Privacy Policy
Introduction
At Verdun Group we take privacy seriously and we are committed to protecting it. This policy explains when and why we collect personal information about individuals, how this information is used, the conditions under which it may be disclosed to others and how it is kept secure. The policy also explains when and how we disclose information to others about an applicant for a loan or a borrower. Whenever dealing with us in respect of a loan application and any subsequent loan facility agreement, the controller of your personal information will be the company that is dealing with the application and (if applicable) that agrees to make the loan A ‘controller’ is an organisation that decides why and how an individual’s personal information is processed. Where this Privacy Policy refers to ‘we’, ‘our’ or ‘us’, unless it says otherwise, it is referring to the company that is the controller of your personal information. Corporate entities must be aware, we may collect personal information about a director or a beneficial owner of the corporate entity or about any person who is to provide us with a guarantee or other security, or who does provide us with a guarantee or other security. Each reference in this policy to ‘you’ is a reference to the individual whose personal information we collect, whether directly from you as the individual, or from our customer (if not you), or from a broker or solicitor, or from third parties such as employers, other lenders or credit reference agencies. Information we collect about you We collect information about you at various stages during our relationship with you or the corporate customer of which you are a director or beneficial owner, including when you or our corporate customer make an application to us, when we enter into an agreement with you/our corporate customer, during the course of providing our services to you/our corporate customer and on other occasions when you contact us or when we ask for information. Personal information you (or your broker or solicitor) give to us:
The personal information that we collect about you is as follows:
• name
• date of birth
• residential address and address history
• contact details such as email address and telephone numbers
• financial information, including bank statements, account details, and details of your assets
• employment details
• information contained in identification documents, including passport, driving licence and household bills
• information you or your broker give to any surveyor or other person acting for us
• information provided by you when filling in a form on our website
• details contained in a loan application and any supporting information
• details contained in a guarantor information sheet
• details of any account you have with us
• your marketing preferences
Personal information we receive from other sources: We may obtain certain personal information about you from other sources, as follows:
• information we receive following enquiries we make with your current and previous lenders, employers, estate agents, landlords, accountants, bankers and the UK Finance Mortgage Lenders Possession Register;
• information we receive following enquiries we make with credit reference and fraud prevention agencies – please see ‘Use by credit reference and fraud prevention agencies’ below for further information; and
• publicly available information obtained from the Internet and other sources such as The Insolvency Service, HM Land Registry, HM Revenue and Customs, Companies House, The Gazette, the electoral register and other public sources.
If you fail to provide us with any mandatory information that we request from you in the course of considering an application for a loan, we will not be able to proceed with the checks and risk assessment necessary to enter into a loan facility agreement; we will not be able to consider the application further or to propose an offer.
Use of your information
We rely upon the following lawful bases under data protection laws (shown in bold) for the uses which we may make of your information:
• On the basis that it is necessary to assess and process your application or to perform a loan agreement with you, we will use your information to verify your identity, assess the application, complete our underwriting, and, if we enter into a loan agreement with you, to provide the service under that agreement (i.e. making the loan(s), managing the account, communicating with you, providing updates on the status of the account, dealing with any complaints and notifying you of any changes to this Privacy Policy) and to trace your whereabouts to contact you and recover debt.
• On the basis that it is necessary for the purposes of legitimate interests pursued by us or a third party, we will use your information for the following purposes:
• to assess a loan application and any lending risks;
• to obtain and analyse information from credit reference agencies;
• to verify your identity and to detect and prevent fraud and money laundering, in order to protect our business;
• to establish, exercise and defend our legal rights;
• to manage and audit our business operations including statistical analysis and accounting;
• to enhance and personalise your customer experience by analysing patterns and customer behaviours, including contacting you to ask you about your experiences (we may engage a market research company to contact you on our behalf);
• to carry out statistical analysis to help with decisions about credit and account management;
• to recover debt, repossess property, and trace your whereabouts;
• to monitor communications between us to prevent and detect crime, to protect the security of our communications, systems and procedures, and for quality control and training purposes; and
• to take steps to protect your information against loss, damage, theft or unauthorised access.
Person(s) who may provide us with funds for a loan to you or a borrower of which you are a director, beneficial owner, proposed guarantor or provider of other security will receive certain information about you (see ‘Use by third parties’ below) and will rely upon their legitimate interest in carrying out their own assessment of any lending risks in order to protect their business.
Any person who is to provide security for a loan agreement (and their legal advisers) will receive all of the information we have obtained about you, where you are the proposed borrower, for our legitimate interest of ensuring that that person obtains independent legal advice as well as for that person’s legitimate interest in obtaining separate independent legal advice as to the meaning, effect and consequences of providing the proposed security.
• On the basis that it is necessary to comply with a legal obligation, we will use your personal information to verify your identity for the purposes of meeting our anti-money laundering and other legal and regulatory responsibilities whether you are the applicant for a loan or the beneficial owner or a director of a corporate applicant for a loan or a proposed guarantor or provider of other security. This may also include processing special categories of data about you, for example for our compliance with our legal obligations relating to vulnerable people.
• Where you have given your consent to specific processing of your information, for example for direct marketing communications (by us and/ or any third parties referred to in the relevant consent request), you can withdraw your consent at any time by following the unsubscribe instructions in the relevant communication or by contacting us, using the ‘Contacting us’ details below.
If we or a fraud prevention agency determine that you pose a fraud or money laundering risk, we may not lend to you, we will inform a fraud prevention agency of the risk, and the fraud prevention agency will keep a record of the risk, which may result in others refusing to provide services, finance or employment to you.
Use by credit reference and fraud prevention agencies
Where you are applying for a loan, or a corporate entity of which you are a director or beneficial owner is applying for a loan, or you are to provide a guarantee or other security for a loan, we will undertake credit and identity checks on you with one or more credit reference agencies (‘CRAs’). We may carry out further periodic searches for the purpose of managing the account under the proposed loan facility agreement.
To do this, we will supply your personal information to CRAs and they will give us information about you and about any person with whom the CRAs have recorded you as being financially linked. The information the CRAs give us will include information about your financial situation and financial history. CRAs will supply us with public information (including information from the electoral register) and also with shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
• assess your creditworthiness;
• verify the accuracy of the information you have provided to us;
• prevent and detect criminal activity, fraud and money laundering;
• manage your account(s);
• trace and recover debts; and
• ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs at any time when you have a relationship with us as an individual borrower. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders and other businesses or organisations.
The identities of the CRAs, their role as fraud prevention agencies, the information they hold, the ways in which they use and share personal information, information retention periods and your data protection rights with the CRAs are explained in more detail on the CRAs’ websites at TransUnion www.transunion.co.uk; Equifax www.equifax.co.uk; and Experian www.experian.co.uk;