AI-Assisted Mortgage Application Processing

Version 2026.8   Effective from August 2026

1. About This Notice

Finplan Limited may offer optional AI-assisted mortgage document processing. This Notice applies only to that workflow; meeting or call recording and transcription are explained in our Data Privacy Notice and communicated before and at the outset of a recording. This Notice explains how mortgage AI is used, the safeguards in place and your rights as a client.

We comply with the EU AI Act, the General Data Protection Regulation (GDPR), and the Consumer Protection Regulations 2025 (S.I. No. 81 of 2025). Our use of AI will never override or diminish our obligations under any of those regulations.

2. How the AI Process Works

When you submit a mortgage application, the following steps take place:

• Document Submission. Upload your application and supporting financial documents.
• AI Analysis. Our partner, IonData Limited, uses approved IonData Products to analyse documents and generate structured summary and dataset reports. “IonData Products” means Finplan-approved technology, automation and AI-assisted record-processing products provided by IonData Limited, including a successor, replacement or rebranded product carrying out the same approved function.
• Report Generation. AI-generated reports are passed to our advisers for review.
• Expert Review. Our advisers review AI outputs alongside your full application. Advisers can override or disregard any AI output.
• Human Decision. All final decisions are made by qualified people, not by AI.

3. What AI Does and Doesn’t Do

4. Safeguards

• No training use. Before client data is routed to an AI provider, Finplan approves the provider and route and, where the service permits, configures it so that client data is not used to train or improve general-purpose models. We maintain the relevant contract and configuration evidence.
• Secure processing. All data is encrypted during processing and subject to strict access controls.
• Data isolation. For joint applications, both applicants’ data is processed together only for that mortgage application. It is never mixed with unrelated applicants’ data.
• Retention and deletion. Mortgage source documents, extracted data and unapproved working drafts are deleted from the AI processing environment within six months of collection or withdrawal of consent, whichever is earlier, unless a documented complaint, error, incident or legal/regulatory hold requires retention. A human-approved record added to your client file is retained under Finplan’s applicable regulatory retention policy.
• Human oversight. All AI outputs are reviewed by a qualified adviser before use.
• Incident response. We maintain procedures to identify, report, and address any AI-related issues. Clients may raise concerns or complaints about AI use at any time.

5. Data Protection and Privacy

• Consent. AI-assisted processing is used only with your explicit consent, obtained in two stages: first when you commence your application, and again when you upload your documents. Consent is voluntary and specific to this optional workflow. For joint applications, both applicants receive this notice by email and must each give individual consent at the document upload stage. One applicant cannot consent on behalf of another. You may withdraw consent at any time by contacting us at online@finplan.ie or on +353 1 443 3010, without affecting your right to continue using our services via manual processing. Withdrawal stops future AI processing but does not require Finplan to delete a human-approved record which it is legally required to retain.
• Secure processing. Data is isolated, encrypted, and protected throughout AI analysis.
• Retention. Temporary mortgage source documents, extracted data and unapproved working drafts follow the six-month deletion period described in this Notice. A human-approved record added to your mortgage file follows Finplan’s applicable regulatory retention policy.

6. Your Rights

• Opt out of AI processing. You may request manual review at any stage of the application process, without disadvantage.
• Explanation requests. You may ask for details on how AI contributed to the assessment of your application.
• Access to AI outputs. You may request a copy of any AI-generated reports held in your file.
• Your data rights (GDPR). Under GDPR, you have the right to access your personal data, have inaccurate data corrected, request erasure where data is no longer necessary, restrict or object to processing, and receive your data in a portable format. To exercise any of these rights, contact us at online@finplan.ie or on +353 1 443 3010. We will respond within one month as required by GDPR.
• Automated decision-making (GDPR Art. 22). No decision about your mortgage application is made solely by automated means. A qualified adviser reviews all AI outputs before any recommendation or decision is made. You have the right to request human review at any stage, to express your point of view, and to contest any decision.

7. Oversight and Compliance

• AI use-case assessment. The AI document-processing system is provided by IonData Limited using approved IonData Products. It analyses financial documents, including bank statements, income and expenditure records, to produce structured summaries for adviser review. It must not generate a creditworthiness score, risk rating, lending recommendation or lending decision, and must not materially influence any such decision. Finplan maintains a written use-case assessment with IonData and reassesses it before any material change to purpose, data, model, provider, transfer, retention or level of automation.
• Our role. Creditworthiness assessments and lending decisions are made solely by the relevant lender. As a mortgage broker and deployer of AI technology, we apply the principles of the EU AI Act (including transparency, human oversight, and record-keeping) appropriate to our role.
• Human oversight. A qualified adviser reviews all AI outputs before any decision or recommendation is made.
• Monitoring and record-keeping. We carry out regular checks on AI output accuracy, bias, and reliability. All AI use, outputs, and reviews are logged.
• Fair treatment. Our use of AI upholds all obligations under the Consumer Protection Regulations 2025 (S.I. No. 81 of 2025). We treat all clients fairly, regardless of whether their application is processed with or without AI assistance.
• Staff training. Our staff receive regular training on AI capabilities, limitations, and regulatory requirements. Advisers review all AI outputs before acting on them.

8. Updates to This Notice

This notice will be reviewed and updated as our AI practices change or as regulatory requirements are updated. The current version is available at finplan.ie/ai-assisted-processing and will be sent to you when you give your consent.

9. Contact and Complaints

For enquiries about our AI-assisted process, to exercise your data protection rights, or to report any concerns, contact us at online@finplan.ie or on +353 1 443 3010.

Complaints procedure

If you have a complaint about how AI-assisted processing affected your application or the service you received, please contact us first using the details above. We will acknowledge your complaint within 5 working days. We will update you on the progress of our investigation within 20 working days and aim to provide a final response within 40 working days.

If you remain dissatisfied, you may escalate to the Financial Services and Pensions Ombudsman (FSPO), 3rd Floor, Lincoln House, Lincoln Place, Dublin 2, D02 VH29. Tel: 01 567 7000. Email: info@fspo.ie. Web: www.fspo.ie. Full details of our complaints procedure are available at www.finplan.ie/complaints.