This policy aims to outline how we use your data, how it’s protected, and how long it’s stored.
“We”, “us”, “our” or “Marsh Finance” refers to the firms named below. “you” or “your” refers to the customer or applicant.
Marsh Finance Ltd is authorised and regulated by the Financial Conduct Authority Number 312186 Company Reg. 1138291 (England) | VAT Number 936 538 395 | Information Commissioner Number Z6526626. Crossfield Mill, Crawford St, Rochdale OL16 5RS. Phone: 01706 648882 Email: email@example.com
Marsh Finance & Commercial Ltd is authorised and regulated by the Financial Conduct Authority Number 704239 Company Reg. 03715914 (England) | VAT Number 182 762 879 | Information Commissioner Number Z3209637. Crossfield Mill, Crawford St, Rochdale OL16 5RS. Phone: 01706 648882 Email: firstname.lastname@example.org
Marsh FM LLP is authorised and regulated by the Financial Conduct Authority Number 704276 Company Reg. OC351145 (England) | VAT Number 984 184 874 | Information Commissioner Number Z3209640. Crossfield Mill, Crawford St, Rochdale OL16 5RS. Phone: 01706 648882 Email: email@example.com
How do we collect personal data?
We may collect information in the following ways:
· Information that you provide when you visit www.marshfinance.com, use any of our online services
· Information that you provide to our affiliates, introducers, brokers and partners where you have consented to that information being passed to us.
· Information that you provide when you contact us by email or SMS.
· Information that we collect about you from documents that are available to the public, such as the electoral register, or from third parties such as credit reference agencies and fraud prevention agencies.
· Information you provide if you report a problem with www.marshfinance.com or if you contact us and request assistance using the previously named website.
· Details of your visits to www.marshfinance.com including, but not limited to, location data, web logs and other communication data, whether this is required for our own purpose or otherwise and the resources that you access.
· Information sent to us from third parties which you have given permission to in respect of your application.
We may also receive personal information from third parties, which enables us to contact potential customers, who have expressed interest in our services. Any information/data obtained from third parties is checked for accuracy and we will endeavour to check your information and ensure that permission as given to disclose your details.
Marsh Finance understands how important your privacy is and we have implemented measures which will ensure any personal data that is obtained from you will be processed and maintained in accordance with the Data Protection Act 2018 (DPA 2018) and the General Data Protection Rules (GDPR).
The GDPR requires Marsh Finance and all organisations to maintain records of processing activities and the legal bases for processing such data. Marsh Finance reviews the data that we hold about you at regular intervals.
What types of personal data do we collect?
· Name and titles.
· Physical address and address history.
· Date of Birth.
· Contact information such as telephone numbers and email address.
· Lifestyle and other information
· Online identifiers (such as IP addresses and cookies).
· Financial information such as bank details, income and expenditure, CCJ’s and defaults.
· Criminal convictions
Examples of special category data that we collect
· Data concerning health regarding a disability, illness or impairment.
· Biometric (where used for identification purposes
Legal Basis for Processing
Legitimate interests: We have a legitimate interest in providing and improving our services and personalising your experience of our services. This interest isn’t outweighed by your rights or any negative impacts on you.
Examples of processes where we rely on legitimate interest include:
· Fraud detection and prevention.
· Engaging and contacting you throughout the lifecycle of your Marsh Finance account to ensure you have a good experience as a valued customer.
· Engaging you and contacting you towards the end of your agreement to remind you of our service and to provide a renewal quote.
· Internally auditing our processes to maintain our high standards.
· Market research, statistical analysis, product development, and sharing data with selected third parties to add value to our products and services and those provided by our partners.
· To carry out monitoring and to keep records.
· To protect you from unnecessary risks or harm.
· Help us to design new and innovative protects.
· Protect ourselves, others, and property.
Contract: It is necessary for us to process your personal data to perform a contract to which you are a party, or to take steps at your request prior to you entering into a contract.
Examples of processes where we rely on Contract include:
· Administering and managing your account and associated services, updating your records, tracing your whereabouts to contact you about your account and doing this for the recovery of debt.
· Sharing your personal data with certain third-party service suppliers such as payment service providers or a debt collection agency.
· To exercise our rights set out in agreements and contracts.
Consent: You have consented to us using your personal data for a specific purpose. You can withdraw your consent at any time using the ‘unsubscribe’ link in our electronic communications or by contacting the Marsh Finance Data Protection Officer.
Examples of processes where we rely on Consent include:
· For some of our processing of special categories of personal data such as about your health (and it will be explained to you when we ask for that explicit consent what purposes, sharing and use it is for.)
· For marketing purposes.
Legal Obligations: When processing is necessary in order for Marsh Finance to adhere with legal and regulatory obligations.
Examples of processes where we rely on Legal Obligations include:
· To carry out identity checks, anti-money laundering checks and checks with Fraud. Prevention Agencies pre-application, at the application stage and periodically after that.
· For compliance with laws that apply to us.
· For establishment, defence, and enforcement of our legal rights.
· For activities relating to the prevention, detection and investigation of crime.
· To deal with requests under data protection laws.
· To process information about a crime or offence and proceedings.
What Do We Do with The Information We Gather?
We require this information to understand your needs and provide you with a better service, and for the following reasons:
· For the purposes of approving and the ongoing management and administration of your loan application.
· Internal record keeping.
· We may use the information to improve our products and services.
· We may periodically send marketing promotional material via email about new products, special offers or other information which we think you may find interesting.
From time to time, we may also use your information to contact you for market research purposes, using the contact details (email address, telephone number and address) you have provided.
How We Use Your Information
We use your information in the following ways:
· To contact you from time to time by email, but only with your express consent, about Vehicle Finance.
· To contact you and any person referred to by you in connection with your application or enquiry.
· To process and respond to requests, enquiries and complaints received from you.
· To arrange for the provision of car finance requested by you.
· To update our records.
· For audit purposes.
· To carry out customer satisfaction research.
· To prevent or detect fraud.
· To meet our regulatory compliance and recording obligations.
· To ensure that content from www.marshfinance.com is presented in the most effective manner for you and your computer/device.
· To develop and improve our services for you.
· To monitor our calls for training and compliance purposes.
· To help us adhere to all EU processing requirements.
· To assist us with Auto Decision Making.
· To assess suitability for finance.
· To assess adherence to group policy.
· To prevent anti money laundering.
· To help you receive the right support during the term.
Fraud Prevention Agencies and Credit Referencing
We may use both fraud prevention agencies and credit referencing agencies to help make relevant decisions on any credit application you submit.
Credit Reference Agencies (CRAs)
When this type of check is made a footprint will appear on your credit file which can be seen by other lenders. CRAs provide us with shared credit information, fraud prevention information and public information; this information will include the what is held about you on the electoral register.
Information received by CRA’s will be recorded by them.
If the finance agreement is live, the activity and details of management of your account will be passed onto them. In the event that you take out a finance agreement and fail to repay back the full funds required, this will be recorded with the CRA. In this case information may be passed onto other companies by CRA’s to locate and trace you with a view to recovering any outstanding debts. We must warn you that if this does occur then this will remain on your record for six years once a case has been closed by either settlement or default.
Fraud Prevention Agencies (FPAs)
When we assess your application and it has been approved in principle, we may also check your identity in order to prevent fraud and crime; this includes money laundering. This information will then be used to ascertain whether to offer any future credit that may be available. This is to comply with our regulatory obligations for responsible lending, FPAs and CRAs assist us in fulfilling this.
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. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by going to https://www.marshfinance.com/cifas
Further information on fraud prevention agencies can be obtained by contacting the Marsh Data Protection Officer DPOfficer@marshfinance.co.uk.
You may contact any/all of the credit reference agencies directly. If you choose to contact a Credit Reference Agency, please bear in mind that the information held may not be the same so it may be useful to contact all of them.
For further information on how credit reference agencies use your personal information, please visit: https://www.experian.co.uk/legal/crain/
If you have been refused credit you can get advice from your local Trading Standards Department, Citizens Advice Bureau or Consumer Advice Centre and the agencies’ web sites. The Information Commissioner also produces a useful leaflet entitled ‘Credit Explained’. You can obtain a free copy on the Information Commissioner’s website or by telephoning 0870 600 8100.
Inaccurate Information Provided by You
False information given by yourself maybe brought to the attention of the FPA’s or other relevant companies who deal in fraud/crime prevention. The same applies if we or any party we deal with suspect fraud of false or inaccurate information has been supplied. Any reported instances may also be accessed by law enforcement agencies i.e. HM Revenue and Customs, The Department of Work and Pensions, regulatory bodies or the police, for use to prevent any possible fraud and money laundering for the following:
· Recovering debt.
· Managing credit and credit related accounts or facilities.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Controlling Your Personal Information
We will not distribute your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you have opted into this.
If you believe that any information we are holding on you is incorrect or incomplete, please write to us at Marsh Finance, Crossfield Mill, Crawford Street, Rochdale, Lancashire, OL16 5RS or email us at DPOfficer@marshfinance.co.uk as soon as possible. We will promptly correct any information found to be incorrect.
Do We Share Your Information with Third Parties?
We may share your information with third parties in the following ways:
· We will release your personal information when we are required to do so for legal or regulatory purposes or as part of legal proceedings.
· You confirm you have the consent of any other person whose details are provided by you in connection with your application or enquiry to provide that person’s information to us and for us to use that person’s information for the processing of any application that you may submit as a joint application.
Your information may be passed to credit reference, fraud prevention, law enforcement agencies and identity and address verification agencies. They may record and use your information and disclose it to other organisations for credit reference, debt tracing, fraud and money laundering prevention purposes.
Where We Store Your Information
All information you provide is stored on secure servers which are held within the European Economic Area.
Unfortunately, transmissions of information via the internet are not completely secure. Although we will do our best to protect your information, we cannot guarantee the security of your information transmitted to www.marshfinance.com; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
You have the right to ask us not to contact you for marketing purposes either by unsubscribing from any emails you receive or by contacting us by post at Marsh Finance, Crossfield Mill, Crawford Street, Rochdale, Lancashire, OL16 5RS or by calling us on 01706 648882. Calls to this number are normally charged at a local rate – charges may apply if you call from a mobile telephone.
You also have the right to access the information that we hold on you and request details of the third parties with whom we have shared your information with us contacting us using the details provided in the previous paragraph. We do not charge a fee for this service in accordance with the General Data Protection Regulations (GDPR), unless the request is deemed to be unreasonable by the company. In the event that the request is deemed unreasonable, Marsh Finance will inform you of the intent to charge a fee and outline the reasons for this.
All information relevant to you will be released upon request within 30 Days of your request being received.
You may also correct errors in, or update your information, or request that we remove information about you form our records by sending us a request to the postal address provided above or by emailing our data protection officer Andrew Marsh at DPOfficer@marshfinance.co.uk. In most cases we will comply promptly with your request and let you know when we have done so. However, sometimes we will not be legally obliged to comply with your request. If this is the case, we will inform you of our decision and the reasons for that decision.
To protect your privacy and the security of your information, we are required to take reasonable steps to verify your identity before we act on any request which you may make in respect of your information.
In accordance with the GDPR you have the following rights:
· right to be informed. You have the right to be fully informed regarding your information throughout our whole journey.
· right to rectification. You have the right to request that we correct any inaccurate personal information we hold about you.
· right to data portability. You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.
· right of access. You have the right to request copies of the personal information we hold about you at any time.
· right to restrict processing. You have the right to request that we restrict how we use your personal information.
· right not to be subject to automated decision making and profiling. If a decision has been made electronically by automated means, you have the right to contest this decision.
· right to erasure (right to be forgotten). You have the right to request for all information to be removed. We will suppress and remove all data held, upon request. We will, however, keep the request from you in which you have asked for your information to be removed, so that Marsh Finance meets its compliance obligations under the GDPR. All other information will be removed in accordance with your right.
We would like to draw your specific attention to this final right. If you have any questions about this right or any others, then please contact our Data Protection Officer.
· right to object. You have the right to object to the collection and use of your personal information at any time.
Links to Other Websites
Notification of Breach
Marsh Finance, where necessary, will inform you, the Financial Conduct Authority and the Information Commissioners Office at the first sign of a data breach and will comply with all the reporting and times scales that the regulators have in place.
In compliance with the GDPR, we want to make sure we are being completely transparent with you regarding your data and the security of your data. We will contact you by email, letter or phone to inform you of any suspicious activity.
How Long Do We Keep Your Information For?
In instances where an application does not result in a live credit agreement, we will retain the data for a period of 6 years from the end of the application process. The reason for this is to help us in the event of a complaint being made. After that period the data is deleted from our systems or anonymised in accordance with Data Protection regulations to be used for statistical analysis purposes to improve our systems and product offering.
In instances where an application does result in a live credit agreement, we will retain the data for a period of 6 years from the end of the agreement. The reason for this is to help us in the event of a complaint being made. After that period the data is deleted from our systems or anonymised in accordance with Data Protection regulations to be used for statistical analysis purposes to improve our systems and product offering.
This policy will be reviewed on at least an annual basis.
The use of your personal data will be explained fully in the event of applying for credit. You must accept these terms before proceeding to a credit application form. If you do not accept them, we will unfortunately be unable to proceed with your application.
Complain to the Supervisory Authority
We hope that we will be able to resolve any questions or concerns you have. However, if you have any complaints relating to the processing of your personal data, you also have the right to complain to the relevant Supervisory Authority. In the UK this is the Information Commissioner’s Office (ICO). They can be contacted at:
Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF
Telephone: 0303 123 1113 Website: www.ico.org.uk