Version 2026.4   Effective from April 2026

 

1. About This Notice

Finplan Limited uses AI technology to assist in the processing of mortgage applications. This notice explains how AI is used in our service, what safeguards are 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, analyses the documents using AI to generate structured summary and dataset reports.
• 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

 

What the AI does: Streamlines document processing Identifies relevant factors in your application Generates structured reports for adviser review

What the AI doesn’t do: Make final mortgage decisions Generate creditworthiness scores, risk ratings, or lending recommendations Act without adviser review and human sign-off

 

4. Safeguards

• No training use. Your data is never used to train or improve AI models.
• 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. AI-generated reports are retained securely for 6 years as required under the Consumer Protection Regulations 2025 (S.I. No. 81 of 2025). Data is deleted from the AI processing environment once analysis is complete.
• 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. 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.
• Secure processing. Data is isolated, encrypted, and protected throughout AI analysis.
• Retention. AI-generated reports form part of your mortgage record and are retained for 6 years for compliance and audit purposes only.

 

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 risk classification. The AI document processing system is provided by IonData Limited. It analyses financial documents (including bank statements, income, and expenditure records) to produce structured summaries for adviser review. The system does not generate creditworthiness scores, risk ratings, or lending decisions. On this basis, the system is classified as limited-risk under the EU AI Act. Finplan has confirmed this classification with IonData in writing and meets all applicable transparency obligations under the Act as a deployer.
• 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.