Introduction

 

Where we obtain your personal information

 

Information we hold

 

Information we disclose to third parties and other organisations

 

Granting third party providers access to your online servicing account

 

How we use your personal information

 

How long we retain your personal information for

 

Security

 

Cookies

 

Using companies to process your information outside of the UK

 

Using credit scoring and automated decision making

 

How we check your identity

 

Declined applications

 

Your data subject rights

 

Use of your personal information for marketing and contact purposes

 

Recording phone calls

 

Social networking sites

 

A guide to the use of your personal information by CRAs and FPAs and the NewDay Group

PLEASE READ THIS SECTION VERY CAREFULLY

When you apply to us to open an account, we will:

Any account you and, if you have one, your "financial associate" (as defined in the next paragraph) may have or have had with us.

A "financial associate" is someone with whom you have a personal relationship that creates a joint financial unit in a similar way to a married couple. You will have been living at the same address at the time. It is not intended to include temporary arrangements such as students or rented flat sharers or business relationships.

CRAs may link together the records of people that are part of a financial unit. They may do this when people are known to be linked, such as being married or have jointly applied for credit or have joint accounts. They may also link people together if they, themselves, state that they are financially linked.

Search at FPAs for information on you and any addresses at which you have lived and on your business (if you have one).

What we do with the information you supply to us as part of the application:

Information that is supplied to us will be sent to the CRAs.

If you are making a joint application or tell us that you have a spouse or financial associate, we will:

You must ensure that you have a financial associate's consent and agreement to disclose personal information about them to us

If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to FPAs and other organisations involved in crime and fraud prevention.

Your personal information may also be used by us to offer you other products, but only if you have given your permission as part of any application that you have completed.

With the personal information that we obtain we will:

Assess this application for credit and/or;

Check details on applications for credit and credit related or other facilities;

Verify your identity and the identity of your spouse, partner or other directors/partners (if any) and/or;

Undertake checks for the prevention and detection of crime, fraud and/or money laundering.

We may use scoring methods to assess this application and to verify your identity.

Any or all of these processes may be automated for more information please see section "Using credit scoring and automated decision making".

What we do when you have an account:

Where you borrow or may borrow from us, we will give details of your personal and/or business account (if you have one), including names and parties to the account and how you manage it/them to CRAs.

If you borrow and do not repay in full and on time, we will tell CRAs.

We may make periodic searches of our own group records and at CRAs to manage your account with us, including whether to make credit available, increase the amount of credit available or to continue or extend existing credit. We may also check at FPAs to prevent or detect fraud.

What credit reference and FPAs do

When CRAs receive a search from us they will:

Place a search “footprint” on your credit file whether or not this application proceeds. If the search was for a credit application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future.

Link together the records of you and anyone that you have advised is your financial associate including previous and subsequent names of parties to the account. Links between financial associates will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs.

Financial associates may "break the link" between themselves if their circumstances change such that they are no longer a financial unit. Financial associates should apply for their credit file from a CRA and file for a "disassociation".

CRAs and FPAs will supply to us:

Credit information such as previous applications and the conduct of the accounts in your name and of your associate(s) (if there is a link between you) and/or your business accounts (if you have one).

Public information such as County Court Judgments (CCJs) and bankruptcies.

Electoral Register information.

Fraud prevention information.

When personal information is supplied by us, to CRAs and FPAs in relation to your account(s):

CRAs will record the details that are supplied on your personal and/or business account (if you have one) including any previous and subsequent names that have been used by the account holders and how you/they manage it/them.

If you borrow and do not repay in full and on time, CRAs will record the outstanding debt.

Records shared with CRAs remain on file for 6 years after they are closed, whether settled by you or defaulted.

How your personal information will NOT be used by CRAs: -

It will not be used to create a blacklist.

It will not be used by the CRA to make a decision.

How your personal information WILL be used by CRAs:

The information which we and other organisations provide to the CRAs about you, your financial associates and your business (if you have one) may be supplied by CRAs to other organisations and used by them to:

  1. Prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities
  2. Check the operation of credit and credit-related accounts.

iii. Verify your identity if you or your financial associate applies for other facilities.

  1. Make decisions on credit and credit related services about you, your partner, other members of your household or your business.
  2. Manage your personal, your partner’s and/or business (if you have one) credit or credit related account or other facilities.
  3. Trace your whereabouts and recover debts that you owe.

vii. Undertake statistical analysis and system testing.

How your personal information may be used by FPAs:

  1. The information which we provide to the FPAs about you, your financial associates and your business (if you have one) may be supplied by FPAs to other organisations and used by them and us to prevent crime, fraud and money laundering by, for example;
  2. checking details provided on applications for credit and credit related or other facilities.
  3. Managing credit and credit related accounts or facilities.
  4. Cross checking details provided on proposals and claims for all types of insurance.
  5. Checking details on applications for jobs or when checked as part of employment.
  6. Verify your identity if you or your financial associate applies for other facilities including all types of insurance proposals and claims.

iii. Trace your whereabouts and recover debts that you owe.

  1. Conduct other checks to prevent or detect fraud.
  2. We and other organisations may access and use from other countries the information recorded by FPAs.
  3. Undertake statistical analysis and system testing.

Your personal information may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

Your personal information may also be used to offer you other products, but only where permitted.

 

How to find out more

You can contact the CRAs currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.

Please contact us at Customer Services Team on 0333 220 2692 if you want to receive details of the relevant FPAs.

 

Questions and answers

Q: What is a CRA?

A: CRAs collect and maintain information on consumers’ and businesses’ credit behaviour, on behalf of organisations in the UK.

Q: What is a FPA?

A: FPAs collect, maintain and share, information on known and suspected fraudulent activity. Some CRAs also act as FPAs.

Q: Why do you use CRAs and FPAs when I have applied to your organisation?

A: Although you have applied to NewDay and we will check our own records, we will also contact CRAs to get information on your credit behaviour with other organisations. This will help us make the best possible assessment of your overall situation before we make a decision.

Q: Where do CRAs and FPAs get the information?

A: Publicly available information:

Q: How will I know if my personal information is to be sent to a CRA or FPA?

A: You will be told when you apply for an account if your application personal information is to be supplied. The next section of this leaflet will tell you how, when and why we will search at CRAs and FPAs and what we will do with the information we obtain from them. We will also tell you if we plan to send payment history information on you or your business, if you have one, to CRAs. You can ask at any time the name of CRAs and FPAs.

Q: Why is my personal information used in this way?

A: We and other organisations want to make the best possible decisions we can, in order to make sure that you, or your business, will be able to repay us. Some organisations may also use the information to check your identity. In this way we can ensure that we all make responsible decisions. At the same time we also want to make decisions quickly and easily and, by using up to date information, provided electronically, we are able to make the most reliable and fair decisions possible.

Q: Who controls what CRAs are allowed to do with my personal information?

All organisations that collect and process personal information are regulated by the Data Protection Act 1998, and compliance with the Data Protection Act 1998 is overseen by the UK Information Commissioner’s Office. All CRAs are in regular dialogue with the Information Commissioner's Office. Use of the Electoral Register is controlled under the Representation of the People Act 2000.

Q: Can just anyone look at my personal information held at CRAs?

A: No, access to your information is very strictly controlled and only those that are entitled to do so, may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement.