Disclosure Notice for AI-Assisted Mortgage Applications
Version 1.1 Effective from September 2025
We comply with the EU AI Act, GDPR, and the Central Bank of Ireland’s Consumer Protection Code.
- Our AI use will never override or diminish Consumer Protection Code obligations.
- We commit to responsible, fair, and transparent AI deployment.
What AI Does
- Streamlines document processing
- Highlights key application factors
- Provides insights to support advisors
What AI Doesn’t Do
- Does not make final mortgage decisions
- All decisions made by qualified advisors
- Advisors can override or disregard AI outputs
Safeguards
- No training use: Your data is never used to train AI models.
- Secure: Encrypted processing with 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: AI reports are securely kept for 6 years as per Central Bank of Ireland rules.
- Oversight: Human review of all AI outputs.
- 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, and we will investigate promptly.
Your Rights
- Access, correction, or deletion of personal data (GDPR compliant).
- Request copies of AI-generated outputs in your file.
- Obtain explanations of AI’s contribution to your case.
- Withdraw consent for AI use at any time
How The AI Process Works
AI Application Process
- Document Submission: Upload your application and supporting financial documents.
- AI Analysis: Our partner, IonData Limited, analyses data using AI to generate summary and dataset reports.
- Report Generation: AI reports are passed to our underwriters.
- Expert Review: Our advisers review AI outputs alongside your full application.
- Human Decision: Final decisions are always made by people, not AI.
Data Protection and Privacy
- Lawful Basis: AI is used only with your explicit consent; consent can be withdrawn at any time.
- No AI Learning: Your data is not used to train or improve AI models.
- Secure Processing: Data is isolated, encrypted, and protected during AI analysis.
- Retention: AI-generated reports form part of your mortgage record and are retained securely for 6 years, as required under Central Bank of Ireland regulations, for compliance and audit purposes only.
- Deletion: Data is deleted from the AI processing environment once analysis is complete.
Your Rights
- Opt-Out Choice: You may request manual review at any stage, without disadvantage.
- Explanation Requests: Ask for details on AI’s contribution to your assessment.
- Access to Outputs: Request a copy of AI- generated reports in your file.
- GDPR Rights: Access, correct, or delete your personal data (subject to legal obligations).
Oversight and Compliance
- GPAI Classification: Our system is a General Purpose AI (GPAI) under the EU AI Act.
- Human Oversight: Humans are involved at every stage.
- Monitoring: Regular checks for accuracy, bias, and reliability.
- Record-Keeping: We log all AI use, outputs, and reviews.
- Fair Treatment: Our use of AI upholds all obligations under the Consumer Protection Code.
AI Literacy
- Our staff receive regular training on AI capabilities and limitations, ensuring responsible use of outputs and application of human judgment in all decisions.
- By engaging our services, you acknowledge that you have read and understood this disclosure notice. We are dedicated to leveraging AI responsibly while protecting your rights and privacy throughout your mortgage application process.
For inquiries about our AI-assisted process, to exercise your data protection rights, or to report any concerns about our AI system, please contact us by email online@finplan.ie or call +353 1 443 3010.
If you are not satisfied with our response to any data or AI-related concern, you have the right to lodge a complaint with the Data Protection Commission (www.dataprotection.ie).