1 What is the purpose of this document?
1.1 This privacy notice describes how
collects and uses personal
information about you in accordance with the applicable data protection legislation.
recognises the importance of this data and the risks related to its possession
of such data.
is committed to protecting the privacy and security of your personal
is a "data controller". This means that we are responsible for deciding how we
hold and use personal information about you. To comply with data protection legislation
and best practice we are required to notify you of the information contained in
this privacy notice.
1.4 This notice sets out your rights under applicable data protection laws as well
as our commitment to you regarding how we treat your data. We may update this notice
at any time.
1.5 It is important that you read this notice, together with any other privacy
notice we may provide on specific occasions when we are collecting or processing
personal information about you, so that you are aware of how and why we are using
We have appointed a Head of Data Protection to oversee compliance with this privacy
policy who acts as data protection officer for
If you have any questions about this privacy notice or how we handle your personal
information, please contact our Data Protection Officer, contact details of whom are
set out below. You have the right to make a complaint at any time to your local
regulator for data protection and privacy issues.
Data Protection Officer
Telephone: +44 113 490 0204
3 Data protection principles
We will comply with applicable data protection law.
has committed to applying the
highest standards, which means that the personal information we hold about you must be:
3.1 Used lawfully, fairly and in a transparent way.
3.2 Collected only for valid purposes that we have clearly explained to you and not
used in any way that is incompatible with those purposes.
3.3 Relevant to the purposes we have told you about and limited only to those purposes.
3.4 Accurate and kept up to date.
3.5 Kept only as long as necessary for the purposes we have told you about.
3.6 Kept securely.
4 The kind of information we hold about you
4.1 Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
4.2 There are "special categories" of more sensitive personal data which require a
higher level of protection (as detailed in paragraph 10).
4.3 We may collect, store, and use the following categories of personal information
4.3.1 Full Name.
4.3.2 Date of Birth.
4.3.3 Place of Birth.
4.3.4 Passport information, including number, date of issuance and expiry.
4.3.5 Email Address.
4.3.6 Phone Number.
4.3.7 Full residential Address.
5 How is your personal information collected?
5.1 We collect personal information about you through your completion of
the application form.
6 How we will use information about you?
6.1 We will only use your personal information when the law allows us to.
Most commonly, we will use your personal information in the following circumstances:
6.1.1 Where we need to perform the contract we have entered into with you.
6.1.2 Where we need to comply with a legal obligation.
6.1.3 Where it is necessary for our legitimate interests (or those of a third party)
and your interests and fundamental rights do not override those interests.
6.1.4 When verifying the information supplied for the purposes of the application.
6.1.5 When completing and submitting the application.
6.2 We may also use your personal information in the following situations, which
are likely to be rare:
6.2.1 Where we need to protect your interests (or someone else's interests).
6.2.2 Where it is needed in the public interest.
7 Situations in which we will use your personal information
7.1 We need all the categories of information in the list above (see paragraph 4)
primarily to allow us to perform our contract with you and to enable us to comply
with legal obligations. In some cases, we may use your personal information to
pursue legitimate interests of our own or those of third parties, provided your
interests and fundamental rights do not override those interests.
7.2 Some of the above grounds for processing will overlap and there may be several
grounds which justify our use of your personal information.
7.3 The situations in which we will process your personal information are listed
in Schedule 1, together with the purpose or purposes for which we are processing
or will process your personal information.
8 If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able
to perform the contract we have entered into with you (such as processing a
transaction on your behalf of), or we may be prevented from complying with our
legal obligations (such as to ensure you are properly identified for the progress
of anti-money laundering legislation).
9 Change of purpose
9.1 We will only use your personal information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose. If we need to
use your personal information for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
9.2 Please note that we may process your personal information without your
knowledge or consent, in compliance with the above rules, where this is required or
permitted by law.
10 How we use sensitive personal information?
10.1 "Special categories" sensitive personal information require higher levels
of protection. We need to have further justification for collecting, storing and
using this type of personal information. We may process special categories of
personal information in the following circumstances:
10.1.1 With your explicit written consent for the purposes of carrying out our
contract with you as part of the application process
10.1.2 Where we need to carry out our legal obligations.
10.2 Less commonly, we may process this type of information where it is needed
in relation to legal claims or where it is needed to protect your interests
(or someone else's interests) and you are not capable of giving your consent, or
where you have already made the information public. We may also process such
information about you in the course of legitimate business activities with the
11 Do we need your consent?
We do not need your consent if we use your personal information in accordance
to carry out our legal obligations or exercise specific rights under the law.
In limited circumstances, we may approach you for your written consent to allow
us to process certain particularly sensitive data. If we do so, we will provide
you with full details of the information that we would like and the reason we
need it, so that you can carefully consider whether you wish to consent. You
should be aware that it is not a condition of your contract with us that you
agree to any request for consent from us.
12 Automated decision-making
12.1 Automated decision-making takes place when an electronic system uses
personal information to make a decision without human intervention. We are
allowed to use automated decision-making in the following circumstances:
12.1.1 Where we have notified you of the decision and given you 21 days to
request a reconsideration.
12.1.2 Where it is necessary to perform the contract with you and appropriate
measures are in place to safeguard your rights.
12.1.3 In limited circumstances, with your explicit written consent and where
appropriate measures are in place to safeguard your rights.
12.2 If we make an automated decision on the basis of any particularly sensitive
personal information, we must have either your explicit written consent or it
must be justified in the public interest, and we must also put in place appropriate
measures to safeguard your rights.
12.3 You will not be subject to decisions that will have a significant impact
on you based solely on automated decision-making, unless we have a lawful
basis for doing so and we have notified you.
12.4 We do not envisage that any decisions will be taken about you using automated
means, however we will notify you in writing if this position changes.
13 Data sharing
13.1 We may have to share your data with third parties, including third-party
13.2 We require third parties to respect the security of your data and to treat
it in accordance with the law.
13.3 We may transfer your personal information outside the EU.
13.4 If we do, you can expect an equivalent degree of protection in respect of
your personal information.
13.5 Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law,
where it is necessary to administer the working relationship with you or where we
have another legitimate interest in doing so. This may involve us sharing your
13.5.1 Third party service providers who help us operate our business;
13.5.2 Credit card companies and direct debit operators; and
13.5.3 The United States Government.
If the make-up of the changes or such changes are proposed we may share your data
with third parties to allow us to sell, merge or transfer aspects of our business
or acquire or merge into other businesses. We will only do this if they agree to
keep your data to the same standards we have set for holding your data. Following
such a change other parties may use your data in line with these standards.
13.6 Which third-party service providers process my personal information?
"Third parties" includes third-party service providers (including contractors and
designated agents). The following activities are carried out by third-party service
a) credit card companies and direct debit operators process the payment information
you have provided us with; and
b) the United States Government processes the personal information you provide us
with in relation to the application, in order to determine whether your application
should be approved.
13.7 How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security
measures to protect your personal information in line with our policies. We do not
allow our third-party service providers to use your personal data for their own
purposes. We only permit them to process your personal data for specified purposes
and in accordance with our instructions.
13.8 Transferring information outside the EU
We will transfer the personal information we collect about you to the following
countries outside the EU:
13.8.1 United States.
in order to perform our contract with you. There is not an adequacy decision by
the European Commission in respect of all of those countries. This means that
some countries to which we transfer your data are not deemed to provide an
adequate level of protection for your personal information.
However, to ensure that your personal information does receive an adequate level
of protection we have put in place binding contract clauses in line with
international standards to ensure that your personal information is treated by
those third parties in a way that is consistent with and which respects the
applicable laws on data protection. If you require further information about these
protective measures, you can request it from the Head of Data Protection.
14 Data security
14.1 We have put in place measures to protect the security of your information.
Details of these measures are available upon request.
14.2 Third parties will only process your personal information on our instructions
and where they have agreed to treat the information confidentially and to keep it
14.3 We have put in place appropriate security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorised way,
altered or disclosed. In addition, we limit access to your personal information to
those employees, agents, contractors and other third parties who have a business
need to know. They will only process your personal information on our instructions
and they are subject to a duty of confidentiality. Details of these measures may
be obtained from Head of Data Protection.
14.4 We have put in place procedures to deal with any suspected data security
breach and will notify you and any applicable regulator of a suspected breach
where we are legally required to do so.
15 Data retention
15.1 We will only retain your personal information for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of satisfying
any legal, accounting, or reporting requirements. Retention periods for your
personal information are decided by considering the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use
or disclosure of your personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other means, and the applicable
legal requirements. In general terms for application information verification and
applications we will retain your information indefinitely or for as long as the
application and verification process requires.
15.2 In some circumstances we may anonymise your personal information so that it can
no longer be associated with you, in which case we may use such information without
further notice to you.
15.3 If you have any questions regarding data retention, please contact our Data
We may use your personal information to let you know about those of our products
and services we think may be of interest to you. Before doing so we may use your
personal information to better understand what services or products you are likely
to need or have use for.
If you ask us to stop using your personal information to market to you, we will
do so, and you can change this choice at any time.
We use "cookies" on our website, these are small pieces of data that allow us
to track which computers visit our website and how. To find out how, please
18 Rights of access, correction, erasure, and restriction
18.1 Your duty to inform us of changes
It is important that the personal information we hold about you is
accurate and current. Please keep us informed if your personal information
changes during your relationship with us.
18.2 Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
18.2.1 Request access to your personal information (commonly known as
a "data subject access request"). This enables you to receive a copy of the personal
information we hold about you and to check that we are lawfully processing it.
18.2.2 Request correction of the personal information that we hold about
you. This enables you to have any incomplete or inaccurate information we hold about
18.2.3 Request erasure of your personal information. This enables you
to ask us to delete or remove personal information where there is no good reason
for us continuing to process it. You also have the right to ask us to delete or
remove your personal information where you have exercised your right to object
to processing (see below).
18.2.4 Object to processing of your personal information where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground. You also have the right to object where we are
processing your personal information for direct marketing purposes.
18.2.5 Request the restriction of processing of your personal information.
This enables you to ask us to suspend the processing of personal information about
you, for example if you want us to establish its accuracy or the reason for processing
18.2.6 Request the transfer of your personal information to another party.
18.3 If you want to review, verify, correct or request erasure of your personal
information, object to the processing of your personal data, or request that we
transfer a copy of your personal information to another party, please contact the
Head of Data Protection in writing.
18.4 No fee usually required
You will not have to pay a fee to access your personal information (or to exercise
any of the other rights). However, we may charge a reasonable fee if your request
for access is clearly unfounded or excessive. Alternatively, we may refuse to comply
with the request in such circumstances.
18.5 What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information (or to exercise any of
your other rights). This is another appropriate security measure to ensure that
personal information is not disclosed to any person who has no right to receive it.
19 Right to withdraw consent
In the limited circumstances where you may have provided your consent to the
collection, processing and transfer of your personal information for a specific
purpose, you have the right to withdraw your consent for that specific processing
at any time. To withdraw your consent, please contact our Data Officer. Once we
have received notification that you have withdrawn your consent, we will no longer
process your information for the purpose or purposes you originally agreed to,
unless we have another legitimate basis for doing so in law.
20 Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide
you with a new privacy notice when we make any substantial updates. We may also
notify you in other ways from time to time about the processing of your personal
How uses your data?