What does this document do?
This Privacy Notice describes how personal data we collect from our clients will be collected, stored and processed. It also explains your privacy choices when using our website as well as your right to access your information under the Data Protection Act (DPA) 1998 up to 24th May 2018 and the General Data Protection Regulation (GDPR) from 25 May 2018 (Data Protection Legislation)
Heritage Commercial Finance Limited is a company registered in England and Wales with a company number of 1054019 whose registered office is situated at 1 The Old Foundry, Cowgate, Welton, HU15 1NB (Heritage Commercial Finance). For the purposes of Data Protection Legislation, Heritage Commercial Finance is the data controller and our Data protection officer is Mrs Allison Lee.
What information do we hold?
To operate efficiently, Heritage Commercial Finance has to collect and use information. This may include current, past and prospective employees also clients and suppliers. In addition we may be required to collect and use information to comply with regulatory requirements. This personal information must be handled and dealt with properly however it is collected, recorded and used whether it be on paper, in computer records or recorded by any other means and there are safeguards within the Act to ensure this.
We will never sell your data
The Company regards the lawful and correct treatment of personal information as very important to our successful operation and maintaining the confidence of all clients. We will ensure that we treat personal information lawfully and correctly.
Why do we need to collect personal information?
During an application process you will have given us consent to obtain necessary personal data to fully process the application. You have the right to refuse to provide that data, if you do we may not be able to proceed with the transaction.
Under the Data Protection Legislation we may collect personal data:
- To fulfil a contract we have with you
- When you consent it
- When it is our legal duty to comply with the law
- When it is our legitimate interest (providing it does not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is)
What will we use your personal data for?
We will use your personal data:
- To manage our relationship with you or your business
- To carry out our underwriting processes
- To liaise with third parties regarding your finance application/agreement
- For fraud prevention
- For statistical analysis
- Credit reference agencies
- To make lender decisions
How will we process your data?
We will do so in accordance with the Data Protection Legislation and shall ensure that your personal data:
- Shall be processed fairly and lawfully and in particular shall not be processed unless specific conditions are met
- Shall be obtained only for one or more specified and lawful purposes and shall not be further processed in any manner incompatible with that purpose or those purposes
- Shall be adequate, relevant and not excessive in relation to the purpose or purposes for which is processed.
- Shall be accurate and where necessary kept up to date
- Shall not be kept for longer than is necessary for that purpose or those purposes
- Shall be processed in accordance with the right of data subjects under the Act
- Shall be kept secure and protected by an appropriate degree of security
- Shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of data protection
We do not use any form of automated decision making to make decisions about you.
Your rights under the Data Protection legislation
You have the following rights:
- The right to be informed that processing is being undertaken
- The right of access to one’s personal information within the statutory one-month period
- The right to prevent processing in certain circumstances
- The right to correct, rectify, block or erase information regarded as wrong information.
- The right to be forgotten or to have your personal data erased
In addition we will ensure that:
- There is someone with specific responsibility for data protection in the organisation.
- Everyone managing and handling personal information understands that they are responsible for following good data protection practice
- Everyone managing and handling personal information is appropriately trained to do so
- Everyone managing and handling personal information is appropriately supervised
- Anyone wanting to make enquiries about handling personal information, whether it be a member of staff or a member of the public knows what to do
- Queries about handling personal information are promptly and courteously dealt with
- Methods of handling personal information are regularly assessed and evaluated
- Performance with handling personal information is regularly assessed and evaluated
- Data sharing is carried out under a written agreement, setting out the scope and limits of the sharing. Any disclosure of personal data will be in compliance with approved procedures
Who we might share your personal information with
We may need to provide your personal data to third parties for the following purposes:
- To carry out the completion of work that you have instructed, we will need to discuss with other parties including solicitors and surveyors plus any other parties relevant to your application
- To other parties where it is necessary for the administration of our business
- Where we need to do so to comply with our regulatory and legal obligations
- For prevention of fraud and money laundering
Where appropriate all contractors who are users of personal information supplied by Heritage Commercial Finance Ltd will be required to confirm that they abide by the requirements of the Data Protection Legislation with regard to information supplied to them by us.
Sharing your information with Fraud Prevention Agencies
To comply with the law and for our own legitimate interest to enable us to assess and manage risk, we can share details about your financial situation and financial history and the financial situation and history of individuals connected to your business with fraud prevention agencies.
We will carry out checks with fraud prevention agencies for the purpose of preventing fraud and money laundering, and to verify your identity and the identity of individuals connected to your business before we provide services to you. These checks require us and agencies to process information about you and individuals connected to your business.
The information you provide or which we’ve collected from you or on behalf of you includes any information from individuals connected to your business or received from third parties. This will be used to carry out these checks in order to prevent fraud and money laundering. This is also to verify your identity and the identity of individuals connected to your business. This includes information such as name, address, D.O.B, contact details, financial information and also employment details.
We and the fraud prevention agencies may also enable law enforcement agencies to access and use information about you and individuals connected to your business to help detect, investigate and also prevent crime.
We process this information on the basis that we have a legitimate interest in preventing fraud and money laundering. We like to verify your identity and also the identity of individuals connected to your business. This enables us to protect our business and to comply with laws that apply to us.
Fraud prevention agencies can hold information for different periods of time. If they’re concerned about a possible fraud or money laundering risk this information and data can be help by them for up to six years.
How long will we keep your personal information for?
We will keep your personal information for a minimum of 6 years after the end of the repayment of your finance agreements(s).
This period may be longer depending upon the circumstances of the loan agreement. The person responsible for your agreement will inform you of the relevant retention period for your file.
We may retain this data for one of the reasons below:
- To respond to any questions or complaints
- To show that we treated you fairly
- To maintain records according to rules that apply to us
- To comply with our regulatory obligations to act in your interests
- To protect our own legitimate interests
What if your personal information is incorrect?
You’re responsible for making sure the information you give is accurate and up to date. You must tell us of any changes as soon as possible.
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you wish to do this. If you do wish to do this, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information or ask us to delete, remove or stop using your personal information if there is no need for us to store it.
There may be legal or other reasons why we need to keep or use your data, but if you think we shouldn’t be using it then please inform us. We may be able to restrict the use of your data meaning that it can only be used for certain things such as legal claims or to exercise legal rights.
What to do if you have any questions of complaints?
Questions or requests in connection with this policy should be addressed by email to firstname.lastname@example.org or by writing to:
Mrs Allison J Lee,
Heritage Commercial Finance Ltd,
1 The Old Foundry,
If you are unhappy with the way in which we treat your data or we do not resolve any concerns with you then you have the right to make a complaint to the Information Commissioner’s Office.