1. Who is Firth Finance?
Firth Finance is committed to safeguarding the privacy of our customers. We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and Laws. This notice provides you with the necessary information regarding your rights and our obligations and explains how, why and when we process your personal data.
Firth Finance’s registered office is at Unit 3, The Sidings, Antrim Road, Lisburn, BT28 3AJ and we are a company registered in Northern Ireland. The new General Data Protection Regulations (GDPR) seeks to give all of us better protection and control over our personal information. As a business we have to comply with the GDPR which is regulated by the Information Commissioner’s Office (ICO).
We are registered on the Information Commissioner’s Office Register; registration number Z4770532, and act as the data controller when processing your data. If you have any query, please contact the Data Protection Officer using firstname.lastname@example.org or calling 028 9024 1349. We process your Personal Data in accordance with this Privacy Notice.
2. Key Information about us:
Firth Finance, Unit 3, The Sidings, Antrim Road, Lisburn, Co. Antrim, BT28 3AJ
Phone: +44 (0)28 9024 1349
We are authorised and regulated by the Financial Conduct Authority. Firm Reference: 708323
We are a registered data controller with the Information Commissioner’s Office (ICO): Z4770532
3. Information that we collect about you as part of you loan application:
The following information is collected from you as part of your loan application and during the term of any agreement between you and Firth Finance. We may also get information from third parties such as Credit Reference Agencies (CRAs), Fraud Prevention Agencies (FPAs), government agencies where permitted by law, this will include their records of you and other people with whom you are linked financially, from public records e.g. the electoral roll. We may also gather information about you from credit brokers where you have given them information and have consented for it to be passed to us. If you consent to open banking as part of the application process, we will obtain your bank account details electronically from your bank via our service provider Hope Macy Ltd who are regulated by the FCA to provide this service.
a) Basic personal information such as your name, address, national insurance number, date of birth, telephone/mobile number, email address, marital status, next of kin, and employment information.
b) Personal financial information such as credit and borrowing history, proof of income and expenditure. Health details and medical conditions.
c) Where required and permitted by law any information relating to the prevention and detection of financial or other crime.
3.1 Information we collect from our website www.firthfinance.co.uk:
We may collect and process the following data about you:
Information that you provide by filling in a form on our site: www.firthfinance.co.uk (the Website).
b) Email Newsletter
If you choose to join our mailing list, your email address will be stored using a third-party supplier. At any time, you can unsubscribe from our newsletters, either from within the newsletter or by contacting us via email at email@example.com
c) Website Visitor Tracking
We use a tool called Google Analytics. This collects information in an anonymous form, including the number of visitors to the website, where visitors have come to the site from and the pages they visited. We use this information to better understand how visitors find us and how they interact with our website. We use this information to make improvements and adjustments to our website, and to deliver a better user experience.
d) IP Address
We may collect information about your computer, including, where available, your IP address, operating system and browser type. This is collected for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual.
We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the Website and to deliver a better and more personalised service. Some of the cookies we use are essential for the Website to operate.
They enable us:
• To estimate our audience size and usage pattern;
• To store information about your preferences, and so allow us to customise our website according to your individual interests;
• To speed up your searches; and
• To recognise you when you return to our website.
Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the website.
4. What we use your information for:
In order that we operate in a lawful and responsible manner and to provide you with our products/services. Your information will be used:
• To make Credit Decisions about you, members of your household or other people with whom you are linked financially.
• Communicate with you by telephone, email, SMS or post.
• Managing your account, make collections and debt tracing.
• Prevent Fraud and Money Laundering.
• Assessing your financial circumstances, to ensure affordability and suitability of our products.
• Report to CRAs and FPAs.
• Report to our Regulator, the Financial Conduct Authority where we are required to do so.
• To keep in contact with you and carry out our contractual and legal obligations.
• To evaluate our business and improve our services.
• To tell you about our products and services.
• To respond to enquiries or complaints.
• To ensure the accuracy of our records.
5. We may share your information – Fair Processing
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”).
To do this, 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 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);
- 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 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.
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.
Third Parties to which we transfer, charge or assign your agreement or which manage your loan or provide services for us.
We will also share your information with law enforcement agencies or regulatory bodies where we are required to do so by law.
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 below. CRAIN is also accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document: Callcredit; Equifax ; Experian
Our Credit Reference Agency (CRA) contact details:
Consumer Help Service
PO Box 9000
6. What gives us the right (lawful basis) to collect and process your information?
The lawful bases we use to collect and process your information are contractual necessity, legal obligation and legitimate interests.
a) Contractual necessity means that when we enter into a contract with you for our products and services we need to collect and process your information to enable us to fulfil our obligations under that contract.
b) Legal obligation means that we are required by law to collect certain information for example proof of your identity to comply with money laundering regulations.
c) Legitimate interests means that we as a business have valid reasons for collecting, processing and using your information. These include the effective day to day operation of our business, being able to communicate with you, to send you marketing information and to tell you about our products and services, to improve and develop as a business, receive and manage complaints, to ensure we comply and protect our legal rights and responsibilities and to manage risk and protect our business by preventing financial crime.
We and this website complies to the following policies:
• UK Data Protection Act 1998 (DPA)
• EU Data Protection Directive 1995 (DPD)
• EU General Data Protection Regulation 2018 (GDPR)
7. Your rights
The GDPR provides you with the following rights;
Right to be informed – you have a right to know how we collect and process your information which is what this notice seeks to do.
Right of access – you have a right to access the personal information we hold. This is free and we must provide it within 30 days. You can request this by emailing us at firstname.lastname@example.org
Right of rectification – you have a right to have your personal information changed if it is incorrect or incomplete.
Right to erasure – sometimes referred to as the right to be forgotten. This means that you can request your personal information be erased if it is no longer required for the purposes it was initially collected.
Right to restrict processing – you can request us to restrict the processing of your personal information if you believe for example it is no longer accurate, that we don’t need it any longer or that we are not using it in a lawful manner.
Right to data portability – you have the right to request your personal information be provided to you in a portable manner which you can give to other organisations or request us to do so on your behalf.
Right to object – you have the right to object to how we collect and process your personal information. You can do so by emailing email@example.com
You have the right not to be subject to a decision based solely on automated processing, including profiling.
We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
We have taken every step possible to ensure that your information has been handled securely and correctly. However, if you feel that we have made a mistake, or are unhappy and wish to make a complaint please contact us so we can investigate the matter (see the complaints section on our website).
You can also contact the Information Commissioners Office. For more information, visit www.ico.org.uk or call them on: 0303 123 1113.
9. Where we store your information
Your information is stored within the European Economic Area (“EEA”). Should your information be stored or transferred to parties outside of the EEA it will only be done so after we have ensured that there is adequate protection in place to ensure the security of your data. Any such arrangement will be approved by the Compliance Officer of Firth Finance.
10. How long we keep your information
We will keep your personal data for as long as you are a customer. We will keep customer account records for up to six years after your relationship with Firth Finance ends for business, legal and regulatory requirements. Other records are retained for shorter periods, for example call recordings may be retained for six weeks. Retention periods may be changed from time to time based on business and regulatory requirements. We may retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators.
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect from you and online through www.firthfinance.co.uk
12. Use of firthfinance.co.uk (The Website)
Our website may, from time to time, contain links to other websites. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites. Complying with data protection and privacy laws is one of our greatest priorities and we do all we can to protect your personal data.
From time to time we may review this Privacy Notice and make changes. Any changes we may make will be posted on our website. Any questions or comments about this notice can be sent to:
The Compliance Officer
Tel: 028 9024 1349
Email: firstname.lastname@example.org – Please mark “F.A.O. Compliance Officer” in the subject title of your email