When we provide services to you we will need to gather information about your personal circumstances (Your Personal Data). This will include us and any finance provider we wish to introduce you to, searching the files of one or more credit agencies.
This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth, National Insurance number. Your Personal Data may also identify you indirectly, for example, your employment situation, or any other information that could be associated with your cultural or social identity.
In the context of providing you with assistance in relation to your Finance requirements Your Personal Data may include:
When we speak with you about your finance requirements we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the products you require, we have the right to use Your Personal Data.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from lenders and our Compliance Service Provider relating to the advice we have given to you, or to make contact with you to seek feedback on the service you received.
On occasion, we will use Your Personal data for contractual responsibilities we may owe our regulator The Financial Conduct Authority, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during the course of our initial meetings or conversations with you to establish your circumstances and needs and preferences in relation to finance. You will provide information to us verbally and in writing, including email.
We may also obtain some information from third parties, for example, credit checks, information from your employer, and searches of information in the public domain such as the voters roll. We may use technology solutions to assist in the collection of Your Personal Data for example software that is able to verify your credit status.
In the course of handling Your Personal Data, we will:
From time to time Your Personal Data will be shared with:
In each case, your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress finance enquiries and to provide you with our professional services.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
We generally keep the personal information we use for at least seven years after the end of any facility which we make available/arrange for you (or any connected company) or from the date you (or such connected company) last used one of our services. In some circumstances we will hold personal information for longer than stated above where we believe that this is necessary for active or potential legal proceedings or to resolve or defend claims.
Your Personal Data will be retained by us either electronically or in paper format.
You have a right to object to our processing your Personal Data on grounds relating to your particular situation.
You also have the right, at any time, to stop us from contacting you or processing your Personal Data for marketing purposes.
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact the Data Protection Manager at 2.04 Flint Glass Works, 64 Jersey Street, Ancoats Urban Village, Manchester M4 6JW.
If we feel we have a legal right not to deal with your request, or to action, it in a different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at ico.org.uk/global/contact-us or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.