Data Protection Fair Processing Notice
Blue Star Business Solutions Limited t/a Bluestar Leasing
We are committed to processing your personal data in accordance with EU data protection laws. This Data Protection Notice aims to give you information on how your personal data (i.e., information which directly or indirectly identifies you) is processed by us. For the purposes of EU data protection laws, we are a data controller.
Data That May Be Collected
We may collect certain personal data with respect to you as a customer, including, without limitation your name, address, date of birth, contact details, credit reference data, financial and employment details, banking and credit card details, bank statements, proof of ID, trading accounts and details of your business. We collect some of this data from third parties, for example credit reference agencies.
Where a corporate entity is entering into this contract we will collect personal data about the individuals who are directors and shareholders of the business from credit reference agencies where this data is held publicly, such as at Companies House. This notice also applies to the processing of such personal data and use of the word ‘you’ in this notice will encompass such individuals.
We may process sensitive personal data (including, for example, information revealing an individual’s physical or mental health). Where sensitive personal data are processed we will obtain your explicit consent for the processing.
Use of Personal Data
We will use your personal data for: provision of products and services via a lending partner. Our lending partner may also use your data for credit and AML risk assessment, assessing ongoing credit performance, recoveries, collections, insurance administration, profiling for marketing purposes, market research and product development, statistical analysis, marketing, fraud prevention and detection and otherwise as necessary to comply with applicable laws, regulations and/or codes of practice. The processing of personal data may be necessary for the performance of a contractual relationship, compliance with a legal obligation, or where it is in our legitimate interests, or those of a company within any group of companies of which we are a member.
Disclosure to Certain Third Parties
We may disclose certain personal data: (i) within any group of companies of which we are a member and to other affiliates in that group; (ii) to our lending partners, professional advisors and service providers (including, information technology systems providers and recovery agents); (iii) to courts, governmental and non-governmental regulators and ombudsmen; (iv) to fraud prevention agencies and law enforcement agencies; (v) to any third party that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or a part of our business, whether by merger, acquisition, reorganization or otherwise; and (vi) as otherwise required or permitted by law.
We may also pass your Personal Data on to other companies within any group of companies of which we are a member and/or any relevant third party and both we and/or they may use it for any purpose linked to any sale of and/or granting of security over the agreement we have with you. In such circumstances, such third parties may also use and/or disclose your Personal Data to any third party that they ask to assist them with the preparation for and/or completion of any such sale and/or granting of security; they may also, once such sale and/or granting of security is completed, use and/or disclose your Personal Data to third parties for any of the other purposes which we have outlined in this notice in the same way as if they had entered into the agreement with you instead of us.
The personal information we have collected may be shared by our lending partners with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights can be found on the our website at http://www.bluestarleasing.com/customer-privacy-notice/
In order to process your application, our lenders will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). To do this, our lenders may supply your personal information to CRAs and they will give them information about you, even if your application does not proceed or is unsuccessful. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to them both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
Our lending partners will use this information to:
- Assess your creditworthiness;
- 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.
Our lending partners may continue to exchange information about you with CRAs while you have a relationship with them. They may 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 one of our lending partners 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, your records may be linked 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.
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 at each of the three CRAs websites – any of these three links will take you to the same CRAIN document:
Transfer of Personal Data Outside the European Economic Area (“EEA”)
We may transfer your personal data to recipients located in countries outside of the EEA which may not have data privacy laws equivalent to those in the EEA. In those instances, we will take all necessary steps to protect your personal data in accordance with applicable data privacy laws.
Under applicable EU data privacy laws, you may have a right to: (i) request access to and rectification or erasure of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) data portability (i.e. to request the transfer of personal data from one data controller to another in certain circumstances). If you wish to exercise any of these rights you should contact the Data Privacy Officer as described below. You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority.
Our lending partners may rely on automated credit assessment based on the personal data you provide to us and data which we obtain from our credit reference agency or similar sources about your credit profile or history. The outcome of this process can result in an automated decline of your application where it does not meet our lending partner’s acceptance criteria. We review this acceptance criteria regularly to ensure fairness in the decisions made. You have a right to ask us to manually review any decision taken in this manner.
In addition our lending partners may use automated profiling to identify whether other products or services may be of use to you when we consider marketing campaigns. You have a right to object to this automated profiling. This is separate to the right you have to object to receive marketing.
We will take steps to protect your personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held.
We will normally retain your personal data for an indefinite period if you have transacted a financial agreement we have introduced to a lending partner, this is in line with our regulatory responsibilities set out by the FCA (Financial Conduct authority). If we have worked with you on a financial opportunity that was not transacted we will delete all personal data held when we have been instructed, by you, that you no longer wish to proceed with the financial agreement application, or we have been unable to progress a financial application. Under certain circumstances this period may vary if we consider it necessary for good operational or commercial reasons, or in order to meet other legal obligations.
Enquiries, Requests of Concerns
All enquiries, requests or concerns regarding this Notice or relating to the processing of Personal Data, should be sent to the Data Privacy Officer using the following email address firstname.lastname@example.org or by calling 01420-481500 and speaking to Marcus Gregory.