Use of Personal Information
Conditions and Use of Information
Finsec products are only available to homeowners based in England and Wales aged over 18 and are subject to status. By accessing and using this website, you are agreeing to our Conditions of Use and Privacy statement below. Telephone calls may be recorded for security and for training, monitoring and compliance purposes.
Finsec Privacy Notice v1.2 21.03.18
Who We Are
Finsec Limited (‘we’ or ‘us’ or ‘our’) gather and process your personal information in accordance with this privacy notice and in compliance with the relevant Data Protection Regulation and law. This notice provides you with the necessary information regarding your rights and obligations, and explains how, why and when we collect and process your personal data.
Finsec Limited is a company registered in England and Wales under company number 04602134 and our registered office is at Palladium House, 1-4 Argyll Street, London W1F 7LD. We are registered on the Information Commissioner’s Office Register of Data Controllers under registration number ZA023813, and act as the data controller. Our designated person for Data Protection is Kevin Cooke, and we can be contacted at our principal place of business which is at 511 Centennial Park, Centennial Avenue, Elstree, Hertfordshire, WD6 3FG. Email firstname.lastname@example.org or telephone 0208 731 3087.
Information That We Collect & Process
Finsec Limited processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never intentionally collect any unnecessary personal data from you and do not process your information in any way other than specified in this notice.
The personal data that we collect from you (which may include more than one of you where an application is made jointly with others) is likely to include your personal, contact, employment and income, bank, financial, and property details, court orders, tenancy agreements and name of your tenant, other occupiers of your property over the age of 18 and their name and relationship to you, the purpose and amount of your loan request and in certain circumstances special category data (health/medical information where you tell us this because you feel this will help us assist you better and if you provide documents that contain, or otherwise volunteer to us, data that constitutes special category personal information then you will be regarded as having accepted our processing of that data). This list may not be exhaustive and should not be read as such.
If you make an application on behalf of another individual, jointly with another or on behalf of a business with others and you provide us with personal information related to them, then this privacy notice will also apply to the information that we collect about those individuals. You must provide a copy of this notice to them as soon as possible and confirm that they have read and understood it.
How We Use Your Personal Data
Finsec Limited takes your privacy very seriously and other than in the ways specified in this notice we will never disclose or share data without your consent unless required to do so by law. Similarly we will not sell your data without your consent. We only retain your data for as long as is necessary and for the purposes specified in this notice.
The purposes and reasons for processing your personal data and our legal basis for processing it is for our legitimate interest, for the performance of a contract and our legal obligation as follows:
- We collect your personal data as we have a legitimate interest where you make an application to borrow from us and to meet responsible lending requirements we make credit reference and affordability checks and verify your identity and details for the prevention of financial crime;
- We collect and retain your personal data in the performance of a contract and to provide a service in administering your mortgage account if you borrow from us;
- We collect and store your personal data to meet our legal obligation for regulatory reporting and business accounting and tax purposes, and for reporting to credit reference agencies and fraud prevention agencies to meet our obligation for responsible lending and prevent financial crime.
Sharing and Disclosing Your Personal Information
Finsec Limited may share your personal data with third parties including your advisor and intermediary or broker who introduced you to us as necessary for our legitimate interests and so we may fulfil our legal obligation; credit reference agencies and fraud prevention agencies to perform credit and identity searches necessary for our legitimate interests and compliance with our legal obligation; any entity (and their professional advisors) who provide funding to us including any potential purchasers of any part of our business and professional advisors and contractors engaged in providing services to us in administering our business necessary for the performance of our agreement with you and necessary for our legitimate interests, and those processors who are acting on our behalf will only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. We may share your personal data with regulators, government bodies, law enforcement agencies and the courts when it is necessary for our legitimate interests and in order to meet our legal and regulatory requirements.
How We Collect Personal Data
We collect information directly from the application you make to us and supporting documents and letters and emails you send to us and indirectly from the application form and application supporting documents provided to us by your broker or advisor, from credit reference agencies (CRAs) and fraud prevention agencies and Companies House when we carry out searches for the processing of your application and during the course of your relationship with us.
Credit Reference Checks
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take a loan from us we may also make periodic searches at CRAs to manage your account with us.
To do this, we will supply your personal information to CRAs and they will give us 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 information.
We will use this information to:
- Assess your creditworthiness and whether you can afford to take the product;
- Verify the accuracy of the data you have provided to us;
- Prevent criminal activity, fraud and money laundering;
- Manage your account(s);
- Trace and recover debts.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us 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 your records together, so you should make sure you discuss this with them, and share with them this information, 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 in the Credit Reference Agency Information Notice ‘CRAIN’ which is also accessible from each of the three CRAs – any of these three links will take you to the same CRAIN document:
- Callcredit http://www.callcredit.co.uk/crain
- Equifax http://www.equifax.co.uk/crain.html
- Experian http://www.experian.co.uk/crain/index.html
Please ask us if you require details of the CRAs or any other agencies from whom we obtain, and to whom we pass information about you. You have a right to receive this.
You have the right to access any personal information that Finsec Limited processes about you and to request information about: –
- What personal data we hold about you;
- The purposes of the processing;
- The categories of personal data concerned;
- The recipients to whom the personal data has/will be disclosed;
- How long we intend to store your personal data for;
- If we did not collect the data directly from you, information about the source.
If you make a request we will provide this information within one month of receipt of your request unless the request is complex or numerous in which case we may extend the period of compliance by up to two months and if this is necessary we will then notify you within one month of the date of receipt of your request.
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to update/correct it as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data, although this right is not absolute and only applies in certain circumstances, or to restrict processing in accordance with data protection laws, as well as object to any direct marketing and be informed about any automated decision-making used.
If we receive a request from you to exercise any of the above rights we will explain whether the right applies to you as these rights do not apply in all circumstances. We may ask you to verify your identity before acting on the relevant request to ensure that your data is protected and kept secure.
Where we Store Your Personal Information
We store your personal information in a secure database which resides within a file server accessed by computer and in document folders within secure filing cabinets housed in our entry protected offices based at our address at Elstree, Hertfordshire which is in the United Kingdom.
Finsec Limited takes your privacy seriously and we take every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place. Computers and file server are protected by fully configured firewall and virus protection. Database access is restricted to authorised employees, user name and password protected and software maintenance by restricted access VPN (Virtual Private Network) using secure encrypted and protected IP to IP connection.
Consequences of Not Providing Your Data
You are not obligated to provide your personal information to Finsec Limited, however, as this information is required for us to provide you with our services and products and because of our legitimate interests, we will not be able to offer any of our products or services without it.
How Long We Keep Your Data
Finsec Limited only retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We retain data and process data in the case of applications which do not result in a loan for 6 months following the end of the month in which the application was declined or terminated. We retain data and process data in the case of applications which result in a loan, for the duration of the agreement and for a period of 6 years following the final repayment or satisfaction or discharge otherwise of any debt or amount due or such further duration as required to meet legal, accounting and regulatory obligations thereafter.
Lodging A Complaint
Finsec Limited only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If you have a complaint that relates to the way your personal information has been handled and we cannot resolve this to your satisfaction you can contact the Information Commissioner’ Office (ICO) at http://www.ico.org.uk or by telephone on 0303 123 113.