mortgage contract(s) or because it is our legal duty to do so.
How Long We Keep Your Personal Information
We will keep your personal information for as long as you are a customer of Foundation Home Loans.
After you stop being a customer, we may keep your data for up to 5 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that applies to us.
We may keep your data for longer than 5 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
- Foundation Home Loans is a trading style of Paratus AMC Limited.
- Our registered Office is 5 Arlington Square, Downshire Way, Bracknell, Berkshire RG12 1WA.
- Paratus AMC Limited is authorised and regulated by the Financial Conduct Authority. Our registration number is 301128.
- You can find out more about us at foundationhomeloans.co.uk
- Or you can call us on 0344 770 8030
- Or write to:
The Data Protection Officer
Foundation Home Loans
5 Arlington Square
Further details can be found in our Privacy Notice.
Occasionally it may be necessary to make changes to this notice. When that happens we will provide you an updated version at the earliest opportunity. The most recent version will always be available on our website.