GDPR is the General Data Protection Regulation. It comes into effect from 25 May 2018. It sets out a series of new EU laws concerning how data is processed and used. The objective of the regulation is to strengthen and standardise data protection laws for all EU citizens. These regulations will apply to any organisation that controls and/or processes data on behalf of an individual or group of individuals. Those responsible for adhering to these regulations include employees of the organisation, including contractors, consultants, agents and third parties who have access to data either directly or indirectly.
Data Protection at Haven Mortgages
Your information, our duty and your rights
To be our customer, you share information with us. To be your mortgage provider, we respect that information.
On this page you will find out how we do that and what your rights are. We think it’s important that you read this page. it will tell you everything you need to know.
Frequently Asked Questions
Who we are?
When we talk about “AIB”, or “us” or “we” on our Data Protection Notice and this website, we are talking about Allied Irish Banks, p.l.c. and its subsidiaries, affiliates and their respective parent and subsidiary companies (including AIB, EBS and Haven).
We share your information within AIB Group to help us provide our services, comply with regulatory and legal requirements, and improve our products.
What does this mean for AIB Group?
We have always appreciated your trust in us to collect, process and protect your information. As a data controller and processor of your personal data, we will continue to
develop on our strong risk culture by acting responsibly and putting your security at the front of our priorities;
manage our controls, processes and systems to continue improving our level of customer service while providing you with the assurance that your information is safe and secure; and
conduct our business in a fair and transparent way and ensure we minimise the risk of unfair outcomes for our customers or impact on their data rights and freedoms.
Our Data Protection Notice and website explains how we collect personal information about you, how we use it and how you can interact with us about it.
Data Protection Officer
Our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. You can contact our Data Protection Officer at DPO@aib.ie or by writing to them at Data Protection Officer, AIB, Bankcentre, Dublin 4.
How we collect information about you
We collect personal information from you, for example when you:
apply for a product; or
look for advice.
We will sometimes record phone conversations and we will always let you know when we do this.
When you apply to us for a product and during the lifetime of this product, we carry out information searches and verify your identity. We do this by sending and receiving information about you to and from third parties including credit reference agencies, and/or credit registers including the Central Credit Register and Irish Credit Bureau. We and these agencies/registers may keep records of our searches whether or not the product goes ahead.
What information do we collect about you?
This is some of the information we collect and hold about you when applying for and using our products:
Personal bank account details
Statement of net worth
Income and expenditure
Transactions, purchasing and spending activity
Credit card account
Revenue documents e.g. P60
Date of birth
Proof of identity and proof of address including driving license, passport and utility bills
Account positions and history
Tax Reference Number (TRN)
Credit records, worthiness, standing or capacity
Personal Public Service Number (PPSN)
Educational details or history
Origin/source of funds
Country of Birth
Purpose of your account
Partners and dependents
Special categories of data
Under GDPR, there are special categories that require additional safeguards for processing. In some instances, AIB will require this information for processing or it may be volunteered by you. These data types include:
Special categories of data
Is this information required?
Biometric data – Fingerprints, Facial and voice recognition
No - We do not request you to provide biometric data
Yes - We may collect health data from you when providing our products and services or to support you in times of financial difficulty or bereavement.
If health data is requested by AIB, we will ask for your consent.
Racial or ethnic origin
No - We do not ask you to provide details of racial or ethnic origin to provide our products and services.
No - We do not ask you to provide political opinions to provide our products and services.
Religious or philosophical beliefs
No - We do not ask you to provide religious or philosophical beliefs to provide our products and services.
Trade union membership
No - We do not ask you to provide trade union membership to provide our products and services.
No - We do not ask you to provide genetic data to provide our products and services.
No - We do not ask you to provide sexual orientation to provide our products and services.
How we use your information
We use information about you to:
provide relevant products;
identify ways we can improve our products;
maintain and monitor your products;
protect your interests; and
decide and recommend how our products and services might be suitable for you
To provide our products under the terms and conditions we agree between us, we need to collect and use personal information about you. If you do not provide this personal information, we may not be able to provide you with our products and services.
We analyse the information that we collect on you through your use of our products. This helps us understand your financial behaviour, how we interact with you and our position in a market place. Examples of how we use this information include helping protect you from financial crime, offering you products and services and personalising your experience.
All of our processing must be supported by a lawful basis, as discussed in our Meeting our legal and regulatory obligations section below.
Lawful basis for processing
To use your information lawfully, we rely on one or more of the following legal bases:
• performance of a contract;
• legal obligation;
• our legitimate interests;
• your consent;
• protecting the vital interests of you or others; and
• public interest.
To help you better understand where these lawful bases may apply, these are some examples for each lawful basis. In some cases, the same information is processed under more than one lawful basis:
Examples of what we use your information for
Performance of a contract – Processing your information is necessary for us to provide your products
Providing relevant products and services
We provide our customers with mortgage products.
We process your information to identify and authenticate you to use our products.
Maintaining and monitoring your products and services
We must continually monitor and update information to ensure your data is safe, accurate and up to date. This ensures we keep your personal details and financial products secure, and give you the best customer service.
To do this we may share information with third parties such as credit reference agencies, fraud prevention agencies and market research entities.
Collecting money owed to us
As part of our credit product agreements, we have the right to collect money owed to us.
In some instances, we will use third parties to help us obtain additional information and collect the debts owed to us.
Legal obligation – We must process this information to comply with our legal obligations
Identify and authenticate our customers
We process your personal information to identify and authenticate our customers.
We share your information with third parties when performing these checks.
Our legitimate interests –Legitimate interest means the interests of AIB Group in conducting and managing our business when providing products and services. The core legitimate interests of AIB Group are to provide the best customer service, introduce innovative products and services, and to protect our customers, employees and shareholders.
We will always assess whether the legitimate interest of AIB Group will adversely impact the rights and freedoms of the data subject prior to processing. We implement safeguards to ensure that the processing remains fair and balanced.
Our risk assessments help us understand what information we need, our business requirements, the impact on our customers and employees, alternative options for processing and how long we hold the information for.
Manage and understand risk
As a regulated financial institution, we must manage and understand our risk exposure to ensure our customers are protected and maintain a stable financial infrastructure.
We produce internal management information and models to understand risk across the bank, ensure necessary safeguards are in place and assess the design and effectiveness of these safeguards. We report this regularly to regulatory agencies.
Perform Credit, Anti-Money Laundering and Know Your Customer checks
To ensure responsible lending and offer you loans and mortgage products, we must perform a check to authenticate you and assess suitability for lending.
We may share information with credit reference agencies, fraud prevention agencies and centralised registers for these checks.
Manage our relationship with you
We keep our records up to date to contact you when required and provide the best customer service.
Analyse information and research your experiences dealing with us
We want to continually improve and better understand our customers. By collecting and analysing data from multiple sources, we can better understand the requirements of our customers and how we can improve products and service offerings.
This analysis also helps us run our business more efficiently and effectively.
Identify ways we can improve our products and services
We are always working to develop new products and innovative ways of bringing these to you.
We analyse the market and our customer base to better understand what people like and what people want from their mortgage provider.
Prevent financial crime and cyber attacks
We continually monitor and analyse transactions, financial behaviour and electronic devices to detect and prevent financial crime and cyber-attacks. This enables us to protect and secure our customers information, our networks and our financial interests.
We share information with third parties to prevent financial crime, report fraud, manage our risks and protect both our interests.
Sell whole or part of our business
We may share information with third parties and their advisors who are interested in or participating in the sale, securitisation, merger, liquidation, receivership of all or part of our assets such as loan portfolios and subsidiary companies. For example, the information shared may be required by the third party to assess value, to perform due diligence and to facilitate the ongoing management of assets.
Internal management information
We produce internal management information to run our business and better understand customer needs. This information enables us to make informed decisions and develop our strategy.
Your consent – We require your consent for processing certain information such as special category data.
We ensure your consent is obtained under the following principles
· Positive Action - Clear affirmative action is required. We will no longer use pre-ticked boxes, imply or assume consent in the event of no positive action from you.
· Free will – Your consent must be freely given and not influenced by external factors.
· Specific – We will be clear on what exactly we are asking your consent for.
· Recorded – We will keep a record of your consent and how we got it.
· Can be withdrawn at any time – We will stop data processing that requires your consent at any time you make a valid request. You can withdraw your consent at any time.
Special Categories of Personal Data is information relating to:
a) Racial or ethical origin, political opinions or religious or philosophical beliefs
b) Trade union membership
c) Biometric data (We may collect voice, facial or fingerprint information to identify data subjects)
d) Physical or mental health
e) Sexual Life/Orientation
f) Genetic data
Processing special category data
We require your consent when processing special category data.
In some instances, customers may provide health data. Given that this is a special category of data, we may have to obtain your consent before accepting this information for processing.
Protecting the vital interests of you or others
Sharing information to protect you
In some instances where we are concerned about your health and safety, we may share information to protect you and others. This may include where we suspect that you, or others, may become a victim of financial crime. In these cases, we may share information with third parties to help ensure your safety and the safety of others.
Prevention of fraud
We may share personal data under the public interest basis in relation to prevention of fraud. We may share information with third parties to reduce fraud risk and protect the public from financial loss.
Meeting our legal and regulatory obligations
To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. We may also gather information about you from third parties to help us meet our obligations.
When you apply to us for products and services, and during the time you use these, we carry out information searches and verify your identity. We share your information with credit reference agencies and/or credit registers including the Irish Credit Bureau (ICB) and the Central Credit Register (CCR).
When you enter into a credit agreement with us, this data is registered on both the ICB database and the CCR database. Each month ICB and CCR receives an update for each open account. This builds up a credit history which indicates how you are meeting the repayment terms of any credit agreements you may have.
When you apply for credit from us, we may access both the ICB and CCR's database to get your credit report. You may have loans from more than one member and your credit report will include details of all registered loans, open and closed. Credit agreements are retained on the ICB and the CCR database for five years after they are completed.
Equally, you may not have any credit history in the cases where you have not borrowed previously, or any credit agreements have been closed for more than five years.
Central Credit Register (CCR)
The CCR was established by the Credit Reporting Act 2013 and is operated by the Central Bank of Ireland. It collects and stores personal and credit information on credit agreements of €500 or more for products such as loans, credit cards, overdrafts and mortgages. The aim of the CCR is to provide greater protection and promote greater financial stability by providing lenders with comprehensive information to support credit assessments.
When you apply for credit from us or enter into a credit agreement with us of €500 or more, this information will be reported to the CCR and then updated monthly while the credit agreement remains in place. Information sent to the CCR also includes your Personal Public Services Number (PPSN) or Tax Reference Number (TRN) which is collected to enable the CCR to complete accurate customer identification. From 30 September 2018, if you apply for credit from us of €2,000 or more, we are required by law to make an enquiry to the CCR about your credit history. Information about your credit agreements will remain on the CCR database for five years after the agreement ends.
Further information on the CCR is available at www.centralcreditregister.ie or www.aib.ie/ccr or by calling (lo call) 1890 100 050 or 01 2245500. You can also send a specific query to firstname.lastname@example.org.
Irish Credit Bureau (ICB)
When you enter into a credit agreement with us, this information is registered on the ICB database and then updated monthly while the credit agreement remains in place. This builds up a credit history which indicates how you are meeting the repayment terms of any credit agreements you may have. When you apply for credit from us, we may access ICB’s database to get your credit report which provides us with a summary of your credit history. You may have loans from more than one member of the ICB and your credit report will include details of all registered loans, open and closed. Credit agreements are retained on the ICB database for five years after the agreement ends.
Equally, you may not have any credit history in the cases where you have not borrowed previously, or any credit agreements you previously had ended more than 5 years ago.
Further information on the ICB is available in their full notice on their website www.icb.ie/pdf/Fair Processing Notice.pdf
NOTICE FROM IRISH CREDIT BUREAU D.A.C (‘ICB’)
As a result of the introduction of the General Data Protection Regulation (‘GDPR’), from 25th May, 2018 ICB will be using Legitimate Interests (GDPR Article 6 (f)) as the legal basis for processing of your personal and credit information. These Legitimate Interests are promoting greater financial stability by supporting a full and accurate assessment of loan applications, aiding in the avoidance of over-indebtedness, assisting in lowering the cost of credit, complying with and supporting compliance with legal and regulatory requirements, enabling more consistent, faster decision-making in the provision of credit and assisting in fraud prevention.
Please review ICB’s Fair Processing Notice which is available here. It documents who they are, what they do, details of their Data Protection Officer, how they get the data, why they take it, what personal data they hold, what they do with it, how long they retain it, who they share it with, what entitles them to process the data (legitimate interests), what happens if your data is inaccurate and your rights i.e. right to information, right of access, right to complain, right to object, right to restrict, right to request erasure and right to request correction of your personal information.
Fraud Reporting 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.
If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our products and services.
Sometimes we need your consent to use your personal information. For example, when we use sensitive personal information (known as ‘special category information’ under GDPR) about you, such as medical data, we ask for your explicit consent
We have controls to ensure that you are informed when making your decision and that you are aware that you can remove your consent at any time by contacting us. Our consent requests are built on the following principles:
Positive Action - Clear affirmative action is required. We will no longer use pre-ticked boxes, imply or assume consent in the event of no positive action from you.
Free will – Your consent must be freely given and not influenced by external factors.
Specific – We will be clear on what exactly we are asking your consent for.
Recorded – We will keep a record of your consent and how it was obtained.
Can be withdrawn at any time – We will stop data processing requiring your consent at any time you make valid request.
How we keep your information safe
We protect your information with security measures under the laws that apply and we meet international standards. We keep our computers, files and buildings secure.
In addition to our technical controls, our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. Our Data Protection Officer advises on how we can best understand risks to your data rights and freedoms, implemented processes to protect these and has responsibility to report to the Data Protection Authorities if we are not meetings our obligation.
When you contact us to ask about your information, we may ask you to identify yourself. This is to help us protect your information.
How long we keep your personal information for
To meet our legal, regulatory and business requirements, we hold your information while you are a customer and for a period of time after that. To help you understand how long we hold some of your data for, we have summarised our internal retention schedules below.
We hold all data while you are an active customer with us.
Please note that these retention periods are our policy but are also subject to external considerations, which may require us to hold the information for a longer period. For example, we must meet minimum retention standards for our Anti Money Laundering obligations. External agencies, such as the Financial Service and Pensions Ombudsman, can request we retain data for longer than our internal schedules. We must do this to protect both of our interests.
We continuously assess and delete data to ensure it is not held for longer than necessary.
Account and service information
- Account Opening documents
- Account Records
- Opening Customer/Business Relationship documentation
- Signed Terms of Business/Engagement documents
- Customer Information –non Criminal Justice Act documents.
- Adherence to Law/Regulation documents – AML Report.
- Credit Committee – Customer related decisions
- Customer Complaints
- Customer Instructions & Communications
- Deceased Accounts
- Security information
7 years after the account closes
Transactional information – Once off
- Customer Orders/Instructions
- Once-Off Transactions
7 years after the transaction
Transactional information – Recurring
- Standing Order & Direct Debit Mandates
- Continuing Transactions
7 years after the cancellation or closure of account
- Tax Returns
- Backup in relation to Special Tax Accounts and encashment tax
- Correspondence files for Dividend Withholding Tax, Revenue Contracts Tax
- Tax Relief at Source information
- Special Tax Accounts
- Special Savings Accounts
- Qualifying Intermediaries
- VAT correspondence dealing with VAT queries including VAT Audit files and information provided to Revenue
- VAT recovery calculations, back up schedules and reconciliation files.
11 years after the date of the document
Reportable Accidents and Health and Safety reports
- Health and safety reports
10 years after the incident
Your information and third parties
Sometimes we share your information with third parties.
For example to:
research your experiences dealing with us;
sell your debts;
sell whole or part of our business;
prevent financial crime;
help trace, investigate and recover funds on your behalf;
trace information; and
protect both our interests.
Third parties we share information with can include:
Fraud prevention agencies
Company search databases
Regulatory bodies including the Data Protection Commissioner and the Central Bank of Ireland.
Companies we have a joint venture or agreement to work with
Government bodies including Revenue (Further information on tax reporting is available on our Group website)
Businesses that introduce you to us or we introduce you to
Market research companies
Debt collection agencies
External consultancy firms including Legal, Accountancy, Compliance and other Professional Services
Any entity you request your data to be shared with
We require that these third parties provide sufficient guarantees that the necessary safeguards and controls have been implemented to ensure there is no impact on your data rights and freedoms.
We also have to share information with third parties to meet any applicable law, regulation or lawful request. When we believe we have been given false or misleading information, or we suspect criminal activity we must record this and tell law enforcement agencies, which may be either in or outside Ireland.
International transfers of data
We may transfer your personal information outside of the European Economic Area (EEA) to help us provide your products and services such as where we share information with service providers in the United States or India. We will only transfer your information outside of the EEA where expect the same standard of data protection applies or appropriate safeguards are in placeis applied outside of the EEA to these transfers and the use of the information, to ensure your rights are protected. This may include;
- transfers to countries approved by the European Commission as having an adequate level of protection
- use of appropriate safeguards such as Binding Corporate Rules or Model Contractual Clauses
- transfers in line with the derogations for specific situations set out in Article 49 of the GDPR.
Your personal information rights
For more information on how you can exercise your rights please refer to our Data Protection Rights section here.
Whenever you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.
Your right to obtain information cannot adversely affect the rights and freedoms of others. Therefore, we cannot provide information on other people without consent.
We generally do not charge you when you contact us to ask about your information. Under GDPR, if a request is deemed excessive or manifestly unfounded, we may charge a reasonable fee to cover the additional administrative costs or choose to refuse the requests.
You can change your mind wherever you have given us your consent, such as for processing your sensitive information, e.g. medical data. By contacting us at 1850 565 500, you can request that we no longer process data we require your consent for.
The right to lodge a complaint with a supervisory authority
If you have a complaint about the use of your personal information, please let a member of staff know, giving them the opportunity to put things right as quickly as possible. If you wish to make a complaint you may do so by phone, in writing and by email. We will fully investigate all the complaints we receive. You may complain through our contact centre, our website, by phone, or by email. We ask that you supply as much information as possible to help us resolve your complaint quickly.
You can also contact the Office of the Data Protection Commissioner in Ireland on the below details:
Updates to this notice
We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and products. You can always find an up-to-date version of this notice on this website at www.havenmortgages.ie/dataprotection, or you can ask us for a copy.
Please see explanations below of some of the data protection terms used on this website.
Consent – of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Data Controller – is a natural or legal person, public authority, agency or other body who determine the purpose and means of the processing - of personal data, where the purposes and means of such processing are determined by Union or Member State law. AIB are considered a data controller, as they process personal data on behalf of both their customers and their employees.
Data Processor – in relation to personal data, means any natural or legal person (other than an employee of the data controller), public authority, agency or another body who processes personal data under the direction of, and on behalf of a data controller. AIB is considered a data processor, as they process personal data on behalf of Third Parties. Additionally, Third Parties engaged by AIB to process personal data are considered data processors.
Data Protection Officer – The Data Protection Officer oversees how we collect, use, share and protect information.
Data Protection Regulation – means all legislation, regulation and applicable codes of practice relating to the processing, protection and privacy of personal data.
General Data Protection Regulation (‘GDPR’) – is a regulation intended to strengthen and unify data protection for all individuals within the European Union (‘EU’). The aim of the GDPR is to reinforce data protection rights of individuals and facilitate the free flow of personal data. It applies to all data controllers and processors established in the EU, as well as those established outside the EU that process the data of EU citizens.
Lawful basis - Processing of data is lawful only if and to the extent that at least one of the following applies:
a) Personal data processing is necessary to enter into or perform a contract with a data subject;
b) There is a legal obligation to the data controller for the personal data processing;
c) AIB Group or our Third Parties have a legitimate interest in processing the data. This legitimate interest cannot over-ride the interests or fundamental rights of the data subject;
d) The data subject has provided consent to the processing of his or her personal data for one or more specific purposes;
e) Personal data processing protects the vital interests of the data subject; or
f) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Location Data – means any data processed indicating the geographical position of the terminal equipment of a user, including data relating to:
a) The latitude, longitude or altitude of the terminal equipment;
b) The direction of travel of the user; or
c) The time the location information was ‘recorded’
Personal Data/ Data Subject – is any data relating to an identified or identifiable natural person (‘data subject’), who may be identified from the data either on its own (directly) or in conjunction with other data (indirectly), in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing – means obtaining, recording or holding the information or data, whether or not by automated means, or carrying out any operation or set of operations on the information including:
a) Collection of data
b) Organisation, adaption or alteration of the information or data
c) Retrieval, consultation or use of the information or data
d) Disclosure of the information, or data by transmission, dissemination or otherwise making available, or
e) Alignment, combination, blocking, erasure or destruction of the information or data
Recipient – means a natural or legal person, regulator, agency or another body, to which the personal data are disclosed, whether a Third Party or not. The processing of those data shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Special Categories of Personal Data – is data which relates to:
a) Racial or ethical origin, political opinions or religious or philosophical beliefs
b) Trade union membership
c) Biometric data (We may collect voice, facial or fingerprint information to identify data subjects)
d) Physical or mental health
e) Sexual Life/Orientation
f) Genetic data
Supervisory Authority – means an independent public authority which is established by a Member State. In the Republic of Ireland the Office of the Data Protection Commissioner (‘ODPC’) and in the UK the Information Commissioner’s Office (‘ICO’) are the public authorities established to monitor the application of Data Protection Law.