Introduction
At April, we’re committed to respecting and protecting your privacy. To this end, we work to be completely open and transparent in the way we collect your personal information and how we use that information.
This notice is to inform you about how we collect, use, share and store your personal information – including personal information we already hold and further information we might collect in the future, either from you or from a third party – and how we uphold your data protection rights.
Who we are
April Mortgages Limited is registered in England and Wales under number 13514833 with our registered office at 158-160 North Gower Street, London, NW1 2ND.
We are what is known as the “data controller” of personal information we collect and use. This means that we are responsible for determining the purpose and the means of processing your personal data. We are registered with the Information Commissioner’s Office under number ZB227506.
What personal information does April collect and why?
We collect, use, store and transfer personal data. Personal data is any information which can (or could be used to) identify you. It doesn't include data which is not possible to relate to a specific person (anonymous data).
As a mortgage lender it is important we have the right information about you in order to make a tailored, and suitable recommendation. This ensures we can select from the widest range of available products to give you the right option for your circumstances.
We collect, use, store, and transfer different types of personal data and they can be grouped as follows:
April may collect and process the following information about you:
Identity Data includes first name, maiden name, last name, marital status, title, date of birth, gender, address and employment history, and citizenship.
Contact Data includes address, email address and telephone numbers.
Financial Data includes bank account details and bank statements, your income and outgoings, credit history including details of any history of bankruptcy or county court judgements, mortgages and protection products held, and payment/ direct debit details.
Special Category/Sensitive Data which includes physical and mental health conditions, racial / ethnic origin, and biometric data
Criminal Offence Data includes information about criminal offences and convictions.
Transaction Data includes details about the products and services you have bought from us
Technical Data includes internet protocol (IP) address, your login data, 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 you use to access this website.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us, and our business partners and your communication preferences.
Job Application Data includes data submitted throughout the recruitment process i.e. name, email address etc.
Employment Data includes any personal information you provide to April as part of the recruitment process or throughout your employment at April should you be a permanent employee, contractor, or 3rd party provider
Special category data and Vulnerable Customers
At April, we give special levels of care to those customers we might consider to be vulnerable. This is to ensure these customers are not disadvantaged when using our services. This is in line with regulations set out by the Financial Conduct Authority. If we think you’re vulnerable, we might record that information to help us give you the right service. That information could be special category data. That’s data that’s likely to be more sensitive – things like physical and mental health conditions.
When companies process special category data, they must have “legal basis” to use it, which means a legal reason from the UK GDPR. The legal basis we rely on is "legal obligation” (we must process your data because the law or regulations require us to).
Alongside that, companies also must meet one of the legal conditions in Article 9 of the UK GDPR. The conditions we rely on are “substantial public interest," “regulatory requirements” and “support for individuals with a particular disability or medical condition.” In plain English, that means we use this data to make sure we support you in the right way. For example, you might tell us that you’re deaf, and that you prefer us to not call you on the phone. We’ll use this information to support our communications with you.
Other Data
As part of our fact find, we may require information about criminal convictions and offences that you may have, for example for fraud detection. We also collect specific Special Categories of Personal Data about you to provide you with advice for your protection needs (i.e. details about your ethnicity and information about your health).
We collect data relating to the number of dependents as this affects our affordability calculations to provide you with the most appropriate recommendation. However, we'll only ask for further data relating to dependents if necessary. This data will be treated sensitively and we won't use this data for marketing purposes.
How does April use your personal information?
We use your data for one or more the reasons we’ve listed below. We will only use your personal data when the law allows us to. Most commonly, we'll use your personal data in the following circumstances:
Consent - you’ve told us it’s OK to use your data for a specific reason.
Contract - you’ve agreed to a contract with us, and we need to use your data to carry out that contract. For example, we’ll use your income data to run affordability checks.
Legal obligation - we have to process your data because the law or regulations require us to. For example, we need to get proof of your identity to meet our anti-money laundering responsibilities.
Legitimate interest - we or one of our partners might use your data because we or they might have a legitimate interest to do that. Sometimes that interest is to do with benefitting April or our partners, and sometimes it’s to benefit wider society. One example of legitimate interest for processing your data might be to try to detect and prevent fraud. Another might be to improve our products and services. Or, we might process your data to recover any money you owe us.
Where we rely on consent as a legal basis for processing your personal data, you have the right to withdraw consent at any time by contacting us at dataprotection@aprilmortgages.co.uk
We've set out below a detailed description of the ways we use your personal data, and which of the legal bases we rely on to do so.
Assessing your mortgage application
The purpose we use your data: We use your identity and contact data to assess your mortgage application and to service you as a customer.
The legal basis: Contract
The purpose we use your data: We use your identity, contact, financial, transaction, marketing and communications, special category, and criminal offence data to help you with your mortgage. We’ll also use this information to assess your mortgage and let you know if one of our products are suitable.
The legal basis: Contract. Legal obligation (for special category data, we also rely on “substantial public interest”, “regulatory requirements,” and “support for individuals with a particular disability or medical condition”). Legitimate interest (in this case, to recover any money you owe us and to develop and grow our business)
Keep you up to date
The purpose we use your data: We use your identity, contact, transaction and marketing and communications data to manage our relationship with you. This includes things like asking you to leave a review or take a survey. It also includes any legal and regulatory reasons.
The legal basis: Contract. Legal obligation. Legitimate interest (keep our records updated, see how customers use April and review our standards of service, to contact you again regarding your mortgage or services requested from us).
Work with others
The purpose we use your data: We use your identity, contact and financial data to talk to other companies or anyone else that helps you with the whole mortgage and home-buying and remortgaging journey. That could include solicitors, conveyancers, surveyors, valuers, other lenders, and brokers and intermediaries.
The legal basis: Contract. Legal obligation.
Handle your complaints
The purpose we use your data: We use your identity, contact and marketing and communications data to manage complaints, take action to put things right, and answer your questions. We can also use financial, transaction, special category data and criminal offence data when it relates to the complaint you’ve made.
The legal basis: Legal obligation. Legitimate interest (investigate complaints, improve our standards and try to prevent future complaints).
Ask for feedback
The purpose we use your data: We collect your identity, contact, technical and usage data when you complete a survey or take part in user testing.
The legal basis: Contract. Legitimate interest (to understand how customers use April and develop our services and business).
Keep the site running
The purpose we use your data: We use your identity, contact and technical data to manage and protect our business and our website. That includes things like troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
The legal basis: Legitimate interest (to run our business, including our admin and IT services, keep it secure, and prevent fraud).
Improvements
The purpose we use your data: We use your technical and usage data to analyse and test our systems, and improve our website, products and services, marketing, customer relationships and experiences.
The legal basis: Legitimate interest (keep our website updated and develop our business and marketing strategy).
Send you marketing
The purpose we use your data: We use your identity, contact, usage, technical and marketing and communications data to suggest services you might like. We’ll use your data to decide what you might find useful or like us to send you. You can unsubscribe from marketing by hitting ‘Unsubscribe’ in the bottom of any marketing email, or by emailing hello@aprilmortgages.co.uk
The legal basis: Consent. Legitimate interest (grow April and develop what we offer – for example, we might use your data to send you personalised marketing campaigns).
Record our communications
The purpose we use your data: We use your identity, contact, usage, transaction, marketing and communications data to monitor or record any communications between you and us. That includes emails and phone calls. We do this to check your instructions to us, analyse and improve our services, and to help us train staff. We also do it for quality assurance purposes (which means to help us prevent mistakes or problems from happening).
The legal basis: Contract. Legal obligation. Legitimate interest (develop and improve our systems, train our people, and give our customers a high standard of service)
Fraud prevention
The purpose we use your data: We use your identity, contact, usage, financial, transaction, marketing and communications data to prevent fraud. We carry out checks on your identity and documents, and look at your financial transactions to detect fraud and money laundering.
The legal basis: Contract. Legal obligation. Legitimate interest (fraud and ID checks protect us and other businesses, as well as you).
Processing of a job application
The purpose we use your data: We use your identity and contact data to carry out various checks as part of a successful job application at April including vetting/background and right to work checks
The legal basis: Consent. Legitimate interest - for April to assess and validate a candidate suitability and capability to carry out the duties assigned to the prospective role
Who does April share my personal information with?
We may share this information for the processing of Applications and Mortgages with other organisations or to fulfil legal and regulatory obligations, including:
Credit reference agencies
In order to process your application, we will perform credit and identity checks on you with Experian, a Credit Reference Agency (CRA). We may also make periodic searches after your mortgage account is opened with a CRA to help us manage your account.
To do this, we will supply your personal information to the CRA, and they will give us information about you.
This will include information from your credit application and about your financial situation and financial history. The CRA 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:
If the CRA information relating to your credit commitments is different from the information you supply in your application, and this difference impacts our decision to lend to you, we will share this information with your mortgage broker.
This is shared so that your broker can advise you of the reason for our decision, which is in your legitimate interest.
We will continue to exchange information about you with the CRA while you have a relationship with us. We will also inform the CRA when you repay your mortgage. If you do not repay your mortgage in full, then the CRA will record the outstanding debt shortfall. This information may be supplied to other organisations by the CRA.
When a CRA receives 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 you tell us that you have a spouse or financial associate, we will link your records together. Make sure you discuss this with your financial associate and share this notice before submitting your application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your associate successfully files for a disassociation with the CRAs to break that link.
The identities of the CRA, their role also 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 CRAs are explained in more detail in the CRA Information Notice at: experian.co.uk/crain/index.html
Automated decisioning
In order to be as efficient and streamlined as possible, we may perform automated processing (i.e. processing that is carried out without human intervention) on your personal information to evaluate certain things about you. In particular, we may do this to analyse or predict (amongst other things) your economic situation and credit history/behaviour.
This could mean that automated decisions (i.e. decisions that are made without human intervention) are made about you using your personal information.
For example, if you do not meet an element of our lending criteria (such as being over 18 or being a resident in the UK) any application for credit will be automatically declined. If you do meet our eligibility criteria, whether we lend will then be determined by your credit status.
When we do this, we take all necessary measures to ensure that your privacy and security are protected.
You have rights in relation to automated decision making; if you want to know more, please contact us using the contact information set-out in the “Who we are” section of this Privacy Notice.
Legal basis for processing personal information
Under the United Kingdom (UK) General Data Protection Regulation (GDPR), the lawful basis we rely on for the processing of personal information are:
Contract. That this is necessary for the performance of the Mortgage (contract) with you, including steps at your request prior to entering into the Mortgage during your Application; and or
Legal Obligation. That this is necessary for compliance with a legal or regulatory obligation that applies to us.
The legal bases on which we collect, process and transfer special categories of data relating to you in the manner described above are:
Consent. That you have given your explicit consent to such processing of any health or sexual orientation information; any withdrawal of your consent, would compromise the Application or the Mortgage and may prevent the processing to satisfy April’s regulatory obligations.
On occasion April may require processing of special category information in the establishment, exercise, or defence of legal claims, even if Consent has been removed.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
April conducts no direct marketing to mortgage applicants or customers. April sends new and existing product updates to its network of mortgage brokers. This is assessed to be a reasonable expectation for business-to-business activities and is therefore conducted under legitimate interest.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
Cookies and similar tracking technology
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. Please see our Cookie Notice for more information.
How does April keep my personal information secure?
April takes all reasonable steps to ensure that Your Information is treated securely and in accordance with this Privacy Policy.
All information you provide to April is securely stored either on dedicated servers within the United Kingdom or with trusted partners who abide by GDPR legislation as part of April's contractual arrangements.
Once April has received Your Information, April will use strict procedures and security features to try to prevent any unauthorised access.
International data transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Data retention
We’ll only keep your data for as long as we need it to do the thing we collected it for and to comply with the UK GDPR requirements. The length of time we keep your data may vary depending on the stage of the journey you reached with April.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Here’s a more detailed breakdown:
Purpose of processing: Successful mortgage applications
Retention: For the life of the mortgage term plus a further 6 years.
Purpose of processing: Withdrawn, stalled, incomplete and failed mortgage applications
Retention: 6 years from the date the latest application was started, or 6 years from the application submitted date if application was submitted and subsequently rejected.
Purpose of processing: Affordability checks
Retention: 6 years from Decision in Principle if affordability check does not proceed to a full mortgage application
Purpose of processing: Job application data
Retention: Successful applicant: life of employment plus 6 years after the employment terminates. Unsuccessful candidate: up to one year
Purpose of processing: Complainant data
Retention: 6-years from the date the complaint was made
In some circumstances you can ask us to delete your data, detailed in ‘Your data protection rights.’ In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your data protection rights
Under UK data protection law, you have a set of certain rights. These are:
You can exercise any of your rights by emailing us on the contact details below or by emailing us at dataprotection@aprilmortgages.co.uk
If you have any concerns or wish to make a complaint
If you have any questions or concerns about our use of your personal information, please reach out to us, by phone on 0330 808 1791, by email at dataprotection@aprilmortgages.co.uk, or by writing to us at April Mortgages Ltd, 158-160 North Gower Street, London, NW1 2ND.
If you have a complaint and we cannot resolve your complaint to your satisfaction, you can contact the Information Commissioner’s Office at www.ico.org.uk or by telephoning 0303 123 1113 if the complaint relates to the way your personal information has been handled.
Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
Last updated: 29th August 2024
April Mortgages Limited. Registered Office: 158-160 North Gower Street, London, NW1 2ND. Registered in England and Wales company number: 13514833. April Mortgages Limited is authorised and regulated by the Financial Conduct Authority (FRN 989666).