"We", "our" or "us" means Close Brothers Group Plc of 10 Crown Place, London EC2A 4FT and its subsidiaries, affiliates and their respective parent and subsidiary companies (“Close Brothers Group”). For the purposes of data protection law, we are a data controller in respect of your personal data. We collect and use your personal data and where applicable this may include information related to your spouse/partner, directors, partners and owners (your “representatives”). Close Brothers is responsible for ensuring that it uses your personal data in compliance with data protection law.
This notice applies to any personal data we receive from you, create or obtain from other sources and explains how it will be used by us. It is important that you take the time to read this notice so that you understand how we will use your personal data and your rights in relation to your personal data.
Personal data that we collect about you
We will collect and use the following personal data about you and your representatives:
Information you give us
- This is information about you and your representatives that you give us by filling in forms or by corresponding with us by telephone, e-mail or otherwise. The information you give us may include your and your representatives’ name, address, e-mail address and telephone number, financial and credit card information, employment history, health information, credit history, identification records and qualifications.
- You must ensure that in respect of any information you provide us with, which does not relate to you (for example, information about your representatives), you have the necessary permissions in order to disclose such information and have provided them with a copy of this notice.
Information we collect or generate about you and your representatives
- Website usage information – our website uses Google Analytics to automatically gather certain statistical information such as the number and frequency of visitors and their IP addresses. This information is used as aggregated statistical information about users, providing usage by IP address. This information helps us to measure how individuals use the website and our services, so that we can continually improve them.
- We sometimes record telephone conversations to resolve complaints, improve our service and for security, training and quality assurance purposes.
- We generate data for statistical analysis.
Information we receive from other sources
- Financial/credit information – we will use information provided by credit reference agencies when assessing any product application and to verify your or, if applicable, your representative's identity. Such information may include some details about other credit you have taken out, any credit arrangements you have met or failed to meet, and any court judgments made against you.
- Fraud prevention agencies – when verifying your identity as part of our application process, we may access information recorded by fraud prevention agencies within and outside the UK. This may include information about any criminal convictions and any allegations regarding criminal activity that relate to you.
- Intermediaries – where applicable, we will receive information from dealers, brokers and introducers including your personal details, contact details and relevant asset or policy details for the purposes of entering in to and administering your agreement.
- Social media profile – where you have clicked through to one of our promotions or event notices posted on a third-party social media website such as LinkedIn, we will receive your contact information provided as part of your user profile such as your name, e-mail address and telephone number and any other relevant business information such as your organisation’s name, address and your industry. Some of this information may be pre-populated based on your social media profile; other parts may be completed by you, as and when requested.
- Public databases – we may obtain information about individuals from public databases. We use reputable sources including, but not limited to, the electoral register and Companies House. We employ appropriate measures to assure the quality of information we collect.
How we use your personal data
Your personal data may be used by us in the following ways:
Credit scoring and crime prevention
- To verify your identity as part of the account opening process for new customers.
- For making credit checks on you. We may carry out searches with credit reference agencies who will keep a record of our enquiry against your name and which may be linked to your representatives (“associated records”). For the purposes of any application for products or services from us, you may be assessed with reference to “associated records”. Where any search or application is completed or agreement entered into involving joint parties, we may record details at credit reference agencies, as a result an “association” will be created that will link your financial records. Details of which credit reference agencies we have used are available on request. We may also add to your or, if applicable, your business’, record with the credit reference agencies' details of your agreement with us, any payments you make under it and any default or failure to keep to its terms. These records will remain on the credit reference agencies’ files for six years after our agreement with you is settled or terminated, whether settled by you or, if applicable, your business or by way of default. These credit reference agencies may create, or add to, their own record about you, or, if applicable, your business, details of our search and your application. This and other information about you or, if applicable, your business and those with whom you are linked financially, may be used to make credit decisions about you or your business.
- You can find further information about how credit reference agencies (TransUnion, Equifax and Experian) may process your personal data at www.experian.co.uk/crain or you can contact us to obtain a paper copy of this information.
- We may use credit scoring techniques and automated decision making systems to either fully or partially assess your information. These credit scoring techniques and automated decision making systems may take into account any previous applications for finance, defaults or existing debt. The results of this decision may decide whether we provide you with our services or not. If you disagree with the results of an automated decision, you can request a review of your application.
- To allow us to detect and prevent fraudulent activity including sharing personal data with fraud prevention agencies.
- To allow us to detect and prevent money laundering activity or terrorist financing.
- Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you. The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.
- Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address. We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
- We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested. Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.
- If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
- A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, you can contact us in accordance with the “Contact us” section below.
Products and Services
- To provide you with information, products or services that you may request from us.
- To carry out our obligations arising from any agreements you enter into with us.
- To make payments.
- To recover monies.
- Where we are permitted to do so, to send promotional information about our products and services via methods such as e-mail, post, telephone, etc.
- To contact you via post, e-mail or telephone in relation to the administration of your account or to carry out quality control research.
As part of our legal and regulatory obligations, to conduct statistical analysis in order to improve our credit risk profile, tackle fraud, and improve our credit decisions. This may include statistical analysis on your personal data even if your application is declined by us or you decide not to complete your application with us.
In order to identify and offer you tailored products and services that are suitable for you and to improve our products and services.
Legal basis for processing your personal data
We process your personal data pursuant to the following legal bases:
- Consent, for example to share your personal data with third party affiliates who may wish to offer you products and services which may be of interest to you.
- Taking steps (at your request) prior to entering into an agreement with you, and subsequently for the administration and performance of our agreement with you.
- To comply with our legal and regulatory obligations.
- To establish, exercise or defend our legal rights and / or for the purpose of (or in connection with) legal proceedings.
- The use of your personal data as described is necessary for our legitimate business interests which are:
- enforcing the terms and conditions of any agreement we have with you;
- the recovery of outstanding debts existing under an agreement with you;
- for statistical analysis to improve our products and services; or
- to contact you about products and services that may be of interest to you.
You may object to this at any time by contacting us using the contact details below.
Sharing your personal data
We may disclose your personal data within the Close Brothers Group and to third party service providers in the circumstances described below:
- To ensure the delivery or maintenance of products or services you have taken out with us.
- To ensure the safety and security of our data.
- As part of our internal research and statistical analysis activity.
We will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this notice.
We may also share your personal data outside of the Close Brothers Group:
- Your advisors, with whom you have given authority to share your personal data, such as lawyers, professional advisors or individuals with power of attorney.
- To third parties to include on a register of financed assets (for the purposes of preventing fraud).
- To an insurer or insurers for administration.
- To claims handlers and fraud prevention agencies.
- To any guarantor.
- To any funder in order to enable funders to assess the value of our assets.
- To any broker or introducer of an agreement with us.
- To tracing and repossession agents.
- If we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes.
- If we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third-party buyer.
- To third party agents or contractors (for example, the providers of our electronic data storage services or call centres) for the purposes of providing services to us.
- With your consent, to third party affiliates who may wish to offer you products and services which may be of interest to you.
These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice.
We may also share your personal data outside of the Close Brothers Group to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation including but not limited to disclosures made to:
- Credit agencies
- Companies House
- Government agencies, such as HMRC
- Regulatory authorities
and to establish, exercise or defend our legal rights.
Transfer of personal data outside the European Economic Area
The information you provide to us will be transferred to and stored on our secure servers in the European Economic Area (“EEA”) or in the UK. However, from time to time, your personal data may be transferred to, stored in, or accessed from a destination outside the EEA and/or in the UK. It may also be processed by staff operating outside of the EEA and/or in the UK who work for a company in the Close Brothers Group or for one of our suppliers.
Where we transfer your personal data outside the EEA and/or in the UK, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA and/or in the UK.
This can be done in a number of ways, for instance:
- the country that we send the data to might be approved by the European Commission or a relevant data protection authority; or
- the recipient might have signed up to a contract based on “standard contractual clauses” approved by the European Commission or a relevant data protection authority, obliging them to protect your personal data.
- In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA and/or in the UK. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA and/or in the UK (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contact us” section below.
How long we keep your personal data
The length of time we hold your personal data for will vary. The retention period will be determined by various criteria including:
- The purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose.
- Legal obligations – laws or regulation may set a minimum period for which we have to store your personal data.
If you are a customer we will usually retain your personal data for seven years (excluding call recordings) following the end of our relationship with you, unless we are required by law to keep it for a longer period of time (in which case, we will keep it until the expiry of the period required by law).
You have a number of rights in relation to the personal data that we hold about you. These rights include:
- The right to object to our processing of your personal data where we process your personal data pursuant to our legitimate business interests. Please note that there may be circumstances where you object to our processing of your personal data but we may be legally entitled to refuse that request.
The right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you.
The right to withdraw your consent to our processing of your personal data at any time.
In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us.
The right to request that we rectify your personal data if it is inaccurate or incomplete.
The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it.
The right to request that we restrict our processing of your personal data in certain circumstances. Please note that there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request.
The right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request.
The right to object to the processing of your personal data for direct marketing purposes.
The right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
You can exercise your rights by contacting us using the details set out in the “Contact us” section below.
You can find out more information about your rights by contacting the data protection regulator, the Information Commissioner, or by searching their website at https://ico.org.uk.
Changes to our privacy notice
We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy notice.
We are registered in the UK and our registered address is 10 Crown Place, London, EC2A 4FT. Our company registration number is 195626. You can contact us using the following link: Contact us
If you have any questions about this notice, about how we process personal data or about your rights over your personal data, our Data Protection Office can be contacted at email@example.com or DPO, Close Brothers, 10 Crown Place, London EC2A 4FT.