General Data Protection Regulation
One of the biggest changes to UK data privacy law comes into effect on May 25th 2018 The General Data Protection Regulation, known as GDPR, is a positive step towards you having more control over how your data is used and how you are contacted. The changes will also better protect your personal data.
We do: use data to provide a great customer service, which includes tailoring the information we share with you to help ensure that it is relevant, useful and timely.
We do: respect your privacy and work hard to meet strict regulatory requirements.
We Don’t: sell your personal data to third parties.
Customer Privacy Notice
Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing circumstances and your financial situation. (Your Personal Data). 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.
What do we mean by “Your Personal Data”?
In the context of providing you with assistance in relation to your Finance application, your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity.
- Employment and remuneration information, (including salary/bonus schemes/overtime/sick pay/other benefits), employment history.
- Bank account details, tax information, loans and credit commitments, personal credit history, sources of income and expenditure, family circumstances and details of dependants.
- Any pre-existing investment/mortgage/finance products and the terms and conditions relating to these.
The basis upon which our Firm will deal with Your Personal Data
When we speak to 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 for the purposes detailed below.
During 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.
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 to meet a legal, compliance or other regulatory obligation to which we are subject.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, but mainly directly from you. You will usually provide information during 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. If we use technology solutions to assist in the collection of Your Personal Data for example software that can verify your credit status. We will only do this if we have consent from you for us or our nominated processor to access your information in this manner. With regards to electronic ID checks we would not require your consent but will inform you of how such software operates and the purpose for which it is used.
What happens to Your Personal Data when it is disclosed to us?
In handling Your Personal Data, we will:
- Record and store Your Personal Data in our paper files, mobile devices and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service.
- Submit Your Personal Data to Product Providers/Commercial Lenders both in paper form, via email and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress any enquiry or application made on your behalf and to deal with any additional questions or administrative issues that lenders and providers may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to any finance product you may take out, or to inform you of any developments in relation to those products and/or polices of which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- Finance providers.
- Third parties who we believe will be able to assist us with your enquiry or application, or who are able to support your needs as identified. These third parties will include but may not be limited to, our Compliance Advisers and Product specialists, (in each case where we believe this to be required due to your circumstances).
In each case, your Personal Data will only be shared for the purposes set out in this Customer Privacy Notice, i.e. to progress your finance enquiry 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.
Security and retention of Your Personal Data
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, for example using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control.
- ask us to further explain how we use Your Personal Data.
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request).
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish.
- change the basis of any consent you may have provided to enable us to contact you for marketing purposes in the future (including withdrawing any consent in its entirety).
How to contact our Firm (Vehicle and Asset Finance Ltd) in relation to the use of Your Personal Data
If you have any questions or comments about this document or wish to make contact to exercise any of your rights set out within it, please contact: Mr Stuart Bowers at the address above.
If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.
You should also contact 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 https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.