Help to Buy - Wales privacy policy

Whenever you provide personal information to Help to Buy (Wales) Limited, or we collect personal information about you, we will only use it in accordance with this privacy notice.

This privacy notice applies to Help to Buy (Wales) Limited, a subsidiary of the Development Bank of Wales plc. Whenever the terms ‘HtBW’, ‘we’, ‘us’ or ‘our’ are used in this notice, it means Help to Buy (Wales) Limited.

For our full list of privacy documentation click here.

Find out more about our governance structure on our governance page.

Our Privacy Principles

We take your privacy seriously and are committed to protecting your personal information. We will always:

  • Only ask you to provide us with personal information that helps us to help you.

  • Hold your personal information securely and responsibly. We use safeguards such as encryption to help keep your personal information secure.

  • Only share your personal information with other companies in the DBW Group, with suppliers who perform services on our behalf, and as otherwise set out in this notice.

  • Never sell your personal information.

Why we collect and use your personal information

We may collect and use your personal information for the following reasons:

  1. To manage our Shared Equity Loan products.

  2. To respond to any specific enquiries you have made to us.

  3. To keep you informed about our products and services.

We may contact you by post, telephone, email, text message, or other digital methods. We may send you communications for the purposes of:

  • Ongoing management of equity Shared Equity Loan products.

  • Meeting our legal and regulatory obligations.

  • Marketing our products and services if you opted in during your application. 

For marketing communications, you can opt-out of this at any time by emailing enquiries@helptobuywales.co.uk, or clicking the ‘unsubscribe’ link in any of our marketing emails.

More details about how we use your information for each of these purposes can be found below. This website also uses cookies, more details can be found in our cookies policy.

See also gov.wales cookie policy

1. Using your personal information for our Shared Equity Loan products

Why does Help to Buy (Wales) Limited need to use my personal information? 

If you apply for a Shared Equity Loan, we need to use your personal information to assess your eligibility. 

If successful, we will use your information for keeping in touch with you and taking care of your Shared Equity Loan Account. We’ll use your personal information to:

  • Process your application for a Shared Equity Loan.

  • Manage your Shared Equity Loan account and keep in touch with you.

  • Send you communications to service your Shared Equity Loan account.

  • Manage any queries and complaints you might have.

  • Make sure the data we hold about you is correct and up to date.

 

We also use information provided by others, such as financial associates. For instance, if you are financially associated with an applicant, then we will need to collect personal information about you both.

We will also share your personal information with third parties to comply with our legal and contractual obligations, and where it is in our legitimate interests to do so (for example, to prevent fraud or financial misconduct, or to monitor compliance with the terms and conditions of the scheme). 

What personal information does Help to Buy (Wales) Limited collect and hold about me?

The information we might collect and hold about you includes:

  • Identity and contact details, such as your name, address, phone numbers, email addresses, and date of birth. 

  • Information about your work or profession, your nationality and education. 

  • Details of the accounts and products you hold and/or previously held with us, and how you use them.

  • Information about your financial position and history, which may include source of funds and wealth.

  • Details of when you contact us and when we contact you.

  • Information about your interactions with us in writing or by telephone.

  • Other information that you supply to us or that we obtain from our relationship with you. 

  • Particularly sensitive personal information, known as special category data (e.g. information about your health).

 

When we talk about ‘information’ throughout this notice, we’re referring to all of the above.

What personal information does Help to Buy (Wales) Limited collect from third parties?

We may collect or receive personal information about you from third parties, including but not limited to:

  • Credit reference agencies (CRAs)

  • Government bodies and agencies

  • HM Revenue & Customs and other tax authorities

  • Regulators

  • Law enforcement agencies

  • Fraud prevention agencies (FPAs)

  • Insurers

  • The Electoral Roll and other sources of publicly available information (e.g. Sanctions list, media)

  • Our service providers

  • Companies and organisations that introduce you to us

  • Financial advisers

  • Land agents

  • Card associations

  • Retailers

  • Comparison websites

  • Market research providers

  • Tracing and debt recovery agents

  • Organisations providing data services to support us in managing our relationship with you and operating our business.

On occasion, we may also collect information from people who are acting on your behalf. This could be from a joint applicant or a power of attorney. If this person provides us with information, well record that it’s been provided and by who. 

What does Help to Buy (Wales) Limited do with my information?

When you provide your information to us, or it is provided by others as part of an application, we will use it to:

  • Assess the application and decide whether to provide the Shared Equity Loan.

  • Manage the Shared Equity Loan and facilitate your property transaction.

Our uses of your information include:

  • Credit Referencing: Conducting searches at credit reference agencies, which provide us with credit information and electoral register data. These agencies will record details of any searches, whether or not your application proceeds. More information about how your information is used by these agencies is available in the Credit Reference Agency Information Notice ("CRAIN"). You can access the CRAIN here.

  • Financial Crime Prevention: Sharing your personal information with fraud prevention agencies to help prevent financial crime. If required for fraud or criminal investigation reasons, we (and the fraud prevention agencies) may also allow law enforcement agencies to access and use your information.

  • Developer and Landlord Communication: Sharing your information with developers and private landlords to assign a plot of land for your property development.

  • Legal Formalities: Sharing your information with solicitors/conveyancers for legal formalities related to your property transaction.

  • Property Data Validation: Sharing your data with HM Land Registry to validate property data.

  • Compliance Assessment: Sharing your data with Rent Smart Wales to assess compliance with the HtBW scheme policy on subletting property.

  • Research and Feedback: Sharing your data with the Welsh Government and their agents for research purposes, including scheme reviews, customer feedback, and statistical surveys. You can opt-out of these activities. HtBW may also share this data with other government departments, local authorities, and agencies working on their behalf.

  • Financial Assessment: Sharing your information with independent financial advisers and mortgage brokers to assess the financial implications of your property purchase.

  • Arrears Collection: Sharing your information with tracing agents to collect arrears if you fall behind on Shared Equity Loan repayments.

  • Complaint Resolution: Using your information to handle and resolve complaints, including sharing information with an Ombudsman, Dispute Resolution Service, or Regulatory Authority.

  • Terms and Conditions Compliance: Using your information in accordance with the fund's Terms and Conditions.

As part of these activities, we may share your information with the specified parties, your accountants, employers, and the Welsh Government.

Sharing Information with Credit Reference Agencies 

We share your personal information with credit reference agencies to ensure that a Shared Equity Loan is right for you. We do this for the following reasons:

  • Assess your creditworthiness and ensure you can afford the Shared Equity Loan.

  • Check the information you have provided is accurate.

  • Prevent financial crime.

  • Manage our ongoing relationship.

  • Trace and recover debts.

Things You Need to Know About Credit Referencing:

  1. When we ask a credit reference agency to do a search on our behalf, this may leave a search footprint on your credit file that may be seen by other lenders. This happens whether or not you, or us choose to proceed with your Shared Equity Loan application.

  2. The number of searches carried out may have an impact on credit decisions made by us and other lenders.

  3. If you’re making a joint application, your credit records will be linked together. This creates what’s known as a ‘financial association’ at credit reference agencies. You should always discuss and agree this with other applicants before disclosing their information to check that they’re happy to proceed.

  4. Information about any financial associations will be shared with other lenders if either of you make a credit application in the future – whether it’s in just your name or together with someone else. We may receive and use information about your existing financial associations as part of our decision-making process.

What is the lawful basis for using my information?

Under data protection law, we must have a valid lawful basis for collecting and using your personal information. When you apply for a Shared Equity Loan with us, the following lawful bases may apply:

Performance of a Contract

We use your personal information to perform necessary pre-contractual steps, enter into a contract with you, and fulfil our contractual obligations.

Legal Obligation

We use your personal information to comply with our legal and regulatory obligations. This includes, for example, compliance with anti-money laundering legislation and Financial Conduct Authority requirements.

Legitimate Interests

We use your personal information where it is necessary for our legitimate interests. This includes:

  • Checks on Potential Customers: Conducting appropriate checks on potential customers, including ID checks.

  • Shared Equity Loan Repayment: Ensuring Shared Equity Loan repayment.

  • Compliance Assessment: Assessing compliance with scheme policies and terms.

  • Property Management: Managing the development of your property and transaction.

  • Data Validation: Validating property data with HM Land Registry.

  • Enquiry and Complaint Management: Investigating and managing enquiries and complaints and analysing them to prevent failures and rectify impacts.

  • Customer Welfare: Considering customers' welfare needs and providing necessary adjustments, support, or protection.

  • Financial Crime Prevention: Identifying, preventing, and investigating financial crime, including fraud and money laundering, and other financial misconduct.

  • Product and Service Improvement: Developing and improving our products and services, including conducting customer surveys and research.

  • Business Continuity: Ensuring business continuity, disaster recovery, and network and information security.

Lawful Basis for Processing Special Category Data

Data Protection laws treat some types of personal information as being particularly sensitive. This information is called ‘Special Category Data’. We will not collect or use these types of data unless the law allows us to. If we do, it will be under one of the following lawful bases:

  • Substantial Public Interest: For reasons of substantial public interest; or

  • Explicit Consent: We have your explicit consent to do so; or

  • Legal Claims: To establish, exercise or defend legal claims.

How long does Help to Buy (Wales) Limited keep my information?

We keep your personal information for different lengths of time based on the purpose we process it for. These purposes are listed below:

  • Successful Applications: If your application is successful, we will keep your personal information for the duration of your contract with us, and for 12 years after the contract ends. This ensures a full record of the contract in case of disputes.

  • Unsuccessful or Withdrawn Applications: If your application is unsuccessful or withdrawn, we will keep and delete your personal data in accordance with our data retention schedule.

  • Email Correspondence: Emails are kept for 2 years. If needed, emails may be kept longer to comply with legal requirements, manage existing claims or complaints, or for regulatory or technical reasons.

  • Legal Obligations and Claims: We may hold your information for as long as necessary to comply with legal obligations, exercise legal rights, comply with the Terms and Conditions of the fund, or defend legal claims.

  • Customer Relationship: Information will be kept for as long as necessary to manage your relationship with us and comply with legal and regulatory requirements.

  • Shared Equity Loan Account: Personal information may be kept up to 12 years after your Shared Equity Loan Account has closed.

  • Legal, Regulatory, or Technical Reasons: Information may be kept longer than indicated if deletion is not possible due to legal, regulatory, or technical reasons.

  • Research or Statistical Purposes: Information may be kept for research or statistical purposes. In such cases, your privacy will be protected, and the information will only be used for these purposes.

What happens if I do not provide my information to Help to Buy (Wales) Limited?

If you don’t provide us with the information we need, we will be unable to assess your application and it may result in you not being able to access our Shared Equity Loan.

2. Using your personal information to respond to your enquiry

Why does Help to Buy (Wales) Limited need to use my personal information?

If you contact us to make an enquiry, we will need to process your personal information to respond to you. 

What information do I need to provide to Help to Buy Wales?

That will depend on the nature of your query. The ‘Contact Us’ page on our website details the minimum information needed to respond to you. You may also contact us email at: enquiries@helptobuywales.co.uk. 

What does Help to Buy (Wales) Limited do with my information?

We use your information to respond to your query and, with your consent, to provide information to you about our products and services (see section 3 below).

What is the lawful basis for using my information?

Under data protection law, we must have a valid lawful basis for collecting and using your personal information. When you contact us with an enquiry, the following lawful bases may apply:

Performance of a Contract

We use your personal information to perform necessary pre-contractual steps, enter into a contract with you, and fulfil our contractual obligations.

Legal Obligation

We are permitted to use your personal information where it is necessary in order for us to comply with our legal obligations.

Legitimate Interests

Where you contact us with an enquiry, we process your personal information for the following reasons under our legitimate interests: 

  • Investigating and managing enquiries and complaints: including analysing enquiries and complaints for the purposes of preventing failures and rectifying negative impacts on customers

  • Enquiry and Complaint Management: Investigating and managing enquiries and complaints and analysing them to prevent failures and rectify impacts.

  • Customer Welfare: Considering customers' welfare needs and providing necessary adjustments, support, or protection.

  • Product and Service Improvement: Developing and improving our products and services, including conducting customer surveys and research, and obtaining feedback from customers.

  • Business Continuity: Ensuring business continuity, disaster recovery, and network and information security.

Lawful Basis for Processing Special Category Data

Data Protection laws treat some types of personal information as being particularly sensitive. This information is called ‘Special Category Data’. We will not collect or use these types of data unless the law allows us to. If we do, it will be under one of the following lawful bases:

  • Substantial Public Interest: For reasons of substantial public interest; or

  • Explicit Consent: We have your explicit consent to do so; or

  • Legal Claims: To establish, exercise or defend legal claims.

How long does Help to Buy (Wales) Limited keep my information?

We keep your information for the duration of your query and normally delete it after 2 years unless you request ongoing communication. This includes correspondence you have with us by email or via the 'Contact Us' form on our website.

If we need to keep your personal information for a longer period than stated, we will do so to either to comply with the law, if there are existing claims or complaints that will require us to keep your information, or for regulatory or technical reasons.

What happens if I do not provide my information to Help to Buy (Wales) Limited?

If you do not provide the information we request, we may be unable to respond to or resolve your query.

3. Using your personal information to keep you informed of our products and services

Why does Help to Buy (Wales) Limited need to use my personal information?

If you would like to be kept informed of our services, we will use your personal information to send you direct marketing communications (such as emails). We will only do this if you have agreed to us using your personal information for this purpose.

What information do I need to provide to Help to Buy (Wales) Limited?

You may provide us with your name and contact details via our application, registration, or expression of interest forms, which can be found on this website. 

What does Help to Buy Wales do with my information?

We use your contact details to provide you with information about our products and services. We never sell or share your information with third parties for marketing purposes.

What is the lawful basis for using my information?

Under data protection law, we must have a valid lawful basis for collecting and using your personal information. When we use your information for marketing purposes, the following lawful bases apply:

Legitimate Interests

Where we use your information for marketing purposes, we process your personal information for the following reasons under our legitimate interests: 

  • Informing you about our Products and Services: Informing you about the products and services of the DBW Group.

  • Product and Service Improvement: Developing and improving our products and services, including conducting customer surveys and research, and obtaining feedback from customers.

Consent

Where we ask for your consent before we send you marketing information about our products and services. 

How long does Help to Buy (Wales) Limited keep my information?

We will keep your information until you opt-out of receiving marketing communications from us. 

What if I do not wish to receive marketing communications from Help to Buy (Wales) Limited?

You can opt-out of receiving marketing information at any time by emailing us at enquiries@helptobuywales.co.uk or by clicking the 'unsubscribe' link in our marketing emails.

Sending your Information Outside the UK

We may transfer personal information to countries outside the UK when:

  • You request for us to do so.

  • We’re required or permitted to by law.

  • We’re sharing data with a third party to support us in managing your account. 

When working with our suppliers and/or transferring information to countries outside the UK, we take appropriate steps to ensure that there is adequate protection in place and that data protection legislation is followed.

This could be by:

  • Ensuring that we transfer information to countries that we believe have comparable data protection legislation to the UK.

  • Putting suitable clauses in our contracts so that organisations take appropriate steps to comply with UK data protection law.

If you would like more information on this, don’t hesitate to get in touch.

Your Data Protection Rights

Under data protection laws, you have certain rights over your personal information. Below is a list of these rights, including a description and how to contact us about them:

  • The right of access – You have the right to ask for copies of your personal data (this is also known as a subject access request).

  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate, and the right to complete information you believe is incomplete.

  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions

  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

  • The right to complain to the regulator - the Information Commissioner's Office, if you are unhappy about how your personal data is being used. The ICO can be contacted at www.ico.org.uk. 

  • Rights in relation to automated decision making – You have rights to object to your personal information being used for any automated decision making, including profiling.

If you would like to exercise any of the rights set out above, please email us at dpo@developmentbank.wales or write to us at:

DATA PROTECTION OFFICER

Development Bank of Wales, 

1 Capital Quarter, 

Tyndall Street, 

Cardiff, 

CF10 4BZ.

How to Raise a Concern or Make a Complaint

To the Development Bank of Wales:

If you have any concerns or complaints about how we use your personal information, we would appreciate the chance to resolve them in the first instance. You can make a complaint to us at dpo@developmentbank.wales or write to us at the same address as above.

To the Information Commissioner’s Office (ICO):

If you are unhappy with how we have used your personal information or dealt with your concern or complaint, you can also complain to the UK data protection regulator, the ICO. The ICO can be contacted at www.ico.org.uk or by phone on 0303 123 1113.