1. Who We Are
We are Carrick Asset Finance Limited (“we“), a company registered in England and Wales (company number 11146023) whose registered office is at Suite 1, 7th Floor, 50 Broadway, London, SW1H 0BL. Our principal trading office is at New Alderston House, 3 Dove Wynd, Strathclyde Business Park, Bellshill, Glasgow, ML4 3FB.
We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation.
Our registration number at the Information Commissioner’s Office is ZA455752.
2. How to Contact Us
If you have any questions about this fair processing notice or our data protection policies generally, please contact us:
By post: New Alderston House, 3 Dove Wynd, Strathclyde Business Park, Bellshill, Glasgow, ML4 3FB
By email: firstname.lastname@example.org
By phone: 0141 530 1722
3. Privacy Notice
3.1 We are committed to protecting your personal data and your privacy. This fair processing notice sets out the basis on which any personal data we collect from you, or that you provide to us, or that we acquire from a third party, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
3.2 This fair processing notice applies to individuals who are our customers as a sole trader or who are employees or partners of a partnership that is a customer or who are directors, employees or beneficial owners of a corporate entity. This fair processing notice also applies to individuals who act or may act as guarantors on behalf of a customer.
3.3 Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data.
4. What personal data do we collect and process?
4.1 Data provided to us by third parties. We initially receive personal data relating to you from the party that introduced you or your organisation to us as a prospective customer or guarantor. Before we provide financing or any other services to you or your organisation or accept you as a guarantor, we undertake credit and identity checks using external credit reference agencies (CRAs) and fraud prevention agencies (FPAs), and we receive further personal data relating to you in response to such checks.
This will include information from your credit application (or your organisation’s credit application) and about your financial situation and financial history. CRAs will supply to us public (including the electoral register) information as well as shared credit, financial situation and financial history information and fraud prevention information.
4.2 The personal data that we receive from third parties may include:
- your name
- your date of birth
- your residential address and address history
- your contact details such as email address and telephone numbers
- your employment details
- your credit application
- your financial situation and financial history (including any shared credit or financial information)
- your credit information and credit history (including previous applications and conduct of accounts in your name, in the name of a financial associate or the conduct of any business accounts)
- information verifying your identity
- fraud prevention information
- public information (such as court judgments, bankruptcies and electoral register information)
4.3 Data that you give us or that we collect from you. You provide personal data to us when you enter into a contract with us. We may collect personal data when you correspond with us by telephone, e-mail or otherwise and we will collect personal data during the lifetime of a contract between us.
4.4 The personal data you provide or we collect from you, may include your:
- personal details (including your name, date of birth, and residential address and address history)
- contact details such as email address and telephone numbers
- financial information
- credit history
- employment details
- details of the asset(s) financed
- payment history
5. How is your personal data used?
We process and use your personal data for the following purposes:
5.1 VERIFICATION AND IDENTITY AND FRAUD PREVENTION
5.1.1 Purposes of processing. In order to process your application (or your organisation’s application), we undertake checks with one or more fraud prevention agencies (FPAs) for the purposes of preventing fraud and money laundering, and to verify your identity.
FPAs will process your personal data in order to provide us with information about you, which may include verification of identity and fraud prevention information. If you have requested services and financing from other providers, FPAs may receive your personal data from those providers too. FPAs may also process your personal data in order to detect and prevent fraud and money laundering by other people.
5.1.2 Sharing of data. We will share your personal data with FPAs, which will include information from your credit application (or your organisation’s application) for the above purposes.
We, and fraud prevention agencies, may permit law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
5.1.3 Consequences of processing. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the financing or other services you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.
5.1.4 Lawful basis of processing. When we, and fraud prevention agencies, process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the financing or other services you have requested.
5.2 CREDIT CHECKS
5.2.1 Purpose of processing. In order to process your application, we perform credit checks on you with one or more credit reference agencies (CRAs) at the time of your application (or your organisation’s application). We may also make periodic searches at CRAs to manage your account (or your organisation’s account) with us, if we suspect fraud or if we spot that you have provided inaccurate data. These checks require us to process personal data about you.
To do this, we will supply your personal data to CRAs and they will give us information about you. This will include information from your credit application (or your organisation’s application) and about your financial situation and financial history. CRAs will supply to us public (including the electoral register) information as well as shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- assess your (or your organisation’s as applicable) creditworthiness and whether you (or your organisation, as applicable) 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) (or your organisation’s account(s));
- trace and recover debts; and
- ensure any offers provided to you or your organisation are appropriate to your circumstances.
5.2.2 Sharing of data. We will continue to exchange information about you with CRAs while you have a relationship with us and where your organisation is our customer, for so long as you are an employee, director, member, partner, beneficial owner or guarantor of such organisation. We will inform the CRAs about your settled accounts (or your organisation’s settled accounts), as well as advise them of any missing payment or other non-compliance with the contract(s) between you or your organisation and us. If you or your organisation 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.
5.2.3 Consequences of processing. When CRAs receive a search from us they may 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.
We may also, in certain limited circumstances, check the record of other members of your family and, if you are a partner or director in a small business, also check on your business.
5.2.4 Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with our legal obligations as a regulated financial provider. Where the relevant contract is directly between us such processing is a contractual requirement of the services or financing you have requested. Where the relevant contract is with your organisation, such processing is in our legitimate interests in establishing the creditworthiness of our customers and ensuring their ability to pay for the financing or other services requested.
5.3 CONTRACTUAL OBLIGATIONS
5.3.1 Purposes of processing. We will process your personal data for the purpose of entering in to a contract with you or your organisation and thereafter for the purposes of carrying out our obligations under any such contract(s) and if necessary of enforcing any such contract(s). Such processing will include assessing your application or your organisation’s application for services or financing against our criteria for such services or financing and such processing may include contacting you from time to time by telephone, e-mail or post for the purpose of administering your account or your organisation’s account, including informing you of any arrears.
5.3.2 Sharing of data. In the course of a contract (including enforcement of a contract), we may share your personal data with our third party service providers or agents who administer parts of the contract(s) on our behalf. Such third party service providers include banks, software service providers (including document management and customer relationship management system providers), data storage providers, debt collection agents, valuation companies and dispute resolution providers. Any personal data shared with a third party service provider is strictly limited to the data required for the third party to provide the relevant services relating to the contract(s) entered between you (or your organisation) and us.
We may disclose relevant personal data to any company which provides maintenance of the asset(s) relating to the contract(s) entered into between you (or your organisation) and us, as well as any party which negotiates a purchase of such asset(s) from you (or your organisation) or us.
We may also disclose your personal data to our or your legal advisors or the legal advisors of your organisation, in particular where this is necessary to enforce any contract(s) entered into between you or your organisation and us.
5.3.3 Lawful basis of processing. When we, or any relevant third party service provider, processes your personal data for the above purposes, we do so on the basis that this is necessary for the performance of an agreement relating to you (where the contract is directly with you). Where the contract is with your organisation, we process your personal data for the above purposes on the basis of our legitimate interests in performing the contract with our customer and running our business efficiently and profitably.
5.4 ADMINISTRATIVE INFORMATION
5.4.1 Sharing of data. We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal data to third parties:
- in the event we obtain funding for providing you or your organisation with the asset, we may disclose your personal data to our funder; Our funders include:
° Bank of London & the Middle East. To understand how Bank of London & the Middle East use your personal data please visit www.blme.com/website-terms-conditions/privacy-notice/
° Recognise Bank Ltd. To understand how Recognise Bank Ltd use your personal data please visit www.recognisebank.co.uk/privacy-notice/
° Walbrook Asset Finance Ltd. To understand how Walbrook Asset Finance Ltd use your personal data please visit www.walbrookasset.com/privacy-policy/
- in the event that we sell or buy any business or assets, in which case we may if relevant disclose your personal data to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers (and their employees, directors, partners, members, beneficial owners or guarantors) will be one of the transferred assets);
- if you do not pay your debt, we may transfer your debt to another organisation and give them details about you and that debt; or
- if we take out an insurance policy in relation to the asset because you have failed to do so, we will pass information to the insurer to manage that insurance (including underwriting and claims and to assess financial and insurance risk).
5.4.2 Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives and managing credit risk.
5.5 COMPLIANCE WITH LEGAL OBLIGATIONS
5.5.1 Purposes of processing. We may process (including share) your personal data with relevant bodies (including the Financial Conduct Authority, HM Revenue and Customs, accountants and auditors):
- in order to comply with any legal obligations binding on us; and
- to protect the rights, property, or safety of our staff, our customers, or others. We may also process (including share) your personal data with legal advisors, Courts and tribunals and any other applicable regulatory authority for the purpose of establishing, exercising or defending our legal rights.
5.5.2 Lawful basis of processing.When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with a legal obligation to which we are subject (including our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015) or necessary in order to protect the vital interests of a natural person, or in our legitimate interests in establishing, exercising or defending our legal rights, respectively.
6. Automated Decision Making
6.1 As part of the processing of your personal data, decisions may be made by automated means in connection with credit profiling and fraud or money laundering risk. This means we may automatically decline the provision of services or financing (i) based on your credit profile with CRAs; or (ii) based on information received from FPAs regarding whether you pose a fraud or money laundering risk.
6.2 You have rights in relation to automated decision-making, including the right to request a review of the accuracy of a decision that you are unhappy with.
7. Your Rights
7.1 Your personal data is protected by legal rights, which include your rights:
7.1.1 to be informed how your data is processed through notices such as this;
7.1.2 to access your personal data;
7.1.3 to rectify your personal data if it is inaccurate or incomplete;
7.1.4 to erase your personal data where there is no compelling reason for its continued processing;
7.1.5 to restrict processing;
7.1.6 to data portability;
7.1.7 to object, on grounds relating to your particular situation, to the processing of your personal data where the processing is based on our legitimate interests; and
7.1.8 in relation to automated decision making and profiling.
7.2 If you want to exercise any of these rights, please contact us using the details above.
7.3 You also have the right to complain to the Information Commissioner’s Office, which regulates the processing of personal data, about how we are processing your personal data
8. Data Retention
We will retain your information as long as such information is required for us to comply with our legal obligations or to carry out our obligations arising from, and administer and enforce, any contracts entered into between you and us and deal with the assets which are the subject of any such contract. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We will usually retain your personal data for 6 years following the expiry of all contracts for services relating to you, unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation. Such legal obligations include our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015.
9. Data Transfers
We do not transfer personal data outside of the European Economic Area, but we do share personal data with fraud prevention agencies and credit reference agencies who may transfer your personal data outside of the European Economic Area.
Whenever fraud prevention agencies or credit reference agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data. Those obligations require the recipient to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
10. Failure to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with financing or other services). In this case, we may have to cancel such financing or service you have with us but we will notify you if this is the case at the time.
10. Changes to our fair processing notice
Any changes we may make to our fair processing notice in the future will be posted on our website. Please visit www.carrickfinance.com to see any updates or changes to our fair processing notice.
The three main credit reference agencies Callcredit, Equifax and Experian (also called ‘CRAs’) each use and share personal data they receive about you that is part of, derived from or used in credit activity and this is explained in more detail in the Credit Reference Agency Information Notice available at any of the following:
- CallCredit Limited, Consumer Services Team, PO Box 491, Leeds, LS3 1WZ or call 0330 024 7574 or visit callcredit.co.uk/crain
- Equifax Limited, Customer Service Centre, P.O. Box 10036, Leicester, LE3 4FS or call 0800 014 2955 or visit equifax.co.uk/crain
- Experian Limited, Customer Support Centre, PO Box 8000, Nottingham, NG80 7WF or call 0344 481 0800 or visit experian.co.uk/crain
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New Alderston House,
3 Dove Wynd,
Strathclyde Business Park,