Privacy Statement
The purpose of this document is to explain what data we collect, why we collect it and what we will do with it. We also explain how we protect the personal data we obtain.
Please read this Privacy Statement carefully because it contains important information.
The information we collect
We will need to collect personal data about you when you apply for car finance. This data will fall in to 3 main categories:-
- Personal Data – such as name, data of birth
- Financial Information – such as income, expenses
- Sensitive Data eg health, subject to gaining your informed consent.
How the information is collected
The above information will be collected in several ways. Via our website, in writing or over the phone or if f you apply for a job vacancy or make a complaint. Information will also be provided to us from third parties such as credit reference agencies, fraud prevention agencies, motor dealers or brokers.
Legal Basis for Processing
We only process information about you that we believe is necessary for us to provide our services to you or to improve the services that we are able to offer. We rely on four legal bases in order to processing data.
- Contract
Our contracts will always be in connection with our credit broking activities and the legal bases for processing data in this instance is to fulfil the performance of that contract ie providing you with our products and services.
- Legal Obligation
We may process your personal information to adhere with legal and regulatory obligations for example to demonstrate the relevant controls to the Financial Conduct Authority.
- Legitimate Interest
Data protection law allows us to use personal information for our genuine and legitimate reasons as long as we respect your rights and freedoms. As such where we use your personal data for our legitimate business interests, we will always carefully consider and balance any negative impact on you and your rights as a data subject ensuring that our legitimate interests never override your rights. We may for example consider it in our legitimate interest to process your personal data for marketing purposes but only where that marketing relates to products and services that are in line with the purpose for which the initial data was gathered.
- Consent
There will be circumstances where we will only process your data if we have consent to do so. For example, if you provide us with data that is classed as a special category of data such as health information, criminal records of convictions and offences, or allegations of criminal offences. We will only process this with your permission (unless we feel the processing is necessary to protect your vital interests or if the law allows us to do so). You have a right at any time to ask us to stop the processing of that specific data.
We will always gain your consent to the processing of your data for any other purpose than the original purpose for which is was gained, for example in connection with marketing activity unrelated to the original enquiry. Where consent is given, it can also be withdrawn at any time by contacting us either by phone, email or letter, please refer ‘How to Contact us’ below
Rights as a Data Subject
Right to be Informed – we provide this statement to ensure our customers understand how we collect and process personal data.
Rights of Access – we will provide copies of personal data held free of charge of charge within one month of receiving an access request.
Right to Rectification – if we hold inaccurate data please advise us of the correct data and your records will be amended without undue delay, typically within 2 working days.
Right to Data Portability – you have the right to receive the personal data about you, which you have provided to us, in a structured and machine-readable format. You also have the right to transmit the data to another controller.
Right of Restriction of Processing – in the circumstances that there is a claim to the accuracy of personal data, or you have challenged the legal basis or legitimate grounds for processing, you have the right to obtain the restriction of processing.
Right to Object – you have the right to object to processing of your personal data on the basis that it is contrary to your rights, we will respond within one month.
Right to Erasure – you have the right to have your personal data erased in certain circumstances, we will respond to right to erasure requests within one month.
Right to Understand the Data Source – where your data was obtained from a third party, you have the right to be informed of the source of the data.
Right to be Advised of any Automated Decision making – aside from where the information is necessary for entering into a contract, or you have given your explicit consent, you have the right not to be subject to a decision based solely on automated processing
How we may use and share your personal information
We will use the personal information you provide us with to progress your application for finance. We will carry out credit reference agency searches, the results of which will help us select the most appropriate funder for your circumstances. We may also provide you with marketing material however where this material is not in accordance with the original purpose of providing the data to us, we will first seek your consent. We will also always provide an easy way to opt out of receiving marketing material.
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. For details of how your information will be used by us and these fraud prevention agencies, and your data protection rights in relation to this, can be found at https://www.cifas.org.uk/privacy-notice
Where available we have listed below the third parties that we may share your personal data with, in order to progress your application. We have also provided a link to those providers privacy policies detailing how that third party will use your information.
Lenders
- Advantage Finance Limited – https://www.advantage-finance.co.uk/home/privacy.asp
- Oodle Financial Services Limited – https://oodlecarfinance.com/use-of-information-statement/
- Marsh Finance Ltd – http://www.marshfinance.com/privacy-policy
- Billing Finance – https://billingfinance.co.uk/privacy-policy/
- Auto Money Motor Finance – https://www.automoneymotorfinance.co.uk/privacy-policy/
- Blue Motor Finance – https://www.bluemotorfinance.co.uk/PrivacyPolicy
- Moneybarn – https://www.moneybarn.com/privacy-policy
- Specialist Motor Finance – https://www.thefundingcorporation.com/privacy-policy
- Paragon Bank PLC – https://www.paragonbank.co.uk/data-protection/
- Close Brothers Motor Finance – https://www.closemotorfinance.co.uk/privacy-policy
- Moneyway – https://www.moneyway.co.uk/privacy-statement
- Go Car Credit – https://www.gocarcredit.co.uk/privacy-notice/
- Lendable Limited TA Autolend – https://www.lendable.co.uk/privacy
- Zopa Bank Limited – https://www.zopa.com/privacy-notice
Other
Credit Reference Agencies, Call Credit Limited (www.callcredit.co.uk/legal-information/privacy-centre, Experience (www.experian.co.uk/legal/privacy-statement.html, Equifax www.equifax.co.uk/abou-us/privacy_policy.html)
Law Enforcement bodies, to comply with our legal obligations
Credit Checking and Automated Decision Making
To process your application, both Bright Car Finance and the finance lenders will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). The personal information that you have supplied will be sent via the finance lender, to the credit reference agencies (CRAs) who will provide back to that provider, personal information about you. This will include information about your financial situation such as payment profiles on past and current credit accounts, defaults and county court judgements. The CRAs will supply both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
This information will be used to:
(a) Assess your creditworthiness and whether you can afford to take the product
(b) Verify the accuracy of the data you have provided to us
(c) Prevent criminal activity, fraud and money laundering
(d) Ensure any offers provided to you are appropriate to your circumstances.
When CRAs receive a search enquiry, they will place a search footprint on your credit file that will not be seen by other lenders, until a contract is entered with that lender / finance provider.
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 at each of the three CRAs websites – clicking on any of these three links will take you to the same CRAIN document:
Callcredit [http://www.callcredit.co.uk/crain];
Equifax [https://www.equifax.co.uk/crain];
Experian [http://www.experian.co.uk/crain].
We have processes and systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information with fraud prevention agencies, if false or inaccurate information is provided and fraud is identified.
We may used automated processing to market our products and services directly to you via SMS or email. Where we do this, we will be doing so with your consent or under a legitimate business interest. You have the right to opt out of this at anytime.
Credit scoring means that the decision is automated. We do use credit scoring to help locate the most appropriate lender for you, however we do not reject any applications solely based on a credit scoring system, all applications are subject to a manual assessment.
Retention Period
We will only process your personal data providing you have given your consent for us to do so. Under the provisions of the DPA, Bright Car Finance’s lawful basis for processing personal data is based on a Legitimate Interest.
The legitimate interest relates to a legal requirement for Bright Car Finance Limited to hold your personal data and financial information on record for up to a total of six years. This six-year period satisfies the requirement of our regulator, The Financial Conduct Authority and it also in line with other financial industry retention periods.
Data Complaints
For the purpose of the Data Protection Act we are the Data Controller and are therefore responsible for your personal data and the control and/or processing of when passed to Bright Car Finance Limited. Should you wish to contact the Data Controller, you can do so by emailing mark@brightcarfinance.co.uk directly.
You also have the right to lodge a complaint with the Information Commissioners Office (ICO), www.ico.org.uk, telephone 0303 123 1113.
Data Security
Bright Car Finance Limited will only store data where it is safe to do so. We will only store your data on a secure CRM which is password protected. We will ensure that where any personal data is stored, appropriate and proportionate steps will be taken to secure that data.
How to contact us
Please contact us if you have any questions about our privacy policy or information we hold about you, by email hello@brightcarfinance.co.uk or in writing to: Bright Car Finance Limited, The Parade, 31 Hoyle Road, Hoylake, Wirral, CH47 3AG
