Blue Motor Finance – Fair Processing Notice

How we use your information

Credit searches

We may use a credit scoring or other automated decision making system to assess your application.

In considering whether to enter into this Agreement, Blue Motor Finance Limited (“we”, “us”) will search your record at credit reference agencies (“CRAs”). They will add, to their record about you, details of our search and your application and this will be seen by other organisations that make searches. This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and those with whom you are financially linked. They will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, verify your identity, manage your account, trace and recover debts and prevent criminal activity such as fraud and money laundering – these checks require us to process personal data about you.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations.

These records may be used and searched by us and them to:

  • consider applications for credit and credit related services, such as insurance, for you and any associated person; and
  • trace debtors, recover debts, prevent or detect money laundering and fraud, and to manage your account(s).

It is important that you provide us with accurate information. We check your details with fraud prevention agencies and if you provide false or inaccurate information or we suspect fraud, this information may be recorded.

Fraud prevention agency records will be shared with other organisations to help make decisions on credit, motor, household, life and other insurance proposals or claims for you and members of your household.

  • If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
  • Law enforcement agencies may access and use this information.
  • We and other organisations may also access and use this information to prevent fraud and money laundering, for example when:
    • Checking details on applications for credit and credit related or other facilities;
    • Managing credit and credit related accounts or facilities;
    • Recovering debt;
    • Checking details on proposals and claims for all types of insurance; and
    • Checking details of job applicants and employees.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

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 in the Credit Reference Agency Information Notice (CRAIN). The Notice can be accessed at any of the following:

Associated persons

Before entering into this Agreement we may search records at CRAs, which may be linked to your spouse/partner, or other persons with whom you are linked financially. For the purposes of any application or this Agreement you may be treated as financially linked and you will be assessed with reference to “associated records”.

Where any search or application is completed or Agreement entered into involving joint parties, you both consent to us recording details at CRAs. As a result an ‘association’ will be created which will link your financial records and your associate’s information may be taken into account when a future search is made by us or another lender unless you file a “disassociation” at the CRA.

Personal data

We will use the following personal information about you in connection with any application you make to us, or any Agreement you enter into with us. This includes:

  • your name, address, phone numbers, email address, date of birth, employment, banking and financial details;
  • demographic and lifestyle information;
  • information we receive when making a decision about you, your loan or application (including information collected from the CRAs);
  • details of the loans you have and have had with us and all transactions;
  • details of when you contact us and when we contact you;
  • if you change your bank and your old bank informs us of your new bank account details, we will hold the new bank account details, and use them to operate your account; and
  • any other information which we reasonably need to operate your account, make credit decisions about you or fulfil our regulatory obligations.

It is important that you provide us with accurate personal information as we will process the personal data with which you provide us in order to provide the following services to you:

  • assess your application, including searches against credit reference agencies (“CRAs”) and fraud prevention agencies’ records (including information from overseas);
  • make, or assist in making, credit decisions about you, assess lending and insurance risks, and to check the details that you have let us and others have;
  • operate and manage your account and manage any application, agreement (including this Agreement) or correspondence you may have with us;
  • carry out, monitor and analyse our business;
  • contact you via email, SMS, letter or telephone regarding this Agreement, including to service your account;
  • contact you by email, SMS, letter or telephone for marketing purposes, where you permit us to do so;
  • to identify, prevent, detect or tackle fraud, money laundering, terrorism and other crimes;
  • to form a view of you as an individual and to identify, develop or improve products, that may be of interest to you;
  • carry out market research, business and statistical analysis;
  • provide information to independent external bodies such as governmental departments and agencies, universities and similar to carry out research;
  • carry out internal audits;
  • perform other administrative and operational purposes including the testing of systems;
  • trace your whereabouts;
  • recover any debt you owe us; and
  • comply with our regulatory obligations.

If you do not provide this information we may not be able to provide credit to you.

We may also use your personal information for credit scoring or other automated decision making systems. We match our data with data from other sources such as credit reference agencies and information we may already hold about you - we may validate and analyse your information and, in some cases, match it against third party data to ensure that the information we hold about you is as accurate, consistent and well-organised as possible. Credit scoring is a system which is used to assess your application and make decisions about your account. It calculates your likelihood of repaying the amount you intend to borrow, this will influence the rate which we may offer you or result in our not offering you a credit facility. We regularly review the formulas we use in our automated systems to ensure that they remain accurate. We also use this analysis for personalising and improving aspects of our services and research such as analysing market trends and customer demographics. A low credit score may result in us not being able to provide credit to you.

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 services or financing 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. If you have any questions about this, please contact us as detailed below.

Information we share

We may share information about you:

  • with any firm, organisation or person we use to help us operate our lending business, to collect payments and recover debts or to provide other services on our behalf, including third party service providers;
  • if you have authorised us to do so, with any person who has told us and who we reasonably believe to be your parent, carer or helper where you are unable to handle your own affairs because of mental capacity or other similar issues;
  • with any payment system we may use;
  • where you have permitted us to do so, to other finance providers for the purposes of your application for a loan, in order for them to assess whether they can provide a loan to you;
  • certain authorities in order to detect and prevent terrorism (including to authorities outside the UK);
  • with any person to whom we sell or transfer (or enter into negotiations to sell or transfer) our business or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the transferee or purchaser may use your personal information in the same way as us;
  • with regulatory and governmental authorities ombudsmen, or other authorities, including tax authorities, including those overseas, where we are requested by them to do so;
  • with CRAs and fraud prevention agencies or any similar organisation which provides a centralised application matching service that collects information from and about mortgage and/or credit applications, for the purpose of preventing and detecting fraud. We may also provide information to third parties to help them to make decisions about whether to lend to you, allow you extended payment terms or otherwise do business with you; and
  • if we transfer, charge or assign your Agreement to a third party or if we employ a third party to manage any aspect of your account, we will pass relevant information about you (including personal data) to them for that purpose.

We use your personal data on the following legal basis, depending on the purpose of our processing:

  • to enable us to perform the contract between you and us, under this Agreement;
  • your consent (for example, in respect of marketing);
  • otherwise in our legitimate interests which include running our business, crime prevention, information and system security, industry regulation, development of products and services and communicating with our customers; or
  • to comply with a legal obligation.

Where the processing of your personal data by us is based on your consent, you may withdraw your consent at any time, by writing to us or emailing us as detailed below.

If you withdraw your consent, this will not affect the lawfulness of any processing which has taken place before you have withdrawn your consent.

Retention of data

We will hold your data on our systems as follows:

  • If you have taken out a loan - 5 years from the date on which your agreement is settled or our last interaction with you
  • If you have had a loan declined or decided not to proceed with it - 3 years from the date on which you applied for finance

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 you have opted into marketing then we will hold your contact details (email address, telephone number, name and address) for marketing purposes for up to 36 months from the time you last interacted with us. You may opt out of this at any time by updating your details through My Account or by clicking unsubscribe from any marketing communication you have received from us.

Your rights

If you want to have details of the CRAs or any other agencies from whom we obtain, and to whom we pass, information about you including fraud prevention agencies, please contact us as detailed below. You have a legal right to these details. You have a right to receive a copy of the information we hold about you. You may at any time request access to and/or, if incorrect, the rectification of your personal data by writing to us or e-mailing us as detailed below.

Under the GDPR, or any equivalent rules in the UK, you may be entitled to additional rights in relation to our handling of your personal data. For example, the right to have your personal data erased, the right to object to or restrict us from processing your personal data, and the right to data portability. If you would like to exercise these rights once they come into force, please write to us or email us as detailed below.

Should you have any complaints about how we handle your personal information, please contact us as detailed below. Should we be unable to resolve your complaint and you wish to take your complaint further, you may do so by contacting the UK Information Commissioner’s Office.

We, the CRAs and the fraud prevention agencies will also use the information provided for statistical analysis about credit, insurance and fraud. We may also use information about you to carry out market research. We and any company associated with and/or approved by us may disclose and use any information about you to advise you by post, telephone, e-mail or other electronic media, about loan and other products and services provided by it or any third party which may be of interest to you, unless you notify us that you do not wish to be so advised.

Transfer of Information

We may transfer your personal information abroad to other countries outside the UK. If we do so, we will ensure the information is held securely to standards as least as good as those in the UK and only used for the purposes set out in this notice.

We may also transfer your personal data to a location outside of the European Economic Area (EEA). If we do so, we shall undertake an assessment and put in place adequate safeguards, in accordance with applicable data protection laws, to ensure third party recipient will provide adequate security of such personal data and respect your rights to privacy. For further information on the adequate safeguards used by us, please contact us as detailed below.

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they 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.

Contacting the Data Protection Officer

You can contact the Data Protection Officer by email to dpo@bluemotorfinance.co.uk or by post to:

Blue Motor Finance Limited
PO Box 565
Sevenoaks
TN13 9RE

Updated February 2020