PRIVACY NOTICE / USE OF YOUR PERSONAL INFORMATION
1. This Privacy Notice explains what data We hold about You and how We plan to use it. It also explains your legal rights under Data Protection Laws.
In order to consider an application for credit and provide financing to You, We use the Personal Information and data your provide directly to Us, or via your intermediary in conjunction with data shared with credit reference agencies (CRAs), anti-money laundering and anti-fraud and data collected from sources available publicly including electoral register and the internet for the following purposes:
To verify your credit history and make lending decisions
To verify your identity
To manage your account
For fraud prevention
For audit and debit collection
For statistical analysis
All these checks require Us to process personal data about You.
3. DATA WE COLLECT & SHARE
We collect data, including personal data, that you have provided to either directly to us or via your intermediary, or We have received from third parties (such as persons who introduced Your application to Us, CRAs, debt recovery agencies, government agencies etc.), and other information which may be publicly available. This data may include:
Your date of birth
Your current and previous home addresses
Contact details including telephone numbers and email addresses
Any other information available to Us for use in processing your application
Information received from Credit Reference Agencies (CRAs).
Credit Reference Agencies collect and maintain data and information regarding consumers and business trends and credit behaviors. This information will include details of previous applications for credit, the conduct of the account and will also detail any adverse history including County Court Judgements, bankruptcies, defaults and decrees etc.
We use the information held by CRAs to consider your application. We provide the CRAs with your personal information, they will then supply Us with information they hold about you. This can include your current and historical financial position. For more details on which credit reference agencies We use, please contact us. The main CRAs within the UK are Experian, Equifax and CreditSafe, and you can obtain details of their Privacy Notices on their websites. The CRA will record a footprint of any searches conducted by Us and this will be visible to other lenders to which you apply for credit.
If You make a joint application with a spouse or financial or business associate, We and the CRAs will link your records together. It is essential that you inform your spouse or financial or business associate of your intention and obtain their permission to do so before providing us with their data.
We will continue to share and exchange information with CRA during the period in which You have a relationship with Us.
We will advise the CRA when Your account is settled and will also inform them of any defaults or failure to repay.
When We, CRAs and fraud agencies process Your personal information, We do so on the basis that We have a legitimate interest in assessing credit worthiness before signing a contract with You, in preventing fraud, terrorism and money laundering, and in verifying identity, in order to protect Our business and to comply with laws that apply to Us.
We will not retain Your personal information for longer than is necessary for the maintenance of Your account, or for legal or regulatory requirements. CRAs can hold your personal information for differing periods of time and you can check this on their websites.
We may disclose data to CRAs, fraud agencies and anyone who introduced Your application/data to Us in order to comply with any legal or regulatory requirements to do so, and also to any establishments we propose to transfer Our rights and/or responsibilities under any agreement We hold with You, each of who may use the personal information in the ways described in this statement.
Your personal data will be processed in accordance with the contractual requirements of the financial services you have requested.
Any phone calls between You and Us may be monitored and/or recorded in order to check We have carried out Your instructions correctly, to resolve any queries and/or issues, for regulatory purposes, and to improve Our quality of service. Recording can also be used to detect or prevent fraud or other crimes and again, this information can be passed to the relevant authorities. We will from time to time monitor conversations to enable us to improve standards and for staff training purposes.
4. AUTOMATED DECISIONS
When processing Your personal data, automated decisions can sometimes be made. This means that We may automatically decide that you are not approved for credit or for the amount of credit which has been requested.
You can also be automatically not approved for credit if there is reason to believe you pose a threat of terrorism, or money laundering or fraud if:
Our processing reveals that Your behavior to be consistent with that of known fraudsters, terrorists, or money launderers etc, or is believed to be inconsistent with Your previous submissions.
Automatic non-approval for credit can also occur if You appear to have deliberately hidden Your true identity.
If You submit an application for credit and it is declined through this automated process, you can contact Us within 21 days to have the decision reconsidered. You also have the right to ask that the decision is not made solely using a credit scoring system.
5. CONSEQUENCES OF PROCESSING
If We, a CRA or fraud prevention agency determine either that You are not approved for credit or that You pose a fraud, terrorism or money laundering risk, We may refuse to provide the financing You have requested or We may stop providing existing services to You.
A record of any fraud, terrorism, or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to You. You can contact Us if you wish to discuss this further. We will allow law enforcement agencies to access and use Your personal data to detect, investigate and prevent crime as governed by statute.
6.MARKETING OF SERVICES & FACILTIES
If you have consented to Us contacting You by email, telephone or post, We may send You details of any existing or new products which We feel may be of interest to you. You may withdraw Your consent at any time by advising Us either by email, telephone or post.
We may use information relating to Your product, which may also include personal information about You for statistical analysis purposes including how We perform as a business and to improve the services provided to Our customers. We also use this information for providing financial bodies with statutory reports as and when requested.
Your personal data is protected by legal rights, governed by English Law, and include Your rights to:
Request that Your personal data is erased or corrected;
Object to Our processing of Your personal data;
Request access to Your personal data
For more information or to exercise Your data protection rights, please contact us. If you are unhappy about how your personal data has been used, please refer to our complaints policy which can be obtained from us in writing or via our webpages.
You have the right to complain to the Information Commissioners Office (ICO) who regulate the processing of personal data.
This notice relating to the use of personal information is correct at the time of going to print in May 2018 and will be updated at regular intervals.