1. Purpose
a. The purpose of this policy is to outline the company procedures on handling personal data.
b. In order to abide by GDPR and the Data Protection Act, we have strict processes in place in which we expect all employees to abide by.
c. We also expect any contractors, consultants or anyone affiliated or working on behalf of the firm to abide by this policy.
d. We take our regulatory responsibilities very seriously, and all staff and parties we work with should be aware of their responsibilities and duty of care under this policy.
2. Regulation
a. In order to work with personal data, we are required to be registered with the Information Commissioner's Office (‘ICO’). Our registered number is ZA566649.
b. It is the responsibility of Senior Management to ensure that our ICO details are accurate, maintained and up to date.
c. As a company we will ensure we keep up to date with any regulation changes and updates, making any changes or updates to our process to reflect any changes.
d. There are some key words and definitions we feel it is important for you to be aware of to fully understand this policy, we have listed these below.
e. If at anytime there are parts or terms within this policy you do not understand, please consult Kai.
3. What information do we need and/or collect?
a. For the purpose of obtaining a consumer a potential finance acceptance, we will collect the following personal data:
● Name
● DOB
● Address and residential status
● Marital status
● Employment status and details
● Income
● Licence type
● Bank details
● Marketing preferences
● IP information
b. We will not request sensitive data, or any additional personal information that is not required.
c. Personal data can be processed and controlled, we act as a Data Controller, and if we receive an application from an introducer, we can act as a Joint Controller.
4. Principles
a. GDPR sets out 7 principles, which define the obligations of the firm as a registered data user of personal data. Article 5(1) sets out that data shall be: -
(a) processed lawfully, fairly and in a transparent manner in relation to individuals (‘lawfulness, fairness and transparency’);
(b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes (‘purpose limitation’);
(c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);
(d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);
(e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals (‘storage limitation’);
(f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).”
Article 5(2) adds that:
The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).