Blue Motor Finance Limited Customer Privacy Notice

Introduction

We are Blue Motor Finance Limited (BLUE), and we have prepared this Fair Processing Notice (FPN) to explain how we use any personal data we collect about you. We are a data controller of the data we collect about our customers, and this FPN describes how we use your information. Our contact details are:

This FPN applies to our customers, people who have applied to us for finance, and people connected to our customers whose data we collect as part of our interactions with customers. If you are a partner, supplier, or another third party, please see our Third Party Privacy Notice.

What information do we collect?

When you apply to us for a loan, you provide us with information so that we may decide whether to lend to you. We may not be able to lend to you if you do not provide this information. The information that you provide to us includes your:

  • name
  • address
  • email address
  • phone numbers
  • bank details
  • employment information
  • gender
  • household information (including marital status and number of dependents)
  • financial information (including income and the details of your loan application)

When you apply for a loan, we may also collect information about you from third parties, including Credit Reference Agencies (CRAs). The information that we receive from CRAs contains details of your financial history and other people with whom you are financially linked (such as your spouse or partner), including but not limited to:

  • credit score
  • sanctions, politically exposed persons, or special interest person status
  • current and previous addresses
  • credit history, including:
    • current credit commitments
    • historic credit commitments ending in the last six years
    • credit payment history
  • electoral roll details
  • details of credit searches undertaken by other organisations
  • information from fraud databases

If you refuse to provide us with your information, we may be unable to lend to you.

What legal basis do we have for using your information?

As the data controller, we are legally responsible for ensuring that we have a legal basis for processing your information. The UK GDPR sets out several legal bases for processing personal data, and we rely on the following of those bases:

  • Contract:
    • We rely on contract as our lawful basis for taking the necessary steps so that we can enter a contract with you (e.g. to provide a quote)
    • We rely on contract as our lawful basis for delivering our contractual obligations to you (e.g. to collect finance payments)
  • Legitimate Interests:
    • We rely on legitimate interests where we have a legitimate interest in performing the processing (e.g. where we record our phone calls with you for training purposes)
    • Where we rely on legitimate interests, we perform assessments to ensure that we consider the impacts of our processing on you and balance our interests against yours
  • Legal Obligation:
    • We rely on legal obligation where we have an identifiable legal obligation to process your information (e.g. to maintain records of loans we have made)
  • Consent:
    • We rely on consent as our lawful basis for direct electronic marketing.
    • We will only market to you where you have given us your consent to do so, and you may withdraw your consent at any time by contacting our Customer Services team at:

For what purposes will we use your information?

We may use your information to:

  • Assess your loan application
  • Conduct credit checks on you to inform our decision on whether we are willing to lend to you
  • Decide whether to lend to you
  • If we decide that we will not lend to you, to identify alternative lenders and ask them whether they are willing to lend to you
  • Enter a credit agreement with you
  • Operate and manage your account and any agreements
  • Recover any debt that you owe us
  • Contact you via email, SMS, letter, or telephone regarding your account
  • Contact you via email, SMS, letter, or telephone with marketing information where we have a legal basis for doing so
  • Comply with our legal and regulatory obligations, including in respect of fraud and money laundering
  • Assess whether you are or may be vulnerable or are in circumstances which may make you vulnerable, and whether we need to make special considerations based on that vulnerability
  • Conduct market research and business analysis
  • Perform internal audits and other administrative or operational tasks such as systems tests
  • Trace your location if necessary for debt recovery or collections.

How will we use your information?

We may process your information in various ways, using automated and manual systems.

We use automated decision making as part of our process to determine whether we will lend to you and on what terms. We will compare your profile against our qualification criteria using automated means. If you do not meet our criteria, we may refuse to lend to you on the sole basis of our automated decision making systems.

With whom will we share your information?

Partner Finance Companies

We may share your information with Partner Finance Companies (PFCs) where we have decided not to lend to you. If we share your information with PFCs, we will be acting as a broker, and we will normally continue to act as a data controller in respect of your information. However, if in our capacity as a broker we act as a data processor, we will provide a link(s) below to the relevant data controller’s privacy notice.

Specialist Motor Finance Limited Privacy Notice: https://www.smfmotor.com/privacy-notice/

Credit Reference Agencies

We may share your information with Credit Reference Agencies (CRAs) for the purpose of gathering information about you to inform our decision to lend to you. If we search your record at a CRA, the CRA will add to your record the details of our search and the details of your loan application. We may also share your information with CRAs on an ongoing basis, including details of settled accounts or debts not fully repaid on time. This information will be available to other organisations that search your CRA record. Other organisations may use this information and other information about you to make credit decisions about you and the people with whom you are linked financially (such as a spouse or partner).

If you propose a joint agreement or we enter an agreement with you involving joint parties, this information will be recorded with CRAs. This will create an association between your record and your joint party’s record, which we or other organisations may consider in future decisions. This association will remain in place until you file a disassociation with the CRA.

For more information on CRAs, including their relationship with Fraud Prevention Agencies, please refer to the Credit Reference Agency Information Notices below.

Fraud Prevention Agencies

We may share your information with Fraud Prevention Agencies (FPAs) to detect and prevent fraud. FPAs will share their records with other organisations. Those organisations may use this information to make decisions about you and other persons connected to you, including in relation to employment, credit, or insurance.

For more information on FPAs, please refer to the Fair Processing Notices below.

CIFAS Fair Processing Notice: https://www.cifas.org.uk/fpn

Legal, Governmental, and Regulatory Bodies

We may share your information with legal, governmental, and regulatory bodies to meet our legal and regulatory obligations. These may include the Financial Conduct Authority, the Financial Ombudsman Service, the Information Commissioner’s Office, or any other legal, governmental, or regulatory body.

Service Providers

We may share your information with professional advisers (including legal advisers), outsourcing providers (such as IT service providers), financial institutions (such as banks), or with any other type of organisation or person that we use to help us conduct our business.

Authorised Third Parties

We may share your information with any person that you have authorised to engage with us on your behalf or that otherwise has a legal authorisation to do so. This includes parents/guardians, carers, or any other helpers where you are unable to handle your own affairs due to mental incapacity or other similar issues.

We may share your information with any organisation you have appointed to act on your behalf or authorised to receive your information, such as law firms and claims management companies.

Other

We may share your information 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 information as set out in this FPN.

Where will we transfer your information?

We may transfer your information outside the United Kingdom. If we transfer your information outside the United Kingdom to a country that is not subject to an adequacy decision in respect of its data protection laws, we will conduct a transfer risk assessment and put in place the necessary safeguards to ensure that your information receives an equivalent level of protection. For more information on international data transfers, including details of safeguards, please contact our Data Protection Officer at dpo@bluemotorfinance.co.uk.

How long will we keep your information?

If you apply for finance but we do not lend to you, we will keep your information for 3 years from the end of your relationship with us. We do this for several reasons, including to provide information to regulators on our lending practices. If you do not have a contract with us, your relationship with us will normally end when we refuse your loan application. However, we may extend the relationship beyond the date we refused your loan application, e.g. if there is an ongoing dispute or complaint. If we extend the relationship, we will end it as soon as we determine it is possible to do so, e.g. when the dispute or complaint is settled.

If you enter a loan agreement with us, we will keep your information for 7 years from the end of your relationship with us. We do this for several reasons, but primarily to maintain records according to our legal and regulatory obligations. If you have a contract with us, your relationship with us will normally end when your contract ends. However, we may extend the relationship beyond the end of the contract, e.g. if there is an ongoing dispute or complaint. If we extend the relationship, we will end it as soon as we determine it is possible to do so, e.g. when the dispute or complaint is settled.

What rights do you have with regard to your information?

You may have the following rights in regard to your information:

  • The right to be informed about the collection and use of your information, as set out in this FPN
  • The right of access to a copy of your information
  • The right to rectify incorrect or incomplete information
  • The right to the erasure of your information, which will not apply in some circumstances, including if we are under a legal obligation to retain your information
  • The right to restrict processing of your information (subject to limitations)
  • The right to data portability (subject to limitations and not including paper files)
  • The absolute right to object to the processing of your information for direct marketing, and a limited right to object in some circumstances, including to the processing of your information on the basis of legitimate interests
  • The right to withdraw consent, where we are relying on your consent
  • Rights in relation to automated decision making and profiling.

If you wish to exercise your right of access to a copy of your information, please contact us at our dedicated email address dsars@bluemotorfinance.co.uk.

If you have questions regarding your rights or wish to exercise a right other than the right of access, please contact our Data Protection Officer at dpo@bluemotorfinance.co.uk.

How can you complain about our processing of your information?

If you are dissatisfied with our processing of your information, please first contact our Data Protection Officer. Our Data Protection Officer may be able to resolve your complaint or address your concerns. Our Data Protection Officer can be contacted at: dpo@bluemotorfinance.co.uk.

You have the right to complain to the Information Commissioner’s Office about our processing of your information. You can contact the Information Commissioner’s Office using the following details.

Web: https://ico.org.uk/make-a-complaint/

Telephone: 0303 123 1113