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To protect the security or integrity of your business operations;
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To other parties connected with me e.g. other people named on the
application including joint account holders who will see my transactions;
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When you restructure or sell your business or its assets or have a merger
or re-organisation;
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Market research organisations who help to improve your products or
services; and
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Anyone else where you have my consent or as required by law.
International transfers
My personal data may be transferred outside the UK and the European
Economic Area. While some countries have adequate protections for
personal data under applicable laws, in other countries steps will be
necessary to ensure appropriate safeguards apply to it. These include
imposing contractual obligations of adequacy or requiring the recipient to
subscribe or be certified with an ‘international framework’ of protection.
Further details can be found in the ‘Using My Personal Data’ booklet.
Identity verification and fraud prevention checks
The personal data you’ve collected from me at application or at any stage
will be shared with fraud prevention agencies who will use it to prevent
fraud and money-laundering and to verify my identity. If fraud is detected, I
could be refused certain services, finance or employment in future. You may
also search and use your internal records for these purposes. Further details
on how my personal data will be used by you and these fraud prevention
agencies, and my data protection rights, can be found in the ‘Using My
Personal Data’ booklet.
Credit reference checks
In order to consider my registration (including as part of an annual review of
my business) you’ll perform credit and identity checks on me at our home
and business addresses with one or more credit reference agencies. To do
this you’ll supply my personal data to the credit reference agencies and
they’ll give you information about me. When you carry out a search at the
credit reference agencies they’ll place a footprint on my credit file. A credit
search may either be: a) a quotation search where a soft footprint is left.
This has no effect on my credit score, and lenders are unable to see this; or
b) a hard footprint where I’ve agreed/requested Cater Allen to proceed with
my application for credit. This footprint will be viewable by other lenders
and may affect my ability to get credit elsewhere. You’ll also continue to
exchange information about me with credit reference agencies while I have
a relationship with you. The credit reference agencies may in turn share my
personal information with other organisations. The personal data shared
with the credit reference agencies will relate to me and my business. Details
about my application (whether or not it’s successful) will be recorded and
you’ll give details of me, the business and my accounts and how I manage
them to credit reference agencies. If I do not repay any debt in full or on time,
they’ll record the outstanding debt and supply this information to others
performing similar checks, to trace my whereabouts and to recover debts
that I owe. Records remain on file for 6 years after they are closed, whether
settled by me or defaulted. A financial association link between joint
applicants will be created at the credit reference agencies. This will link our
financial records and be taken into account in all future applications by either
or both of us until either of us apply for a notice of disassociation with the
credit reference agencies.
The identities of the credit reference agencies, and the ways in which they use
and share personal information is explained in more detail in the ‘Using My
Personal Data’ booklet, or via the Credit Reference Agency Information Notice
(CRAIN) document which can be accessed via any of the following links:
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experian.co.uk/crain
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equifax.co.uk/crain
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transunion.co.uk/crain
My marketing preferences and related searches
Any information or data supplied by me (or my customers, providing
their permission has been given) may be used for the purposes of
conducting market research, preparing strategic or other marketing
plans or gauging product sales.
You’ll use my home address, phone numbers, and email address and social
media (e.g. Facebook, Google and message facilities in other platforms)
to contact me according to my preferences. I can change my preferences
or unsubscribe at any time by contacting you. In the case of social media
messages I can manage my social media preferences via that social media
platform. If I’m over 18, you may search the files at credit reference agencies
before sending marketing communications to me about credit. The credit
reference agencies don’t record this particular search or show it to other
lenders and it won’t affect my credit rating. You do this as part of your
responsible lending obligations which is within your legitimate interests.
From time to time you’d like to contact me about products, services and
offers that may interest me or to get my opinion on how you are doing.
I understand you won’t bombard me and I can choose to stop receiving
information at any time by contacting you.
Each applicant can choose how they would like to be contacted within
section 1 of this form.
Automated decision making and processing
Automated decision making involves processing my personal data without
human intervention to evaluate my personal situation such as my economic
position, personal preferences, interests or behaviour, for instance in relation
to transactions on my accounts, my payments to other providers, and triggers
and events such as account opening anniversaries and maturity dates. You
may do this to decide what marketing communications are suitable for me, to
analyse statistics and assess lending risks. All this activity is on the basis of your
legitimate interests, to protect your business, and to develop and improve your
products and services, except as follows; when you do automated decision
making including profiling activity to assess lending and insurance risks, this
will be performed on the basis of it being necessary to perform the contract
with me or to take steps to enter into that contract. Further details can be
found in the ‘Using My Personal Data’ booklet.
Other information about me as an intermediary
You may also hold all the information I give to you (i.e. name, address, date
of birth, nationality) in order to undertake periodic due diligence checks
which banks are required to undertake to comply with UK legislation.
Criteria used to determine retention periods (whether or not I
become a customer)
The following criteria are used to determine data retention periods for my
personal data:
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Retention in case of queries. You’ll retain my personal data as long as
necessary to deal with my queries (e.g. if my application is unsuccessful);
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Retention in case of claims. You’ll retain my personal data for as long as
I might legally bring claims against you; and
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Retention in accordance with legal and regulatory requirements. You’ll
retain my personal data after my account has been closed or has otherwise
come to an end based on your legal and regulatory requirements.
My rights under applicable data protection law
My rights are as follows (noting that these rights don’t apply in all
circumstances and that data portability is only relevant from May 2018):
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The right to be informed about your processing of my personal data;
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The right to have my personal data corrected if it’s inaccurate and to
have incomplete personal data completed;
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The right to object to processing of my personal data;
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The right to restrict processing of my personal data;
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The right to have my personal data erased (the “right to be forgotten”);
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The right to request access to my personal data and information about
how you process it;
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The right to move, copy or transfer my personal data (“data
portability”); and
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Rights in relation to automated decision making including profiling.
I have the right to complain to the Information Commissioner’s Office. It has
enforcement powers and can investigate compliance with data protection
law: ico.org.uk.
2: Data Protection Statement (continued)