This privacy notice applies to customers and prospective customers who are
referred to us by a third party introducer.
- Who we are
We are Streamline Car Finance Limited (known as Streamline Car Finance ), a
company registered in England & Wales (company number 14504140) whose
registered office is at Trinity House, 114 Northenden Road, Sale, Manchester, M33
3HD.
We are a data controller for the purposes of the Data Protection Act 2018 and related
data protection legislation. Our registration number at the Information Commissioner’s
Office is ZB542583. - How to contact us
If you have any questions about this fair processing notice or our data protection
policies generally, please contact us: By post: Trinity House, 114 Northenden Road,
Sale, Manchester, M33 3HD.
By email: info@streamlinecarfinance.co.uk By phone: 0161 968 3434 - Privacy notice
3.1. We are committed to protecting your personal data and your privacy. This fair
processing notice sets out the basis on which personal data we collect from you, or that
you provide to us, or that we acquire from a third party, will be processed by us. Please
read the following carefully to understand our practices regarding your personal data
and how we will treat it.
3.2. Before we process your personal data, we are obliged to inform you of who we are,
why we need to process your personal data, what we will do with your personal data
and to whom we will pass your personal data.
3.3. It is important that you read this fair processing notice together with our website and
communications privacy notice and any other privacy notice or fair processing notice we
may provide on specific occasions when we are collecting or processing personal data
about you so that you are fully aware of how and why we are using your data. This
privacy notice supplements the other notices and is not intended to override them.
3.4. It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship with us.
3.5. This version of our fair processing notice was last updated on 9th December 2021.
- Who does this fair processing notice apply to?
This fair processing notice applies where you are an individual (acting solely or jointly
with another person for your own account) who is applying for or entering into a
financing arrangement directly with us or who is giving a guarantee or other security
either solely or jointly with another person. - What personal data do we collect and process
5.1.Data provided to us by third parties
We initially receive personal data relating to you from the party that introduced you as a
prospective customer to us. Before we provide financing or any other services to you,
we undertake credit and identity checks using external credit reference agencies
(CRAs) and fraud prevention agencies (FPAs), and we receive further personal data
relating to you in response to such checks. This will include information from your credit
application and about your financial situation and financial history. CRAs will supply to
us public (including the electoral register) information as well as shared credit, financial
situation and financial history information and fraud prevention information.
5.2.The personal data that we receive from third parties may include:
● Your name
● your date of birth
● your residential address and address history
● your contact details such as email address and telephone numbers
● your employment details
● your credit application
● your financial information, financial situation and financial history (including any
shared credit or financial information
● your credit information and credit history (including previous applications and
conduct of accounts in your name, in the name of a financial associate or the
conduct of any business accounts)
● information verifying your identity
● fraud prevention information
● public information (such as court judgments, bankruptcies and electoral register
information)
5.3. Data that you give us or that we collect from you
You provide personal data to us when you enter into a contract with us. We may collect
personal data when you correspond with us by telephone, e-mail or otherwise and we
will collect personal data during the lifetime of a contract between us.
5.4. The personal data you provide or we collect from you, may include your:
● personal details (including your name, date of birth, and residential address and
address history)
● contact details such as email address and telephone numbers
● financial information
● credit history
● employment details
● vehicle details
● payment history
- How is your personal data used
We process and use your personal data for the following purposes:
6.1. Assessment of application
6.1.1 Purposes of processing.
On receipt of your application for services or financing, we assess the details of your
application against our criteria for providing such services or financing (which criteria
are set out in the application process) to determine whether your application is eligible.
6.1.2 Lawful basis of processing.
When we process your personal data for the above purpose, we do so on the basis that
this is a necessary step (in response to your application) prior to entering into a contract
with you, even where we decline to proceed with the application if our criteria for such
services or financing are not met.
6.1.3 Consequences of processing.
If the personal data contained within your application for services or financing is
incomplete or inaccurate, we will decline your application.
6.2 Verification of identity and fraud prevention
6.2.1 Purposes of processing.
In order to process your application and before we provide financing or other services to
you, we undertake checks with one or more fraud prevention agencies (FPAs) for the
purposes of preventing fraud and money laundering, and to verify your identity. These
checks require us to process personal data about you.
FPAs will process your personal data in order to provide us with information about you,
which may include verification of identity and fraud prevention information. If you have
requested services and financing from other providers, FPAs may receive your personal
data from those providers too. FPAs may also process your personal data in order to
detect and prevent fraud and money laundering by other people.
6.2.2 Sharing of data.
We will share your personal data with FPAs, which will include information from your
credit application for the above purposes. The personal data you have provided, we
have collected from you or we have received from third parties will be used to prevent
fraud and money laundering, and to verify your identity. We, and fraud prevention
agencies, may permit law enforcement agencies to access and use your personal data
to detect, investigate and prevent crime.
6.2.3 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 financing or other services 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.
6.2.4 Lawful basis of processing.
When we, and fraud prevention agencies, process your personal data for the above
purposes, we do so on the basis that we have a legitimate interest in 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 necessary step (in
response to your application) prior to entering into a contract with you for, and a
contractual requirement of, the financing or other services you have requested.
6.3 Credit checks
6.3.1 Purpose of processing.
In order to process your application and before we provide financing or other services to
you, we perform credit checks on you with one or more credit reference agencies
(CRAs) at the time of your application. We may also make periodic searches at CRAs to
manage your account with us, if we suspect fraud or to check if you have provided
accurate data. These checks require us to process personal data about you.
To do this, we will supply your personal data 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 public (including the
electoral register) information as well as shared credit, financial situation and financial
history information and fraud prevention information. We will use this information to:
● assess your creditworthiness and whether you can afford to take the product;
● verify the accuracy of the data you have provided to us;
● prevent criminal activity, fraud and money laundering;
● manage your account(s) where you enter into a contract with us;
● trace and recover debts where you enter into a contract with us; and
● ensure any offers provided to you are appropriate to your circumstances.
6.3.2 Sharing of data.
We will share your personal data with CRAs, which will include information from your
credit application for the above purposes. We will continue to exchange information
about you with CRAs while you have a relationship with us. We will inform the CRAs
about your settled accounts, as well as advise them of your missing any payment or
otherwise not complying with the contract(s) between you and us. If you borrow and do
not repay in full and on time, CRAs will record the outstanding debt. This information
may be supplied to other organisations by CRAs.
6.3.3 Consequences of processing.
When CRAs receive a search from us they may 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.
We may also, in certain limited circumstances, check the record of other members of
your family and, if you are a partner or director in a small business, also check on your
business.
6.3.4 Lawful basis of processing.
When we process your personal data for the above purposes, we do so on the basis
that such processing is necessary for compliance with our legal obligations as a
regulated financial provider and such processing is a contractual requirement of the
services or financing you have requested.
6.4 Contractual Obligations
6.4.1 Purposes of processing.
We will process your personal data for the purpose of deciding whether to enter into a
contract with you and, where we do enter into a contract with you, for the purposes of
carrying out our obligations under any such contract(s) and if necessary of enforcing
any such contract(s). Such processing will include assessing your application for
services or financing against our criteria for such services or financing and such
processing may include contacting you from time to time by telephone, e-mail or post for
the purpose of administering your account, including informing you of any arrears.
6.4.2 Sharing of data.
In the course of a contract (including enforcement of a contract), we may share your
personal data with our third party service providers or agents who administer parts of
the contract(s) on our behalf. Such third party service providers include banks, software
service providers (including document management and customer relationship
management system providers), loan servicing providers, data storage providers, debt
collection agents, vehicle valuation companies and dispute resolution providers. Any
personal data shared with a third party service provider is strictly limited to the data
required for the third party to provide the relevant services relating to the contract(s)
entered between you and us. We may disclose relevant personal data to any company
which provides maintenance of the vehicle(s) relating to the contract(s) entered
between you and us, as well as any party which negotiates a purchase of such
vehicle(s) from you or us. We may also disclose your personal data to our or your
professional advisors, in particular where this is necessary to enforce any contract(s)
entered into between you and us.
6.4.3 Lawful basis of processing.
When we, or any relevant third party service provider (acting as a processor on our
behalf), processes your personal data for the above purposes, we do so on the basis
that this is necessary for the performance of a contract relating to you. When we share
your personal data with a third party service provider (as a separate controller), we do
so on the basis that this is necessary for our legitimate interests in administering our
business efficiently and cost-effectively and in ensuring that we can provide services to
our customers.
6.5 Administrative Information
6.5.1 Purposes of processing.
We may process your personal data for administrative and internal purposes, such as
risk management and quality control. Such processing may also include customer
satisfaction surveys and other customer review or feedback mechanisms.
6.5.2 Sharing of data.
We may share your personal data with any member of our group, which means our
subsidiaries, our immediate holding company and its subsidiaries, as defined in section
1159 of the UK Companies Act 2006 for any of the following purposes: group-wide risk
management and the management of any part of the group’s business or assets.
We may disclose your personal data to third parties:
● in the event we obtain funding for providing you with the vehicle, we may disclose
your personal data to our funder if required under the terms of the funding
arrangement
● in the event that we sell or buy any business or assets, in which case we may (if
relevant to such business or assets) disclose your personal data to the
prospective seller or buyer of such business or assets; or
● if we or substantially all of our assets are acquired by a third party, in which case
personal data held by us about our customers will be one of the transferred
assets
We may disclose limited personal data to third party service providers for the purposes
of assisting us with customer satisfaction surveys, customer reviews and similar market
research. We normally engage such third party service providers as processors on our
behalf, however please refer to the relevant service provider’s privacy or fair processing
notice for details of how such service provider may use your personal data as a
controller.
6.5.3 We may disclose limited personal data to the party that introduced you to us
(the Introducer).
Please refer to the relevant Introducer’s privacy or fair processing notice for details of
how such an Introducer may use your personal data. Lawful basis of processing. When
we process your personal data for the above purposes, we do so on the basis that we
have a legitimate interest in pursuing business aims and objectives and managing our
credit risk and undertaking market research. We disclose your personal data to the
relevant Introducer on the basis of our legitimate interest in fulfilling contracts, and
maintaining relationships, with Introducers and on the basis of the relevant Introducer’s
legitimate interests in following upon previous contracts and in direct marketing.
6.6 Compliance with legal obligations
6.6.1 Purposes of processing.
We may process (including share with third parties including the Financial Conduct
Authority, HM Revenue & Customs, Courts and tribunals, any other applicable
regulatory authorities) your personal data in order to comply with any legal obligations
binding on us and to protect the rights, property, or safety of our staff, our customers, or
others. We may also process (including share with our legal advisors) your personal
data for the purpose of establishing, exercising or defending our legal rights.
6.6.2 Lawful basis of processing.
When we process your personal data for the above purposes, we do so on the basis
that such processing is necessary for compliance with a legal obligation to which we are
subject (including our reporting obligations to the Financial Conduct Authority and HM
Revenue & Customs, as well as our obligations under applicable legislation including
the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015)
or necessary in order to protect the vital interests of a natural person, or in our
legitimate interests in establishing, exercising or defending our legal rights, respectively.
6.7 Marketing
We will not use your personal data for the purposes of direct marketing. Where we have
provided your personal data to a third party (as a data controller) in accordance with this
fair processing notice, please refer to such third party’s privacy or fair processing notice
for confirmation whether such third party will use your personal data for direct marketing
purposes.
- Failure to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we
have with you and you fail to provide that data when requested, we may not be able to
perform the contract we have or are trying to enter into with you (for example, to provide
you with financing or other services). In this case, we may have to cancel such financing
or service you have with us but we will notify you if this is the case at the time. - Automated decision-making
8.1 As part of the processing of your personal data, decisions may be made by
automated means in connection with credit profiling and fraud or money laundering risk.
This means we may automatically decline the provision of services or financing that you
requested (i) based on your credit profile with CRAs; or (ii) based on information
received from FPAs regarding whether you pose a fraud or money laundering risk.
8.2 You have rights in relation to automated decision-making, including the right to
request a review of the accuracy of a decision that you are unhappy with. If you want to
know more, please contact us using the details above.
8.3 For the consequences of processing, please see paragraphs 6.2.3 and 6.3.3 above. - Your rights
9.1 Your personal data is protected by legal rights, which include your rights:
● 9.1.1 to be informed how your data is processed through notices such as this;
● 9.1.2 to access your personal data;
● 9.1.3 to rectify your personal data if it is inaccurate or incomplete;
● 9.1.4 to erase your personal data where there is no compelling reason for its
continued processing;
● 9.1.5 to restrict processing;
● 9.1.6 to data portability;
● 9.1.7 to object, on grounds relating to your particular situation, to the processing
of your personal data where the processing is based on our legitimate interests;
and
● 9.1.8 in relation to automated decision making and profiling.
9.2 If you want to exercise any of these rights, please contact us using the details
above.
9.3 You also have the right to complain to the Information Commissioner’s Office, which
regulates the processing of personal data, about how we are processing your personal
data
- Data retention
We will retain your information as long as such information is required for us to comply
with our legal obligations or to carry out our obligations arising from, and administer and
enforce, any contracts entered into between you and us and deal with the vehicle which
is the subject of any such contract. We will retain and use your information as
necessary to comply with our legal obligations, resolve disputes, and enforce our
agreements. Unless we are obliged to retain your personal data for a longer period as a
result of an overriding legal obligation (as set out in clause 6.6 above), we will usually
retain your personal data for:
● six years following the date of your application if not proceeding; or
● six years following the expiry of all contracts for services relating to you.
Fraud prevention agencies and credit reference 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.
- Data transfers
We generally do not transfer your personal data out of the UK. However, whenever we
are required to transfer your personal data out of the UK (for example where a
third-party supplier is located outside of the UK), we ensure a similar degree of
protection is afforded to it by ensuring that appropriate safeguards are implemented,
including any of the following:
● we will only transfer your personal data to countries that have been deemed to
provide an adequate level of protection for personal data by the UK Government;
● where we use certain service providers based outside of the UK, we may use
specific contracts approved by the ICO which give personal data the same
protection it has in the UK; or
● you have provided your explicit consent to the transfer of your personal data
outside of the UK .
We do share personal data with fraud prevention agencies and credit reference
agencies who may transfer your personal data outside of the UK. This may be to a
country where the UK Government has decided that your data will be protected to UK
standards, but if the transfer is to another type of country, then the fraud prevention
and/or credit reference agencies will ensure your data continues to be protected by
ensuring appropriate safeguards are in place.
Cifas has published more information about data transfers: CIFAS
The three main credit reference agencies TransUnion, Equifax and Experian (also
called ‘CRAs’) each use and share personal data they receive about you that is part of,
derived from or used in credit activity and this is explained in more detail in the Credit
Reference Agency Information Notice available at any of the following: TransUnion ,
Equifax and Experian