Data Policy

PCF – Data Policy

This page lets you know how we look after your personal information, including what you tell us about yourself, what we learn by having you as a customer, business contact, or other type of individual with whom we have a working relationship, and the specific choices you make and confirm to us about what marketing and other communications you want us to send you.

This notice explains how we do this and lets you know about your privacy rights including how the law protects you.

Last updated May 2018

Introduction

PCF is a commercial and business mortgage and finance broker, is registered with the Information Commissioner’s Office and is the Data Controller of the information you provide. You can contact us for general data protection queries by email to [email protected] or in writing to PCF, 58 Grange Gardens, Pinner, Middlesex HA5 5QF

How the law protects you

As well as our Privacy Policy, your privacy is protected by law. This section explains how it works.

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside PCF only when necessary to do so.

The law says we must have one or more of these reasons to process personal data:

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you.

Your rights

Your personal data is protected by legal rights, which include your rights to:

  • object to our processing of your personal data;
  • request that your personal data is erased or corrected;
  • request access to your personal data.

For more information or to exercise your data protection rights, please contact us using the details above.

You also have the right to complain to the Information Commissioner’s Office (ICO) https://ico.org.uk/concerns/, which regulates the processing of personal data.

How we may use your personal information

We’ll use your personal information under our fair processing policy to manage our relationship with you or your business, develop new ways to provide services to our customers and other business contacts, and to grow our business in an efficient and proper way.

We’ll also use your personal information to manage how we work with other companies that provide services to us and our customers. This will be to:

  • detect, investigate, report, and seek to prevent financial crime;
  • manage risk for us, our customers and any of our partnering businesses;
  • obey laws and regulations that apply to us;
  • respond to complaints and seek to resolve them quickly and efficiently;
  • exercise our rights as set out in business agreements.

When we may use your personal information

We’ll use your personal information for fulfilling contracts and business agreements we have with you and for what we consider to be our legitimate interests or our legal duty. Legitimate reasons when we may use your personal information include maintaining our records and managing our relationship with you, including advising you of new products and services or key events in our industry. For anything else, we will only use your personal information with your consent.

What type of Personal Information we’ll gather

For borrowers, in order for us to be able to find the right product or service for you, we need to collect personal information about you. These will include (but are not limited to) your name, occupation, date of birth, contact details and financial details.

Additionally, we may need to collect sensitive personal data for some products or to comply with legislation. We will only collect and use these types of data if we are specifically required to:

  • Racial or ethnic origin
  • Religious or philosophical beliefs
  • Genetic and bio-metric data
  • Health data including gender
  • Criminal convictions and offences

We will only collect the information we require to progress your case and only collect and process sensitive personal data where it is essential to finding the product or service you have requested. We will not explicitly request your consent to process this information as it is required by us to perform the service we have agreed to. If you do not want us to use and where necessary, share this information, we will be unable to help you.

Where we’ll gather your Personal Information from

The majority of your personal data we collect will come directly from you, from information you enter into our website, details of telephone calls, email correspondence and the completion of application forms or other documents.

Who we’ll share your personal information with

We will share personal information with third parties such as lenders and other, to arrange supply of services and products we have recommended. We may also share personal information with other organisations when required, such as:

  • HM Revenue & Customs, regulators and other authorities
  • Fraud prevention agencies
  • Organisations that introduce you to us
  • Companies you ask us to share your data with
  • Agents we use to help run our accounts and services, for example; collection of payments owed

In addition to the above, should we undergo a major company restructuring, then your data will be used by the new organisation in the same way as set out in this notice.

On occasions we work with MarketMakers, a third party marketing company that will use your data under legitimate interest for the purposes of promoting PCF.  You can view their privacy policy here.

Fraud Prevention Agencies (FPAs)

Before we provide products, services or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, including verifying your identity. To do this, we may share your personal information with FPAs.

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, in order to protect our business and to comply with the law. Such processing is also a contractual requirement of the services and financing you have requested. When appropriate, we and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

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. 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, please contact us on the details above.

Data transfers

Should a fraud prevention agency transfer your personal data outside of the European Economic Area (EEA), they will impose contractual obligations on the recipients of that data 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.

How we’ll keep your personal information secure

All the data we hold on you will be securely stored within the European Economic Area (‘EEA’)

We have strict procedures for how and where we store and share your personal data, that comply with industry practices, for both electronic and paper formats. We store all the information you give us and will use new information to update existing records we hold for you.

Sending data outside of the EEA

We will only send data outside of the European Economic Area (‘EEA’) to comply with a legal duty. We do not transfer information to agents or advisers outside of the EEA, but if we should need to, we will ensure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:

  • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
  • Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,

Marketing

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. A legitimate interest is when we have a business or commercial reason to use your information in a way that is fair and potentially beneficial to you.

You can ask us to stop sending you marketing messages by contacting us at any time. If you change your mind you can update your choices at any time by contacting us.

How long we keep your personal information

We will keep your personal information whilst you are a customer. For borrowers, as a minimum, this will be for the period that you hold a financial product arranged through us. After you stop being a customer, we may keep your data for up to seven years so that we can:

  • Respond to any questions or complaints.
  • Show that we treated you fairly.
  • Maintain records according to rules and legislations that apply to us.

We may keep your data for longer than seven years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and the data only used for those purposes.

How to get a copy of your personal information

You can access your personal information we hold by emailing us at [email protected] or in writing to PCF, 58 Grange Gardens, Pinner, Middlesex HA5 5QF

Letting us know if your personal information is incorrect

You have the right to review any information we have about you and to ask us to correct anything that you think is wrong or incomplete. Please contact us as above if you want to do this. We will take reasonable steps to check its accuracy and correct it if it was wrong at the time of processing and to update your contact details if appropriate.

What if you want us to stop using your personal information?

You have the right to object to our use of your personal information or to ask us to delete it if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

Please contact us as above if you wish us to delete your personal information. There may be legal or other official reasons why we are not able to, but we may be able to restrict its use. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. We would not use or share your information in other ways whilst it is restricted.

You can ask us to restrict the use of your personal information if:

  • It is not accurate.
  • It has been used unlawfully but you don’t want us to delete it.
  • It is not relevant any more, but you want us to keep it for use in legal claims.

You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

How to withdraw your consent

You can withdraw your consent for us to use your personal data at any time. Please contact us if you want to do so. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

How to complain

Please let us know if you are unhappy with how we have used your personal information. You can contact us by phone on 07880 588930, via email to [email protected] or write to us directly at PCF, 58 Grange Gardens, Pinner, Middlesex HA5 5QF

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

Future formats for sharing data

The Data Privacy laws will change on 25 May 2018. From that date you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.

We continue to work within our industry to improve the way your data is shared. We’ll update this notice if required with more details.

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