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Optimum Credit Limited (“Optimum”) of Haywood House South, Dumfries Place, Cardiff CF10 3GA is a data controller of your personal information. This means information about you or from which we can identify you. This privacy notice is a statement of how Optimum processes your personal information in accordance with relevant data protection laws. It underpins our approach to respecting your privacy.
We can be contacted at any time at the above address including if you have queries about this privacy notice or wish to exercise any of the rights mentioned in it. You can also contact the Data Protection Officer by: Email: DPO@optimumcredit.co.uk
This privacy notice may be updated from time to time. This means we may send you an updated copy (depending on whether we are required to do that or not).
We will generally collect your personal information from you directly, including application forms, correspondence, email, telephone, or via our website. If you are introduced to us by a broker or other intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.
In addition, we may obtain your personal information from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, your employer, landlord, other lenders, HMRC, DWP, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.
Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources. In particular, Credit Reference Agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about Credit Reference Agencies below. We have also mentioned above in the lists of personal information that we process some of the Credit Reference Agencies’ other sources of information (which are our own source of information too).
When a broker or other intermediary processes your personal information on our behalf, this privacy notice will apply and you should contact us to exercise your rights under data protection laws. When a broker or other intermediary processes your personal information as a data controller in its own right, its own privacy notice will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.
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We process your personal information for the primary purpose of providing our services, as a mortgage provider, to you. The information that we generally process in connection with these services includes:
We are unable to provide you with products and services or to process your application without having personal information about you. Your personal information is required before you can enter into the relevant contract with us, and/or it is required during the life of that contract, and/or or it is required by laws that apply to us. If we already hold some of the personal information that we need – for instance if you are already a customer – we may not need to collect it again when you make your application.
In cases where providing some personal information is optional, we will make this clear in any discussions regarding the provision of that information. For instance, we will say in application forms, or via the broker or other intermediary, if the alternative (such as work) telephone number can be left blank.
If you make a joint application with your spouse, partner or family member, we will also collect the personal information mentioned above about that person. You must show this privacy notice to the other applicant and ensure they confirm that they know you will share it with us for the purposes described in it. If you look now at the “What are the legal grounds” section (below) you will see reference to consent and a description of some limited scenarios where it may be relevant to what we do with personal information. If we ask you to obtain consent from the joint applicant (such as for marketing) you should do that using the consent capture mechanism that we give or make available to you for that purpose.
If you apply for your mortgage with a guarantor, that person will see this privacy notice when he/she submits his own personal information to us because he/she must necessarily sign the application form.
If there is somebody who has power of attorney over your affairs, that person will see this privacy notice when we make contact with him/her directly.
Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations). For some processing more than one legal ground may be relevant (except where we rely on a consent). We set out as follows the legal grounds that are relevant to us.
1. Processing necessary to perform our contract with you or for taking steps prior to entering into it:
2. Where we consider that, on balance, it is appropriate for us do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations (who we list below) are:
Your guarantor (if you have one);
If your application is unsuccessful or if you decide not to proceed on the rate we have proposed we will retain some of your personal information related to the application or the pre-application quotation searches (including if you applied through a broker or other intermediary) for the following legitimate interests. First, we have a legitimate interest in managing the risk to our business of money laundering, fraud and other crimes and in meeting our legal and regulatory obligations in this type of circumstance. We have to be able to identify where there is a particular risk of these serious issues arising. For example, if an individual resubmits the application or makes a second enquiry pre-application for a rate quotation, and if he or she does this through a different broker or intermediary with changed details of his or her income or marital circumstances, it would be very important to identify that. Similarly, if our identity checks, anti-money laundering checks, checks with Fraud Prevention Agencies or Credit Reference Agencies pre-application or during the application (as relevant) reveal risk – we would retain the relevant details until we were satisfied we no longer needed them for the legitimate interest we have mentioned here. Secondly, where there is a decision not proceed on the rate that we offer, we have a legitimate interest in keeping a record of that rate and some of the personal information related to our offer in order to take account of it when an individual resubmits the application or makes a second enquiry. It would be contrary to this legitimate interest if individuals were able to resubmit through another broker or intermediary soon afterwards and if we were unable to identify the rates we had already offered having carefully considered their application first time around. It is necessary to process and retain personal information for these legitimate interests and we have balanced these against your own interests rights and freedoms. Your own interests do not override our legitimate interests here since we do not retain your personal information for longer than necessary and we do not make public that information – we use it only for our own strict needs in these circumstances and in accordance with data protection laws.
3. Processing necessary to comply with our legal obligations:
Your guarantor (if you have one);
4. Processing with your consent:
5. Processing for a substantial public interest under laws that apply to us where this helps us to meet our broader social obligations such as:
Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details above. The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about your health or if you are a vulnerable customer (but these outcomes will be relevant only in cases where we rely on explicit consent for this).
We will tell the broker or other intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.
To comply with payment services regulations we have to share some of your personal information with other payment service providers in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. This is why if you ask to withdraw consent from what we do with your personal information, we may still have to hold and use your personal information where we need to have it in relation to the payment services regulations
We are based in the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area. If it is processed within Europe or other parts of the European Economic Area (EEA) then it is protected by European data protection standards. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA which do not have adequate protection under laws that apply to us.
For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact us using the details above.
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies. Where you take mortgage services from us we may also make periodic searches at Credit Reference Agencies to manage your account with us. To do this, we will supply your personal information to Credit Reference Agencies and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. Credit Reference Agencies 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:
We will continue to exchange information about you with Credit Reference Agencies while you have a relationship with us. We will also inform the Credit Reference Agencies about your settled accounts. If you borrow and do not repay in full and on time, Credit Reference Agencies will record the outstanding debt. This information may be supplied to other organisations by Credit Reference Agencies. The identities of the Credit Reference Agencies, their role 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 Credit Reference Agencies are explained in more detail in the separate leaflet which we refer to later on in this privacy notice.
When Credit Reference Agencies 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. Credit Reference Agencies 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 Credit Reference Agencies to break that link
The personal information we have collected from you will be shared 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 by contacting our Data Protection Officer by Email: DPO@optimumcredit.co.uk or Post: FREEPOST Optimum Credit Limited.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information.
However, most of the personal information is or will be stored by us for a maximum of five years after your account is closed, unless a longer retention period is required in case of: queries from you; legal claims by you; and/or legal or regulatory requirements to which we are subject. If you would like further information about our data retention practices, please contact us.
In addition, please refer to the paragraph at the end of our list of legitimate interests, where we explain about retention of personal information where your application is unsuccessful or if you decide not to proceed on the rate we have proposed.
Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not.
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/
If you wish to exercise any of these rights against the Credit Reference Agencies, the Fraud Prevention Agencies, or a broker or other intermediary who is data controller in its own right, you should contact them separately.
If you wish to access your personal information, please contact us in writing at Haywood House South, Dumfries Place, Cardiff CF10 3GA or via email using the address: DPO@optimumcredit.co.uk.
In order to protect your personal information, we may require identification from you before releasing the requested information.
In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.
We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or in person meetings (as relevant) we will do so.
Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes.
Some of our monitoring may check for obscene or profane content in communications.
We may conduct short term carefully controlled monitoring of your activities on your account(s) where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes.
Telephone calls and/or in person meetings between us and you in connection with your application and/or your account(s) may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes.
This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. For instance, in relation to transactions on your account(s), payments into your account(s) from other providers, and triggers and events such account opening anniversaries and maturity dates. We may do this to decide what marketing communications are suitable for you, to analyse statistics and assess lending risks.
We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) only where the profiling and other automated decision making does not have a legal or other significant effect on you. In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases you have the right to obtain human intervention to contest the decision (see ‘rights in relation to automated decision making which has a legal effect or otherwise significantly affects you’ below). Profiling for direct marketing can mean there is a separate right to object (see ‘right to object’ above).
We may use your home address, phone numbers, email address and social media (e.g. Facebook, Google and message facilities in other platforms to contact you according to your marketing preferences. This means we do this only if we have a legal ground which allows it under data protection laws – see above for what is our legal ground for marketing. You can stop our marketing at any time by contacting us or by following the instructions on how to do that in the marketing email or other communication.
We have mentioned that we share your personal information with Fraud Prevention Agencies and Credit Reference Agencies. They require us to pass on to you information about how they will use your personal information to perform their services or functions as data controllers in their own right. These notices are separate to our own. Here are links to the information notice of the three main Credit Reference Agencies: Call Credit, Equifax and Experian.
It is an important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
The personal information we have collected from you will be shared 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 obtained by emailing our Data Protection Officer DPO@optimumcredit.co.uk or post: FREEPOST Optimum Credit Limited
Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.
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.
Details of the personal information that will be processed include, for example: name, address, date of birth, contact details, financial information, employment details, device identifiers including IP address and vehicle details.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your personal data 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 contractual requirement of the services or financing you have requested.
Fraud prevention 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.
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 services or financing you have requested, or to employ you, 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. If you have any questions about this, please contact us on the details above.
Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data; request that your personal data is erased or corrected; request access to your personal data.
For more information or to exercise your data protection rights, please contact us using the contact details above.
You also have a right to complain to the Information Commissioner’s Office which regulates the processing of personal data