Fair processing notice

FAIR PROCESSING NOTICE

This privacy notice applies to customers and prospective customers who are referred to us by a third party introducer.
  1. Who we are
  2. We are Startline Motor Finance Ltd (known as Startline), a company registered in England & Wales (company number 08302453) whose registered office is at 6th Floor, 60 Gracechurch Street, London, EC3V 0HR. Our principal trading office is at Suite 4/5, Skypark 1, 8 Elliot Place, Glasgow, G3 8EP. We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation. Our registration number at the Information Commissioner's Office is ZA006163.
  3. How to contact us
  4. If you have any questions about this fair processing notice or our data protection policies generally, please contact us: By post: Startline Motor Finance Ltd, Suite 4/5, Skypark 1, 8 Elliot Place, Glasgow, G3 8EP By email: enquiries@startlinemotorfinance.com By phone: 02920 853 528
  5. Privacy notice
    1. We are committed to protecting your personal data and your privacy. This fair processing notice sets out the basis on which personal data we collect from you, or that you provide to us, or that we acquire from a third party, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it. 
    2. Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data. 
    3. It is important that you read this fair processing notice together with our website and communications privacy notice (which can be found on our website) and any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
    4. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
    5. This version of our fair processing notice was last updated on 23 May 2018.
  6. Who does this fair processing notice apply to? This fair processing notice applies where you are an individual (acting solely or jointly with another person for your own account) who is applying for or entering into a financing arrangement directly with us or who is giving a guarantee or other security either solely or jointly with another person.
  7. What personal data do we collect and process 
    1. Data provided to us by third parties. We initially receive personal data relating to you from the party that introduced you as a prospective customer to us. Before we provide financing or any other services to you, we undertake credit and identity checks using external credit reference agencies (CRAs) and fraud prevention agencies (FPAs), and we receive further personal data relating to you in response to such checks.This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us public (including the electoral register) information as well as shared credit, financial situation and financial history information and fraud prevention information.
    2. The personal data that we receive from third parties may include:
      1. your name
      2. your date of birth
      3. your residential address and address history
      4. your contact details such as email address and telephone numbers
      5. your financial information
      6. your credit history
      7. your employment details
      8. your credit application
      9. your financial situation and financial history (including any shared credit or financial information)
      10. your credit information and credit history (including previous applications and conduct of accounts in your name, in the name of a financial associate or the conduct of any business accounts)
      11. information verifying your identity
      12. fraud prevention information
      13. public information (such as court judgments, bankruptcies and electoral register information)
    3. Data that you give us or that we collect from you. You provide personal data to us when you enter into a contract with us. We may collect personal data when you correspond with us by telephone, e-mail or otherwise and we will collect personal data during the lifetime of a contract between us.
    4. The personal data you provide or we collect from you, may include your:
      1. personal details (including your name, date of birth, and residential address and address history)
      2. contact details such as email address and telephone numbers
      3. financial information
      4. credit history
      5. employment details
      6. vehicle details
      7. payment history
  8. How is your personal data used We process and use your personal data for the following purposes:
    1. Assessment of application
      1. Purposes of processing. On receipt of your application for services or financing, we assess the details of your application against our criteria for providing such services or financing (which criteria are set out in the application process) to determine whether your application is eligible.
      2. Lawful basis of processing. When we process your personal data for the above purpose, we do so on the basis that this is a necessary step (in response to your application) prior to entering into a contract with you, even where we decline to proceed with the application if our criteria for such services or financing are not met.
      3. Consequences of processing. If the personal data contained within your application for services or financing is incomplete or inaccurate, we will decline your application.
    2. Verification of identity and fraud prevention
      1. Purposes of processing. In order to process your application and before we provide financing or other services to you, we undertake checks with one or more fraud prevention agencies (FPAs) for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
      2. FPAs will process your personal data in order to provide us with information about you, which may include verification of identity and fraud prevention information. If you have requested services and financing from other providers, FPAs may receive your personal data from those providers too. FPAs may also process your personal data in order to detect and prevent fraud and money laundering by other people.
      3. Sharing of data. We will share your personal data with FPAs, which will include information from your credit application for the above purposes. 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.
      4. We, and fraud prevention agencies, may permit law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
      5. Consequences of processing. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the financing or other services you have requested, 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.
      6. Lawful basis of processing. When we, and fraud prevention agencies, process your personal data for the above purposes, we do so 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 necessary step (in response to your application) prior to entering into a contract with you for, and a contractual requirement of, the financing or other services you have requested
    3. Credit checks
      1. Purpose of processing. In order to process your application and before we provide financing or other services to you, we perform credit checks on you with one or more credit reference agencies (CRAs) at the time of your application. We may also make periodic searches at CRAs to manage your account with us, if we suspect fraud or if we spot that you have provided inaccurate data. These checks require us to process To do this, we will supply your personal data to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us public (including the electoral register) information as well as shared credit, financial situation and financial history information and fraud prevention information. We will use this information to:
        1. assess your creditworthiness and whether you can afford to take the product;
        2. verify the accuracy of the data you have provided to us;
        3. prevent criminal activity, fraud and money laundering;
        4. manage your account(s) where you enter into a contract with us;
        5. trace and recover debts where you enter into a contract with us; and
        6. ensure any offers provided to you are appropriate to your circumstances.
      2. Sharing of data. We will share your personal data with CRAs, which will include information from your credit application for the above purposes. We will continue to exchange information about you with CRAs while you have a relationship with us. We will inform the CRAs about your settled accounts, as well as advise them of your missing any payment or otherwise not complying with the contract(s) between you and us. 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. 
      3. Consequences of processing. When CRAs receive a search from us they may place a search footprint on your credit file that may be seen by other lenders.  If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link. We may also, in certain limited circumstances, check the record of other members of your family and, if you are a partner or director in a small business, also check on your business. 
      4. Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with our legal obligations as a regulated financial provider and such processing is a contractual requirement of the services or financing you have requested.
    4. Contractual Obligations
      1. Purposes of processing. We will process your personal data for the purpose of deciding whether to enter in to a contract with you and, where we do enter into a contract with you, for the purposes of carrying out our obligations under any such contract(s) and if necessary of enforcing any such contract(s). Such processing will include assessing your application for services or financing against our criteria for such services or financing and such processing may include contacting you from time to time by telephone, e-mail or post for the purpose of administering your account, including informing you of any arrears.
      2. Sharing of data. In the course of a contract (including enforcement of a contract), we may share your personal data with our third party service providers or agents who administer parts of the contract(s) on our behalf. Such third party service providers include banks, software service providers (including document management and customer relationship management system providers), loan servicing providers, data storage providers, debt collection agents, vehicle valuation companies and dispute resolution providers. Any personal data shared with a third party service provider is strictly limited to the data required for the third party to provide the relevant services relating to the contract(s) entered between you and us. We may disclose relevant personal data to any company which provides maintenance of the vehicle(s) relating to the contract(s) entered between you and us, as well as any party which negotiates a purchase of such vehicle(s) from you or us. We may also disclose your personal data to our or your professional advisors, in particular where this is necessary to enforce any contract(s) entered into between you and us.
      3. Lawful basis of processing. When we, or any relevant third party service provider, processes your personal data for the above purposes, we do so on the basis that this is necessary for the performance of a contract relating to you.
    5. Administrative Information
      1. Sharing of data. We may share your personal data with any member of our group, which means our subsidiaries, our immediate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 for any of the following purposes: group-wide risk management and the management of any part of the group's business or assets.
        We may disclose your personal data to third parties.
        1. in the event we obtain funding for providing you with the vehicle, we may disclose your personal data to our funder;
        2. in the event that we sell or buy any business or assets, in which case we may if relevant disclose your personal data to the prospective seller or buyer of such business or assets; or
        3. if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
      • Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives and managing our credit risk.
    6. Compliance with legal obligations
      1. Purposes of processing. We may process (including share with third parties including the Financial Conduct Authority, HM Revenue & Customs, Courts and tribunals, any other applicable regulatory authorities) your personal data in order to comply with any legal obligations binding on us and to protect the rights, property, or safety of our staff, our customers, or others. We may also process (including share with our legal advisors) your personal data for the purpose of establishing, exercising or defending our legal rights.
      2. Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with a legal obligation to which we are subject (including our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015) or necessary in order to protect the vital interests of a natural person, or in our legitimate interests in establishing, exercising or defending our legal rights, respectively.
  9. Failure to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with financing or other services). In this case, we may have to cancel such financing or service you have with us but we will notify you if this is the case at the time.
  10. Automated decision-making
    1. As part of the processing of your personal data, decisions may be made by automated means in connection with credit profiling and fraud or money laundering risk. This means we may automatically decline the provision of services or financing that you requested (i) based on your credit profile with CRAs; or (ii) if our automatic processing reveals your behaviour to be consistent with that of known fraudsters or money launderers; or (iii) based on information received from FPAs regarding whether you pose a fraud or money laundering risk; or (iv) if you appear to have deliberately hidden your true identity.
    2. You have rights in relation to automated decision-making, including the right to request a review of the accuracy of a decision that you are unhappy with. If you want to know more, please contact us using the details above.
    3. For the consequences of processing, please see paragraphs 6.2.3 and 6.3.3 above.
  11. Your rights
    1. Your personal data is protected by legal rights, which include your rights:
      1. to be informed how your data is processed through notices such as this;
      2. to access your personal data;
      3. to rectify your personal data if it is inaccurate or incomplete;
      4. to erase your personal data where there is no compelling reason for its continued processing;
      5. to restrict processing;
      6. to data portability;
      7. to object, on grounds relating to your particular situation, to the processing of your personal data where the processing is based on our legitimate interests; and
      8. in relation to automated decision making and profiling.
    2. If you want to exercise any of these rights, please contact us using the details above.
    3. You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data
  12. Data retention We will retain your information as long as such information is required for us to comply with our legal obligations or to carry out our obligations arising from, and administer and enforce, any contracts entered into between you and us and deal with the vehicle which is the subject of any such contract. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation (as set out in clause 6.6 above). we will usually retain your personal data for:
    1. Six months following the date of your application if not proceeding; or
    2. Six years following the expiry of all contracts for services relating to you.
    3. Fraud prevention agencies and credit reference 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.
  13. Data transfers We do not transfer personal data outside of the European Economic Area, but we do share personal data with fraud prevention agencies and credit reference agencies who may transfer your personal data outside of the European Economic Area. Whenever fraud prevention agencies or credit reference agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data. Those obligations require the recipient to protect your personal data to the standard required in the European Economic Area.They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
The three main credit reference agencies Callcredit, Equifax and Experian (also called 'CRAs') each use and share personal data they receive about you that is part of, derived from or used in credit activity and this is explained in more detail in the Credit Reference Agency Information Notice available at any of the following: Callcredit, Equifax and Experian.