Fair Processing Notice
USE OF YOUR INFORMATION
Bluestone Leasing Ltd (hereinafter referred to as Bluestone Leasing, we or us) is a UK registered company who provides UK organisations with credit broking services, in both the public and private sectors, with a range of specialist financial services centred around asset leasing, supporting thousands of partners and customers ranging from sole traders, partnerships, small SMEs to large, global corporates. We have direct servicing support to a number of specific partner channels, Technology, Interiors, Vehicles, Health & Fitness and General Assets. In addition, we also have a direct business to customer relationship, specifically with those customers who were originally introduced via a business partner. We do not otherwise trade directly with end business users.
Bluestone Leasing is authorised and regulated by the Financial Conduct Authority and registered with the Information Commissioner’s Office under number Z6897676.
This notice explains what personal data we collect from you and how it will be used by us and why.
WHAT WE WILL DO WHEN YOU APPLY
Before we provide services, goods or credit broking to you, we will need to collect certain details from you for the purpose of entering into an agreement with you for providing goods (for example, a sale agreement), services (for example, a rental agreement), or credit broking; administering any agreement with you; and in order to undertake checks for the purposes of preventing money laundering or to verify your identity; and if you access our website we collect information about your browsing experience, for the purposes of understanding and improving our website, customer experience and our products and services.
WHAT WE SHARE AND PROCESS
We will collect and process the following personal data about you:
Information you give us when purchasing or making an application for finance (Submitted Information): The information you give us comprises your name, date of birth, residential address and address history for the last five years, contact details such as email address and telephone numbers, financial information and employment details or company information. Financial and employment details may include, but not be limited to, your business accounts, bank statements, your salary, P60, wage slips, employer’s name, address and time you have worked there. Additionally, you may be required to provide further information for your application as proof of identification. These may include, but are not limited to, passport, driving licence and utility bills.
Information we receive about you from third parties (Third Party Information): This information may include your personal and financial information, your employer, companies that you are connected with (such as a Director) or other persons connected with your finance application; information about the asset you are purchasing or finance you require; credit information, such as previous applications, the conduct of accounts in your and your financial associate’s name (this is anyone linked to you for credit or finance purposes), any business accounts you have and public information such as County Court Judgments, bankruptcies and the Electoral Register.
We may combine Submitted Information with Third Party Information and may use both these categories of information and the combined information for the purposes set out below.
HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU
Account processing and administration
Sale or Supply Agreement Administration: which will mean verifying identity; customer services; to investigate and respond to a complaint; complying with legal, regulatory and compliance obligations that apply to us (for example, anti-money laundering and counter terrorism checks) and detection and prevention of fraud and other crimes; account management; call monitoring;
General Administration: which will mean tax administration; auditing; reporting and accounting functions; statistical analysis and market research; market, regulatory and operational risk management; systems testing; network monitoring.
Marketing Activities: which may mean conducting customer service surveys and offering goods and services such as alternative products; profiling of your data for marketing purposes; contacting you to offer you other products and services; analysis of our customer database to understand our customer’s activities and preferences, and to improve our services to you.
Commercial Activities: which will mean assigning our rights or obligations to a third party; obtaining funding for our business, and to understand and improve our products and services, (and when we use your data for each of these purposes we do so on the basis that we have a legitimate interest in doing so).
When you phone us or we phone you: call recording and customer identification
We will also use your personal data to check your identity if you get in touch with us.
We may monitor, and record calls made to us for monitoring and training purposes and to improve the services we offer.
We use your information in this way in our legitimate interest, to improve the services, we provide to you.
Verifying your identity and preventing fraud and money laundering
We will use certain personal data you have provided to us in order to confirm your identity and to prevent money laundering. More details about these checks are set out below.
Legal Basis for Processing Data: When we use your personal data for these purposes we do so on the basis that we have a legitimate interest in assessing your application, 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 you have requested, and we will not be able to process your application without undertaking these checks. However, we may also process your data when it will be in your vital interests for us to do so, when it is in the public’s interest for us to do so, or when we are compelled to do so by law.
As part of your original finance application, the lender will collect its own data in order to assess your application. However, should your application with one of our selected lenders be unsuccessful we may pass your application details to another finance company to help fulfil your lending requirement.
That company will obtain their own credit reference and fraud prevention searches. We may from time to time add & remove lenders from our panel and we will always let you know if we pass your data to a lender not on our usual panel.
We, as the introducing broker, will have access to your information up to the point that your finance agreement is executed with the finance company, to facilitate your application for finance. However, we may also gain access to your information after the execution of any finance agreement to assist in a regulatory or servicing requirement, such as complaints handling and settlement values for any finance agreement arranged through us for you.
CREDIT SEARCH FACILITY
If you decide to proceed with an application with us, we will use your information to obtain credit and identity checks on you with one or more credit reference agencies ("CRAs").
To do this, we or the financiers to whom we send your application (together "we") will supply your personal information 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 both public (including the electoral register) and 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 data you have provided to us;
- Prevent 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 while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you 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.
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.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at any of these three links: www.callcredit.co.uk/crain; www.equifax.co.uk/crain; www.experian.co.uk/crain
DATA RETENTION AND STORAGE
All personal data you provide to us, or which we obtain from third parties, will be stored on our secure servers (or those of third parties or contractors we engage to help us run our business). All these servers are located within the UK and we will never transfer your data outside of the UK without first obtaining your express consent.
We will keep information no longer than we need to for the purpose for which we collected it. The period for which we keep personal data depends on our various legal and regulatory requirements, the purpose for which the information was obtained, and our business needs. If you require further information regarding our data retention procedures, please contact our Data Protection Officer: firstname.lastname@example.org
We will keep information about any account you hold with us for at least a period of 6 years from the end of any Agreement, in line with our data retention policy that stipulates the timescales in line with our lawful purpose for processing your data. For applications which do not result in an Agreement we normally retain information for a period of 12 months.
WHO WE SHARE YOUR DATA WITH
To enable us to provide our products & services to you, we may share your personal data with other companies in our group or to other third parties acting on our behalf, such as finance companies to whom we apply for finance on your behalf. This may be necessary for administrative processing purposes or for the operation and maintenance of your business with us. These include but are not limited to our service, system, support and outsourcing providers; retailers/dealers and manufacturers of goods relating to your agreement; regulatory bodies, and law enforcement agencies.
A full list of the firms we share your data with can be made available upon request. We may also share your personal data with any person (and their or our professional advisors for this purpose) with whom we are negotiating any sale, transfer or re-organisation of our business or where we are organising our commercial funding. If this proceeds, the acquiring party or part of it may use your personal details in the same ways and for the same purposes as set out in this policy. We will give you their details once any business change has been completed.
We may also share your data with any other third party when so doing is in your vital interests, in the public’s interest or when we are compelled to do so by law.
YOUR RIGHT TO OBJECT
You have a right to object to our processing your information on grounds relating to your particular situation.
You also have the right, at any time, to stop us from contacting you or processing your information for marketing purposes.
YOUR OTHER RIGHTS
You have the following additional rights (subject to certain statutory exemptions):
- to opt-out of receiving marketing information, or withdraw your consent to receive marketing information if provided on a previous occasion;
- to be informed about the processing of your personal data (this is what this statement sets out to do);
- to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
- to withdraw any consent you may have given to processing your personal data;
- to restrict processing of your personal data;
- to request access to the personal data that we hold on you and information about how we process it to specify which credit reference agencies we have shared your personal data with
If you are unhappy about how your personal data has been used, you can contact us using the details above. You also have a right to complain to the Information Commissioner’s Office (ICO), which regulates the processing of personal data.
You can refer your concerns to the ICO by:
- Phone - 0303 123 1113
- Writing to them - Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
- Going to their website – www.ico.org.uk
If you would like more information about how we process personal data or are unable to access of any of the links or further information referred to in this document; or would like to exercise any of your data protection rights; then please contact us using the contact details set out in this notice.
Bluestone Leasing Ltd are authorised and regulated by the Information Commissioners Office (ICO) and the Financial Conduct Authority (FCA). Our ICO Registration number is Z6897676. Our FCA Register number is FRN663701. We are a credit broker rather than a lender and offer credit from a selected panel of lenders. Bluestone Leasing Ltd is registered in England and Wales - Company Registration Number: 02519389. VAT Number 895 2334 95. Registered Address: Bluestone Leasing, Limited, Lakeside House, Navigation Court, Wakefield, WF2 7BJ.