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These will demonstrate a high level of understanding of the To put in place the necessary data audits, risk review, maximum value from their technology solutions. management systems, such as 360 Dotnet and Networks,
requirements and support the operational control framework policies and practice audits will improve our businesses and like ourselves, who are currently working tirelessly to
should a third party such as the ICO request an insight. reduce the scope for procedures that may inadvertently Emma Hall, Gwlegal: I believe that greatest challenges implement the correct measures to protect Broker’s
have been previously detrimental to clients. will be as a business deciding what level of data is business.
David Gilman, Blacks Connect: The same threat as compliant under the new rules to keep and for how long
it poses to any business. That is, enhanced entitlements Mark Dryden, 360 Dotnet: In general terms: greater before certain data is deleted, as we all have different Ingard has conducted an indepth analysis of our internal
for data subjects (that’s each of us - as individuals) to transparency of controls and data ownership, greater interpretations. processes and Members’ processes, to enable us to decide
demand and receive data on Subject Access Requests, rights to individuals, and a strengthened focus on data on the best method to monitor and regularly review, the
to correct that data, and to be forgotten. In terms of security and retention. This will then become a foundation GDPR changes to procedures which we will be shortly
marketing it will spell an end to reliance on historic for new innovations and capabilities such as Open Banking introducing.
databases and consents, and new requests for full and integration and usage of data into other contexts. Do you feel Mortgage Brokers
informed consent to be approached for marketing Over the next few weeks Ingard will be releasing clear
purposes, on an opt-in rather than an opt-out basis. Emma Hall, Gwlegal: There will be an improved are adequately preparing their guidelines to our Network Members to ensure they are able
communication between Brokers and Clients on the to effectively prepare all areas of their business over the
In terms of data breaches, it imposes stricter timescales understanding of what data they hold about their clients. business for these changes? next three months. This will begin with a comprehensive
for reporting to the Information Commissioner. The There will be a more conscious effort to protect clients’ overview of the GDPR at our Training Academy in February.
overarching threat is that of higher fines from the data to reduce risk of fraud. Louisa Sedgwick, Vida Homeloans: Market surveys
ICO’s office up to a maximum of the higher of 4% of suggest that preparations could be improved. It is We would also like to welcome Directly Authorised Brokers
turnover or Euro 500,000 – though hopefully the scale important to stay calm, read the new rules and understand who would like guidance on the best way to approach
of breaches from Brokers are unlikely in most cases to the level of impact and prepare your business for 25th May the new regulation, or a bespoke review of their current
attract maximum level fines unless/until the Broker What do you think the greatest 2018. The cost of non-compliance with the GDPR could be documents and processes, to contact us.
has promised to improve security to reduce the risks high and, given that Mortgage Brokers will be impacted,
of breaches, but fails to do so after several warnings. challenge will be for today’s you have an obligation to effectively prepare for these

Mark Dryden, 360 Dotnet: There’s no threat, but there is Mortgage Brokers? changes now.
scope for opportunity. GDPR provides greater transparency David Gilman, Blacks Connect: Good question! Firstly,
and control to an individual, which in turn increases Louisa Sedgwick, Vida Homeloans: Their greatest I think Brokers are aware of the impending changes. If
understanding and trust when they share their data. challenge is likely to be the implementation and they are AR’s, then their Networks will be guiding them
documentation of a robust control framework that through the requirements and transition stage.
Emma Hall, Gwlegal: Some, particularly larger Broker incorporates all requirements under the GDPR.
firms are at risk of an influx of requests from previous For Directly Authorised Brokers, I’m sure most are
clients, which could lead to administrative burdens. 5 Top Tips for Brokers include: underway with the review and implementation of the
new rules. If not, then there is a huge amount of support
1. Do NOT ignore the GDPR. However, do not panic. The available within the sector, e.g. from Mortgage Clubs, and
GDPR may have less of an impact than you imagine. Have external individual sources.
What positive effects do you feel a GDPR Champion to help implement the regulation.

GDPR will have on the mortgage 2. Ensure the relevant documentation is in place including We do like a deadline in our industry, so I wouldn’t be
surprised to see the clamour for advice and putting new
industry? policies, procedures and a data inventory. procedures in place, intensify as we near the deadline.

3. Gain an appropriate level of awareness of the key GDPR Mark Dryden, 360 Dotnet: This really does depend
Louisa Sedgwick, Vida Homeloans: A lot of the features including, but not limited to, consumer rights, on the organisation but embracing the features of 360
principles that lead to ‘best practice’ data protection consent requirements, Fair Processing Notices and data will go some way to helping organisations meet certain
processes already exist under the present Data Protection breach reporting. challenges. Dovetailing a Broker’s existing website and
Act. However, the enforcement mechanisms have changed brand with the Client Portal starts and maintains a digital
considerably to drive a high standard of behaviour. This 4. Make sure you have secure filing systems (physical and relationship with the client. Regular communications in
ultimately means significant benefits to a company in digital). Campaign Manager and automated reviews in the Hotbox
terms of increasing customers’ trust and decreasing has been proven to increase sales and client retention.
business risk. 5. Understand data collection, retention, transfer, storage
and deletion requirements. Emma Hall, Gwlegal: It is concerning in recent polls
David Gilman, Blacks Connect: The new legislation some Brokers are not prepared even some worryingly
puts the onus on everyone who hold or use personal David Gilman, Blacks Connect: The greatest challenge being unaware of the change at all. In saying that Brokers
data, including Mortgage Brokers to consider existing to Mortgage Brokers is probably if they have not already are already operating in a heavily regulated sector so
procedures and practices in their use of personal data, started thinking about finding the time and staff to get those that are prepared should have little impact.
and to check that it is complaint with the themes and rules their heads around the new legislation, and the changes
of the original DPA 1998. that they need to make. There may be a scramble for
external advice and consultants to help out!
The renewed focus on personal data arising from the Ingard’s Approach to GDPR
imposition of the GDPR will improve practices and policies Mark Dryden, 360 Dotnet: There’s no single challenge
so that consumers can expect better cyber security and to Mortgage Brokers, which is dependent on various
training of staff at all levels to consider what data they factors such as their client base, location, business plans, The GDPR should be embraced rather than feared, or
hold, and how it is used and kept and when it is ultimately etc. But in a very general sense, businesses may need worse, avoided until the last minute.
destroyed, to minimise the risk of breaches. to regularly review its digital engagement and online
presence, its client retention strategy and extracting the As highlighted in this article, there is a lot of guidance
and support available to Mortgage Brokers through client
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