Blue Motor Finance Limited Customer Fair Processing Notice

Introduction

Blue Motor Finance Limited (Blue), has prepared this Fair Processing Notice (FPN) to explain how it uses any personal data it collects about you. Blue is a data controller of the data it collects about its customers, and this FPN describes how it uses your information. Blue’s contact details are:

This FPN applies to Blue’s customers, people who have applied to it for finance, and individuals connected to its customers whose data it collects as part of its interactions with customers. If you are a partner, supplier, or another third party, please see the Third Party FPN.

What information does Blue collect?

Information Blue collects from you

When you apply to Blue for a loan, you provide it with information so that it may decide whether to lend to you. Blue may not be able to lend to you if you do not provide this information. The information that you provide to Blue includes your:

  • name
  • address
  • email address
  • phone numbers
  • bank details
  • employment information
  • identity information which may include Photo ID
  • gender
  • household information (including marital status and number of dependants)
  • financial information (including income and the details of your loan application).

In the course of applying for a loan or while the loan is operating and you interact with Blue, you may provide to Blue and/or Blue may need to process information which is especially sensitive.  Some of this information is called “Special Category Data” and may include information about your health, family circumstances, accessibility needs, gender, and social and lifestyle arrangements. Other information may relate to any criminal offence, allegations or proceedings.

Blue describes how it treats this information below.

Information collected from third parties

Blue will collect information about you from third parties, such as Credit Reference Agencies (CRAs) when it carries out credit checks on you (see below for more information).

What legal basis does Blue have for using your information?

As the data controller, Blue is legally responsible for ensuring that it has a legal basis for processing your information. The UK GDPR sets out several legal bases for processing personal data, and Blue relies on the following of those bases:

  • Contract:
    • Blue relies on contract as its lawful basis for taking the necessary steps so that it can enter a contract with you (e.g. to provide a quote)
    • Blue relies on contract as its lawful basis for delivering its contractual obligations to you (e.g. to collect finance payments)
  • Legitimate Interests:
    • Blue relies on the legitimate interests ground where it has a legitimate interest in performing the processing (e.g. where it records its phone calls with you for training purposes and where it carries out credit checks)
    • Where Blue relies on legitimate interests ground, it performs assessments to ensure that it considers the impacts of its processing on you and balances its interests against yours
  • Legal Obligation:
    • Blue relies on legal obligation where it has an identifiable legal obligation to process your information (e.g. to maintain records of loans it has made)
  • Consent:
    • Blue relies on consent as its lawful basis for direct electronic marketing.
    • Blue will only market to you where you have given your consent to do so, and you may withdraw your consent at any time by contacting the Customer Services team at:

customerservices@bluemotorfinance.co.uk

0203 005 9332

What about especially sensitive information?

As described above Blue may need to use information which is especially sensitive such as information in relation to health, lifestyle, accessibility, family circumstances and in some cases information relating to criminal matters or offences.

Where this is the case, Blue will normally process this information on the legal basis that it is in the wider public interest, such as for regulatory or legal reasons (for example in relation to identifying and supporting any vulnerability or making any accessibility adjustments) or for preventing or detecting unlawful acts such as fraud.

There may alternatively be some instances, such as where you provide Blue with especially sensitive personal information in calls and contacts, where the basis of this processing is consent Blue will ask for your consent to do this. You have the right at any time to withdraw that consent and in such circumstances Blue will stop the processing of that specific information. However, Blue may need to retain records of that information and undertake processing relating to that as part of performing our regulatory and legal obligations

For what purposes will Blue use your information?

Blue may use your information to:

  • Assess your loan application
  • Conduct credit checks on you
  • Decide whether to lend to you
  • If Blue decides that it will not lend to you, to identify alternative lenders and ask them whether they are willing to lend to you
  • Enter a credit agreement with you
  • Operate and manage your account and any agreements
  • Recover any debt that you owe Blue
  • Contact you via email, SMS, letter, or telephone regarding your account
  • Contact you via email, SMS, letter, or telephone with marketing information where Blue has a legal basis for doing so
  • Comply with Blue’s legal and regulatory obligations, including in respect of fraud and money laundering
  • Assess whether you are or may be vulnerable or are in circumstances which may make you vulnerable, and whether Blue needs to make special considerations based on that vulnerability
  • Conduct market research and business analysis
  • Perform internal audits and other administrative or operational tasks such as systems tests
  • Trace your location if necessary for debt recovery or collections.

How will Blue use your information?

Blue may process your information in various ways, using automated and manual systems.

Blue uses automated decision making as part of its process to determine whether it will lend to you and on what terms. Blue will compare your profile against its qualification criteria using automated means. If you do not meet its  criteria, it may refuse to lend to you on the sole basis of its automated decision making systems.

With whom will Blue share your information?

Partner Finance Companies

Blue may share your information with Partner Finance Companies (PFCs) in order to find alternative finance providers, where it has decided not to lend to you. If it shares your information with PFCs, it will be acting as a broker, it will provide a link(s) below to the relevant PFCs privacy notice.

Specialist Motor Finance  Limited Privacy Notice: https://www.smfmotor.com/privacy-notice/

Moneybarn Limited: https://www.moneybarn.com/privacy-policy/

Advantage Finance Limited: https://www.advantage-finance.co.uk/Information/UseOfYourData

Credit Reference Agencies

If you apply for a loan, Blue will carry out credit checks on you with CRAs, to:

  • confirm the details you have provided when you apply for a loan;
  • make credit and affordability assessments to decide whether to accept your loan application and set credit limits.

Blue will carry out additional checks on you from time to time to understand your financial position and manage your loan account. 

To carry out credit checks on you, Blue will provide your information to a CRA and the CRA will give Blue information about you. The information that Blue receives from CRAs contains details of your financial history and other people with whom you are financially linked (such as your spouse or partner), including but not limited to:

  • credit score
  • sanctions, politically exposed persons, or special interest persons status
  • current and previous addresses
  • credit history, including:
    • current credit commitments
    • historic credit commitments ending in the last six years
    • credit payment history
  • electoral roll details
  • details of credit searches undertaken by other organisations
  • information from fraud databases

If Blue searches your record at a CRA, the CRA will add to your record the details of its search and the details of your loan application. Blue may also share your information with CRAs on an ongoing basis, including details of settled accounts or debts not fully repaid on time. This information will be available to other organisations that search your CRA record. Other organisations may use this information and other information about you to make credit decisions about you and the people with whom you are linked financially (such as a spouse or partner).

If you propose a joint agreement or Blue enters an agreement with you involving joint parties, this information will be recorded with CRAs. This will create an association between your record and your joint party’s record, which Blue or other organisations may consider in future decisions. This association will remain in place until you file a disassociation with the CRA.

For more information on CRAs, including their relationship with Fraud Prevention Agencies, please refer to the Credit Reference Agency Information Notices below.

Fraud Prevention Agencies

Blue may share your information with Fraud Prevention Agencies (FPAs) to detect and prevent fraud. FPAs will share their records with other organisations. Those organisations may use this information to make decisions about you and other persons connected to you, including in relation to employment, credit, or insurance.

For more information on FPAs, please refer to the Fair Processing Notices below.

CIFAS Fair Processing Notice: https://www.cifas.org.uk/fpn

Legal, Governmental, and Regulatory Bodies

Blue may share your information with legal, governmental, and regulatory bodies to meet its legal and regulatory obligations. These may include the Financial Conduct Authority, the Financial Ombudsman Service, the Information Commissioner’s Office, or any other legal, governmental, or regulatory body.

Service Providers

Blue may share your information with professional advisers (including legal advisers), outsourcing providers (such as IT service providers), financial institutions (such as banks), or with any other type of organisation or person that it uses to help it conduct its business.

Authorised Third Parties

Blue may share your information with any person that you have authorised to engage with it on your behalf or that otherwise has a legal authorisation to do so. This includes parents/guardians, carers, or any other helpers where you are unable to handle your own affairs due to mental incapacity or other similar issues.

Blue may share your information with any organisation you have appointed to act on your behalf or authorised to receive your information, such as law firms and claims management companies.

Restructure, sale or acquisition

Blue may share your information with any person to whom it sells or transfers (or enters into negotiations to sell or transfer) its business or assets. If the transfer or sale goes ahead, the transferee or purchaser may use your information as set out in this FPN. 

Other lenders with an interest in your loan

If you have a loan agreement, Blue may transfer an interest in your loan to selected partners, such as other lenders, including where Blue transfers or delegates its rights and obligations under your loan agreement to another lender. If the transfer goes ahead, Blue may share your information with each transferee who has an interest in your loan where there is a legitimate reason for it to do so - for example, to enable the other lender to meet its regulatory obligations or reporting requirements. In such circumstances, the transferee may use your information as set out in this FPN, including data from credit reference agencies for the purpose of assessing their risk, which may include matching your data to other data which they may hold about you. 

Where will Blue transfer your information?

Blue may transfer your information outside the United Kingdom. If Blue transfers your information outside the United Kingdom to a country that is not subject to an adequacy decision in respect of its data protection laws, it will conduct a transfer risk assessment and put in place the necessary safeguards to ensure that your information receives an equivalent level of protection. For more information on international data transfers, including details of safeguards, please contact Blue’s Data Protection Officer at dpo@bluemotorfinance.co.uk.

How long will Blue keep your information?

If you apply for finance and Blue decides not to lend to you or your finance application is accepted but you do not proceed, it will keep your information for 3 years from the end of your relationship with it. Blue does this for several reasons, including to provide information to regulators on its lending practices. However, Blue may extend the relationship beyond the date it refused your loan application, e.g. if there is an ongoing dispute or complaint. If Blue extends the relationship, it will end it as soon as it determines it is possible to do so, e.g. when the dispute or complaint is settled.

If you enter a loan agreement with Blue, it will keep your information for 7 years from the end of your relationship with it. Blue does this for several reasons, but primarily to maintain records according to its legal and regulatory obligations. If you have a contract with Blue, your relationship with it will normally end when your contract ends. However, Blue may extend the relationship beyond the end of the contract, e.g. if there is an ongoing dispute or complaint. If it extends the relationship, it will end it as soon as it determines it is possible to do so, e.g. when the dispute or complaint is settled.

What rights do you have with regard to your information?

You may have the following rights in regard to your information:

  • The right to be informed about the collection and use of your information, as set out in this FPN
  • The right of access to a copy of your information
  • The right to rectify incorrect or incomplete information
  • The right to the erasure of your information, which will not apply in some circumstances, including if Blue is under a legal obligation to retain your information
  • The right to restrict processing of your information (subject to limitations)
  • The right to data portability (subject to limitations and not including paper files)
  • The absolute right to object to the processing of your information for direct marketing, and a limited right to object in some circumstances, including to the processing of your information on the basis of legitimate interests
  • The right to withdraw consent, where Blue is relying on your consent
  • Rights in relation to automated decision making and profiling.

If you wish to exercise your right of access to a copy of your information, please contact Blue at its dedicated email address dsar@bluemotorfinance.co.uk.

If you have questions regarding your rights or wish to exercise a right other than the right of access, please contact Blue’s Data Protection Officer at dpo@bluemotorfinance.co.uk.

How can you complain about our processing of your information?

If you are dissatisfied with Blue’s  processing of your information, please first contact the Data Protection Officer. Blue’s Data Protection Officer may be able to resolve your complaint or address your concerns. The Data Protection Officer can be contacted at: dpo@bluemotorfinance.co.uk.

You have the right to complain to the Information Commissioner’s Office about Blue’s processing of your information. You can contact the Information Commissioner’s Office using the following details:

Web: https://ico.org.uk/make-a-complaint/

Telephone: 0303 123 1113