This policy explains how we collect information, what we use the information about you for, the basis on which we collect it and your rights.
The information we hold is collected and managed by The City Broker Limited. We are based at 53 King Street, Manchester, M2 4LQ; Company Number 09872235
We are a credit broker and collect and use information to assist our clients in making applications for various types of credit. Our clients may be companies and/or individuals and this policy related to the use of information on individuals. All information we are provided with is held confidentially. We are authorised and regulated by the Financial Conduct Authority Ref No: 761049.
The Data Protection Officer for the company can be contacted on firstname.lastname@example.org or 0161 359 4358.
We collect your information from you, from credit reference agencies and financial institutions.
The City Broker Limited oversees all of the data management to ensure compliance with this policy and the data protection rules.
The personal information we collect and hold
We collect the following information from you, your business (if applicable) and credit reference agencies (‘CRAs’).
- Your name;
- Details of your business/employment;
- Your address;
- Your financial information;
- Your email address;
- Your date of birth;
- Bank details;
- Details of any litigation you have been involved in;
- Any bankruptcy or other solvency information;
- Identification documents, and;
- Criminal convictions.
How we use and disclosure personal information
We and third parties may use your personal data for the following purposes:
- providing our clients with a personalised service, which may be part of an application to consider finance options or part of any finance arrangements;
- create client accounts and to identify you;
- seek proposals for the provision of credit for you/your business or to obtain credit for you/your business we may provide your information to third parties who will consider funding the application. This is part of the application for credit and without this we cannot provide our services;
- assist with an application for credit and providing information to Credit Reference Agencies or Fraud Prevention Agencies. The use of this information may leave a credit footprint from the required checks – this is part of your application for credit or if the application is for credit for your business it is in our legitimate interests.
- Providing and administering the contracts we provide for you – this is part of the provision of the contract to you or your business. If it is to your business, we have a legitimate interest in processing your data.
- Also, providing you with information about promotions and products and services we offer – we provide this information as part our legitimate interests to let you know about other offers we can provide to your business.
We will use your data in considering applications for and providing any credit. We may share this information with third parties where necessary to provide the service. This may include funding providers who will provide funding to us or to whom we intend to assign any agreement. It is likely to include credit reference agencies as outlined below. We will confirm to you any lenders we will provide your details to. This information is all used so we and any lenders can carry out or obligations or rights under these contracts or applications with you or your business. The funding providers and CRAs will process your information as a Data Controller subject to their own privacy policies.
We may share your information with companies who provide services to us. Where we share data on this basis the companies must enter a data processing agreement to ensure that this policy, the data protection laws and your rights are protected.
We use your personal information when providing services to:
- prepare an application
- provide our services
- deal with any queries or meet any requirements of our regulators – this is a legal obligation on us
- assess your credit worthiness and whether you can afford to take the product (or your employer/business can)
- verify the accuracy of the data you have provided to us
- prevent criminal activity, fraud and money laundering
- manage your account
- to provide you with details of credit facilities which may be of interest to you
- ensure any offers provided to you are appropriate to your circumstances.
Where we process your data, it is subject to our strict internal policy requirements as well as the Data Protection regulations.
In situations where we are providing our credit broking services to you we use your information on the basis of your contract with us in providing our services. Where we are providing our credit broking services to your business/employer we use your information on the basis of our and your business/employer’s legitimate interest.
We may provide you with details of other credit offers and we do this on the basis of our legitimate interest to do so. If you do not want us to provide these offers please let us know – you may opt out of them at any time.
Credit Reference Agencies
In order to process an application, we and/or any lenders will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). We and/or any lenders may also make periodic searches at CRAs to pursue a credit application.
To do this we and/or any lenders will supply your personal information to CRAs and they will give back information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention.
When CRAs receive a search from us and/or any lenders they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application or tell us that you have a spouse or financial associate, we will link to your records together, so you should discuss this with them, and share this information with them, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail by the CRA’s on their websites in a Credit Reference Agency Information Notice (CRAIN). For Experian (our main CRA) the CRAIN can be found at: http://www.experian.co.uk/crain/index.html
How long will we hold your personal information
We will hold the personal information we use to meet the requirements of our agreements with you for the period of those agreements and any further period afterwards that we need for regulatory or other legal reasons (such as to defend any claims). This will usually mean that we will hold information for seven years after an agreement ends. We will remove any personal information we do not need when we no longer need it.
Where we have personal information which you have consented for us to use we will hold it for the period the consent remains in force and any other period we need for regulatory or other legal reasons. You may remove your consent at any time.
We will delete any information about you we no longer need. Please see below in relation to your rights to have data erased, rectified or for you to access it and for you to object to any processing or to transfer it.
You have a number of rights in relation to your personal information. These include the right to –
- Confirm if we are using data about you and to access details about what we are using and how;
- Lodge a complaint with the Information Commissioners Office;
- Request we rectify any inaccurate data corrected or to have data which is incomplete for the purpose we hold it completed;
- Be forgotten. Which is the right to ask us to delete information about you and if it is appropriate to do so we will do so;
- Restrict what we do with data in specific circumstances, including where the accuracy of the data is contested, processing is unlawful, but you do not want us to erase the data or if we only need the data to meet legal requirements;
- Receive the data we hold about you in a format you can use to transfer the data electronically elsewhere.
Your privacy and data protection is very important to us and we comply with all aspects of the Data Protection legislation and ensure that any third parties we engage do so. You can find out more about your rights to data from the Information Commissioners Office.
Some data processing may occur in other parts of the European Union (“EU”) or outside of the EU. Wherever data is processed your rights under the Data Protection Regulations will be met and we will ensure that any agreement to process your data ensures this and give you rights in the unlikely event of any security breach.
If you have any enquiry relating to your personal information, you can do so by sending an e-mail to us at email@example.com. (Please note that because of the insecure nature of emails we cannot accept any responsibility for data lost or intercepted in transit.) Or write to us at:
Data Protection Controller, The City Broker Limited, 53 King Street, Manchester, M2 4QL
Telephone 0161 359 4358