Why we collect and process your personal data
We collect and process an individual’s personal data for the purposes of giving interest-free loans and for marketing purposes.
Our legal bases for processing personal data is for establishing a loan fund, providing interest-free loans, complying with financial regulation and for our legitimate interests.
- When we provide loan services under Consumer Credit Law for the fulfillment of a contractual obligation our legal basis for processing personal data in respect of that service is Contract.
- When we receive donations, assess applications and monitor loan repayments and when we report to and comply with financial regulators our legal basis for processing personal data is Legal Obligation.
- Otherwise, our legal basis is legitimate interests.
We process our donors’ or our borrowers’ personal data for marketing purposes with their consent or to meet a legitimate interest. This means we can tell you about our new services, initiatives, products and events that may be relevant to you. If you do not want us to process your personal data for marketing purposes, please let us know and we will stop.
The data we may collect and process
The personal data of donors, borrowers, and guarantors that we may collect and process includes:
- Your name, contact details, marital status, number of dependents, home-owner or renting any personal identifiers (such as date of birth)
- Your employment details, monthly income, and expenditure and guarantor details
- Your bank account details, details of credit history, CCJs, Bankruptcy
- Details of the amount to be borrowed and the reason for the loan, investments, savings
- Information relevant to the assessment of your loan application or guarantor status
How we hold and share your personal data
We process your personal data in strict confidence. We keep your personal data securely in our filing and electronic systems. Patient records are only accessible to the trustees and employees and those under their supervision.
We will usually keep any personal data we hold about you for 6 years after our last contact with you before we delete it. This is the period recommended as good accountancy practice. In exceptional cases, we may need to retain personal data for a longer period and will explain our reasons for doing so on request.
In the course of processing your personal data we may share it with:
- Credit reference agencies to obtain a credit rating or pass on relevant information if you default on a loan
- Legal professionals, courts or debt collection agencies in case of default on a loan
- The Financial Conduct Authority for Consumer Credit, AML and terrorist financing reporting
You have legal rights in respect of the personal data we hold about you. The Information Commissioner’s Office (ICO) has published guidance on the full range of rights. The rights that are most relevant to the way in which we use your personal data include:
- The right to be informed about how we use personal data – this privacy notice gives that information
- The right to object – if you object to us processing your data for marketing purposes or where our legal basis is legitimate interests (see ‘why we collect and process your personal data’, above), we will then stop doing so, unless we are processing the data in respect of a legal claim or can otherwise show that our legitimate interest in processing the data overrides your rights and interests
- The right of access – if you ask us for the personal data we hold about you we will provide it within a month, free of charge (unless we have already provided it to you, in which case we may have to charge you the administrative cost of providing it again)
- The right to rectification – if you ask us to correct personal data about you that is inaccurate or incomplete, we will do so within a month (unless we need longer, in which case we will discuss this with you)
- The right to erasure – also known as the ‘right to be forgotten’. If you ask us to delete your personal data, we will do so if there is no compelling reason to continue processing the data. We will not usually delete data before our usual time limit (see ‘how we hold and share your personal data’ above) where we have a duty to keep accurate records – for example, to comply with a legal obligation, or in connection with a legal claim. If you ask us to delete such data we will discuss this with you
Contacting us and the ICO about your personal data
Please speak to us first if you have any questions or concerns about the way in which we process personal data. You can contact the office on 0161 850 6161 or via firstname.lastname@example.org
You have the right to complain to the ICO if you have a concern about our handling of your personal data which you do not think we can resolve. You can contact the ICO here.