Privacy Notice

This explains how and why we acquire and use your personal information in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), and the Data Protection Act 2018.

We collect information about you:

• as part of your loan application and during the term of any agreement
• from you and from searches of Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (FPAs) of their records relating to you and other people with whom you are linked financially, from public records, e.g. the electoral roll and third parties e.g. credit brokers where you have provided information to them and consented for it be passed to us
• this includes your name, address, national insurance number, date of birth, contact details, marital status, employment information, credit record and records of your account.

We use your information to:

• make credit decisions about you, taking members of your household or others to whom you are linked financially into account
• communicate with you by telephone, email, SMS, or post
• manage your account, make collections and debt tracing
• prevent fraud and money laundering
• report to CRAs and FPAs
• report to our regulator, the Financial Conduct Authority, where we are required to do so.

This is to comply with our legal and regulatory obligations and fulfil our legitimate interests of promoting responsible lending. If you do not provide us with your information, we will not be able to lend to you.

We may also use your information for other purposes where you have consented to this for example for surveys and research.

We may share your information with:

• third parties to which we transfer, charge or assign your agreement or which manage your loan or provide services for us
• law enforcement agencies or regulatory bodies where we are required to do so by law
• CRAs and FPAs to which we may report positive, delinquent and default data about your account(s) on a regular (minimum monthly) basis. This information may be supplied to other organisations which search your credit record.

When CRAs receive a search from us they place a search “footprint” on your credit file whether or not the application proceeds. Records remain on file with CRAs and FPAs for 6 years after they are closed, whether your loan is settled by you or defaulted.

More information about CRAs and how they use personal information is available at https://www.experian.co.uk/legal/crain/ or you can contact the agencies below:

Experian, PO BOX 9000, NOTTINGHAM, NG80 7WP.
Tel: 0344 481 0800 or 0800 013 8888 or visit: http://www.experian.co.uk/consumer/contact-us/index.html

We store your information:

• within the United Kingdom (UK).
• we may transfer data outside of the UK but will ensure that before we do so, there is “adequate protection” in place to ensure the security of your data.

We keep your information:

• for as long as it is needed to manage your account and for a maximum of six years unless a longer period is required by law.

You have the right to:

• access the information we hold about you
• ask us to make any changes to your information to make sure it is accurate and up to date
• ask us to stop or limit our use of or to delete your information
• receive your information in a format that suits you
• transfer your information to a third party
• be told which CRAs we have used and obtain a copy of your file from CRAs.

Open Banking

This section of our Privacy Policy relates to Open Banking and should be read in conjunction with the other clauses in our Privacy Policy. In the event of conflict with any other clauses, this clause shall prevail.

What is Open Banking?

Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose.

Registered providers and participating banks and building societies are listed under the Open Banking Directory.

Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector.

As a forward thinking lender, we support the use of Open Banking as it allows us to process loan applications efficiently, securely and in our consumer’s best interests.

By permitting access to your bank or building society account information we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.

Further information about Open Banking is available from www.openbanking.org.uk.

How will my personal data be shared and used for the purposes of Open Banking?

By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Perfect Data Solutions Limited (“PDS”) who are also a credit reference agency. During your loan application we shall safely and securely direct you to PDS’s secure portal (“the Portal”) for the purposes of granting PDS access to your bank or building society account information (“Transaction Information”). As soon as your Transaction Information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”).

Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com.

Is Open Banking secure?

PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards.

We are responsible for the secure transmission of any Shared Personal Data to PDS, for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information.

You will not be required to share your banking password or log in details with either us or PDS. Once you have given your explicit consent to share your bank account information on the Portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.

Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with PDS or with your own bank or building society.

How will my Shared Personal Data and Transaction Information be used?

PDS shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.

PDS shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.

PDS shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on the Portal, which you will be required to read and consent to once directed their via our website.

As PDS are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.

Will you use my Transaction Information data for any other purpose?

The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.

Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.

Do I have to provide you with my consent to proceed?

(Client to define policy on options to consent)

Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.

Are any of my other rights under this Privacy Policy affected?

Your individual data protection and privacy rights including the right to access, correct, delete, object, restrict, withdraw consent, request transfer and/or make a complaint, continue to apply to relevant personal data we control or process and are dealt with elsewhere in this Privacy Policy.

Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.

Contact

If you have a question, want to exercise your rights or make a complaint, please contact our Data Protection Officer Geoffrey Dunning, 141 Priory Road, L4 2SG, 0151 260 5544.

You can also make a complaint to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113.

Agreement

I agree to the terms of this Privacy Notice and acknowledge that as part of my loan application the lender may undertake searches of my records with Credit Reference Agencies and Fraud Prevention Agencies and that information regarding my loan account including positive, delinquent and default data will be reported to those agencies and may be accessed by other organisations which search my records.