First Home Scheme Privacy Notice

This privacy notice provides information about the personal data relating to you that is processed by First Home Scheme, the purposes for which it is processed and the manner and duration of the processing. You should read this Privacy Notice prior to providing any personal data to First Home Scheme and refer to it at any time should you have queries regarding the use of your personal data.

WHO ARE WE?

Your Personal Data is controlled by First Home Scheme Ireland a designated activity company limited by shares incorporated in Ireland with registered number 710046 (the “First Home Scheme DAC”). Our registered office is Pembroke Hall, 29 Upper Mount Street, Dublin 2,D02K003.

When we refer to “we,” “us,” or “our,” in this Privacy Notice, we are talking about the First Home Scheme DAC. When we say “you” and “your” and “individuals” in this notice, we mean anyone whose Personal Data we may collect.

HOW WE OBTAIN YOUR PERSONAL DATA

Personal Data collected directly from you

We collect personal data from you directly in several ways including:

  • Correspondence with us via our website e.g., by completing the ‘Contact Us’ form on our website or by telephone, live chat, email, or social media,
  • Applying to the First Home Scheme or by expressing an interest in making an application
  • Through your account on our platform

Personal Data collected automatically

Some Personal Data may be collected automatically when you visit or use our website, such as data collected by cookies and other technologies on our websites. Please also consult our Cookies Policy for more information on how we make use of cookies and other automated means of data collection.

TYPES OF PERSONAL DATA WE COLLECT

The tables below set out the different types of personal data that we collect depending on our interaction with you. We also set out the purpose of the processing, the sources we collect it from and the lawful basis for processing that personal data. Under data protection law, we must always have a lawful basis for processing your personal data. For some processing activities, we consider that more than one lawful basis may be relevant, depending on the circumstances.

Category

Purpose of Processing

Collected From

Legal Basis for Processing

Contact Information

  • First and last name
  • Current Address
  • Email address
  • Telephone number
  • Any additional personal data entered into the free text ‘Contact Us’ section of our website.
  • Responding to your enquiries
  • To arrange a call with one of our agents
  • You
  • For our legitimate interest in responding to your enquiry

Contact Information

  • First and last name
  • Current home address
  • Telephone number
  • Email Address

Personal Information

  • Date of birth
  • Employment Status

Financial Information

  • Salary Details
  • Secondary Income Details
  • To create a first home scheme account
  • You
  • For our legitimate interest in making the First Home Scheme available

Contact Information

  • First and last name
  • Current home address
  • Previous home address
  • Telephone number
  • Email address

Personal Information

  • Date of birth
  • Marriage status
  • Country of birth
  • Nationality
  • Gender
  • Employment Status

Financial Information

  • Salary details
  • Secondary income details
  • Bank and Account details
  • Personal asset details
  • To make an application/assess eligibility for scheme
  • You
  • To perform a contract or to take steps prior to entering a contract

Contact Information

  • First and last name
  • Current home address
  • Telephone number
  • Email address

Personal Information

  • Date of birth
  • Country of birth
  • Nationality
  • Photo ID
  • Facial Image
  • Criminal convictions
  • Sanctions
  • To verify your identify to comply with our regulatory, statutory, and legal obligations
  • You
  • Your explicit consent
  • Information automatically generated through your use of our website such as the type of your device and browser, about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked and the websites you have visited before arriving at one of our websites
  • IP address
  • MAC address
  • Information revealing the location of your electronic device
  • To ensure your connection to the website is secure
  • To remember your tracking preferences
  • To help us understand how visitors to our website are using it so we can make it better.
  • From your device
  • For our legitimate interests to improve the performance of our website
  • Your consent

SPECIAL CATEGORIES OF PERSONAL DATA

Under the GDPR certain sensitive types of personal data, such as information relating to health and race or ethnic origin, are known as ‘Special Categories of Personal Data’. While Special Categories of Personal Data generally cannot be processed, there are limited exceptions to this general rule, including where your explicit consent to the processing of this data has been obtained. Subject to your consent, we may collect biometric data (facial images) for the purpose of verifying your identity. We ask for your explicit consent before collecting this data and do not retain it after your identity has been confirmed. If you do not consent to the use of your biometric data, we will verify your identity through a manual review of your documents. You may also withdraw your consent to the use of your biometric data at any time, but this does not affect the validity of any processing carried out before your consent was withdrawn.

We do not actively collect any other type of special categories of personal data. However, during your application and relationship with us you may voluntarily provide us with information that you may deem relevant, for example information about your health where it relates to your ability to repay. In cases where you voluntarily provide this type of information to us, we rely on your consent to process it (on the basis that you have voluntarily provided such data to us).You may withdraw your consent to the use of such data at any time, but this does not affect the validity of any processing carried out before your consent was withdrawn. Where this information is provided, we will ensure your personal data is subject to protection as required under the GDPR.

ANTI-MONEY LAUNDERING SCREENING

We carry out anti-money laundering, fraud and terrorist screening on all applicants to the First Home Scheme on a best practice basis.  During this process we receive results of adverse media searches run by a third party on behalf of the First Home Scheme.  The results of an adverse media search may include criminal conviction data if you have been convicted of a crime that has been publicly reported.  Where this type of data is processed, we will ensure it is afforded the appropriate level of security and protection.  The results of the AML screening will be considered as part of the application process.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Service providers

We share your Personal Data with trusted service providers who provide services on our behalf. These service providers include IT and support services providers and professional services such as lawyers and accountants.

Disclosure to Third Parties

We may share your Personal Data with regulators, law enforcement, other government agencies, industry partners, our advisors if we have a good-faith belief that it is necessary to:

  • respond pursuant to applicable law or regulations, court orders, legal process, or government requests. For example, sharing with regulators, law enforcement, or other government agencies in response to legal requests or sharing with civil litigants pursuant to court orders.
  • protect the rights, property and safety of our employees or others, including to prevent death or imminent bodily harm. For example, sharing with law enforcement, in emergency situations where we learn that a person’s life is at risk.

INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

First Home Scheme only processes your personal data within The European Economic Area (EEA).

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

Personal data will not be held for longer than is necessary for the purpose(s) for which they were obtained as set out in this Privacy Notice or otherwise to comply with legal or regulatory requirements applicable to us.

When your Personal Data is processed for meeting legal and regulatory requirements, we retain your Personal Data as it is set out by the applicable law.

  • Unsuccessful applicant’s personal data is retained for 12 months after their application is declined
  • The personal data of individuals who register an account but don’t make an application is retained for 6 months from account registration.

Further details of retention periods for different aspects of your personal data are available by contacting us.

In some circumstances you can ask us to delete your data: see Your Rights below for further information.

AUTOMATED DECISION MAKING

We may process your personal data using calculators and quotation tools to establish your qualification for the scheme. We do not carry out these processes on an automated basis; we operate with human intervention.

We use automated decision making when we process your biometric information (facial image) to help identify you when you make an application for The First Home Scheme.

NECESSITY OF PROVISION OF CERTAIN PERSONAL DATA

Certain information, such as contact details and your financial information, must be provided allow us to assess your eligibility for the First Home Scheme and to enable us to enter a contract to allow you to avail of the First Home Scheme. If you do not provide certain of this information, it may mean that we cannot enter a contract to provide the First Home Scheme to you.

YOUR RIGHTS

Any individual whose Personal Data we hold has several rights in relation to how that information is processed by us. You have the following rights:

  • The right to object– individuals can object to us processing their data and we will either agree to stop processing or explain why we are unable to
  • The right of access– individuals can request a copy of their personal data we hold about you
  • The right of rectification– individuals can ask us to update or correct their personal data to ensure its accuracy or completeness
  • The right to be forgotten– individuals can ask us to delete their personal data from our records if it is no longer needed for the original purpose
  • The right of restriction– individuals can ask us to restrict the processing of their personal data in certain circumstances
  • The right to data portability– individuals can ask for the data we hold about them to be transferred to another organisation.
  • Right to object to automated processing, including profiling – individuals have the right to object when a decision is based solely on automated processing of their personal data.

You can exercise these rights via our Data Privacy team. You can contact them at dataprivacy@firsthomescheme.ie. When you contact us to ask about your information, we may ask you to identify yourself to protect your information.

Complaints

You also have a right to lodge a complaint with a supervisory authority. In Ireland this is the Data Protection Commission (DPC). You can contact the DPC via their website: https://www.dataprotection.ie/en/contact/how-contact-us.

HOW TO CONTACT US

If you would like further information about this Privacy Notice or our processing of your Personal Data, you can contact us by:

Email: dataprivacy@firsthomescheme.ie

CHANGES TO OUR PRIVACY NOTICE

Occasionally it may be necessary for us to make changes to this notice. When such a change is made, we will post a revised version online at the earliest opportunity. Changes will be effective from the point at which they are posted.

This privacy notice was last updated in August 2022