Unsecured loans privacy statement
Published on 06 May 2021
Places for People Financial Services Ltd is committed to protecting your privacy when you use our services.
The Privacy Notice below explains how we use information about you and how we protect your privacy.
We have a Data Protection Officer who makes sure we respect your rights and follow the law. If you have any concerns or questions about how we look after your personal information, please email the Data Protection Officer.
Why we collect your personal information
Do you know what personal information is?
Personal information can be anything that identifies and relates to a living person. This can include information that when put together with other information can then identify a person.
Information we may collect about you may include (but is not limited to):
We will record information throughout your application and store it to our database, once you have hit the submit application button we will perform checks on the information you provide with third parties – once some of these checks have been performed we are legally obliged to keep the information in line with our retention schedule (this is available in our Frequently Asked Questions page).
Type of personal information
Income and expenditure, bank statement data you provide to us, credit reference agency data
Your name, address, telephone numbers and email address
Your employment details, your household make up and your residency status
Payments to and from your loan account
Loan agreements, direct debit mandates and other terms and conditions you agree to
Data about where you are such as an IP address
Data about how you manage other contracts from credit reference agency data or bank statement data you provide to us
Details on the type of device you use to access our application form
Copies of emails, SMS messages and letters we send to you or you send to us
Open data/Public Records
Such as electoral roll data
Information on your intended use of any approved funds
Copies of any supporting evidence you have provided to prove your identity, income or address
Contact preferences and marketing permissions
Your National Insurance number you provided to us
We may also collect personal information from others who you authorise to speak to us on your behalf – this may include:
- Family and household members
Did you know that some of your personal information might be classified as ‘special’?
Some information is ‘special’ and needs more protection due to its sensitivity. It’s often information you would not want widely known and is very personal to you. This is likely to include anything that can reveal information relating to your:
- Sexuality and sexual health
- Religious or philosophical beliefs
- Physical or mental health
- Trade union membership
- Political opinion
- Genetic/biometric data
- Criminal history
We will only collect this type of information if it is necessary to your contract or you willingly disclose it to us at any point during your contract, so that we can provide the right services to you. In some circumstances we may ask for your additional consent to record this information with the right for you to request it be withdrawn at any time.
We may at times need to share this information we will only do this if we have your consent or if there are legal requirements for us to do so. We may receive information about you from other data controllers, such as to the police who might tell us about a crime they are investigating where this impacts on your contract with us. If you give us this information about yourself when communicating with us, you do so because you consider it forms part of a legitimate interest for us to hold this information on our records.
If we ask for any sensitive personal data about you, we will always tell you why we need it and ask for your consent to hold it.
Why do we need your personal information?
We may need to use some information about you to:
- deliver products and support to you;
- manage those products we provide to you;
- product improvement
- prevention/detection of crime/fraud
- help investigate any complaints you have about your products;
- check the quality of products and services;
- to help with research and planning of new products.
How the law allows us to use your personal information
There are a number of legal reasons why we need to collect and use your personal information.
Generally we collect and use personal information for the purposes of where:
- you are entering or have entered into a contract with us
- you, or your legal representative, have given consent
- it is necessary to protect someone in an emergency
- it is required by law
- you have made your information publicly available
- it is necessary for legal cases
- it is necessary for archiving, research, or statistical purposes
Consent and Your Preferences
We may contact you or send communications to tell you about a service enhancement such as improvements to our online services or to keep you informed on how we are performing. We won’t need your consent to communicate with you this way because we have assessed that it forms part of our agreement with you and it is of mutual interest for us to keep you informed and is relevant to your contract with us.
We would like to occasionally send you information on other products and services we offer, and which we think will be of interest to you. We will ask for your consent to communicate this type of information to you, you can remove your consent and ask us to stop.
Places for People Financial Services Ltd is part of the Places for People Group, one of the largest property and leisure management organisations in the UK. Places for People provides customers with a wide range of products and services, including leisure centre and gym memberships, affordable finance products and retirement services to name just a few. We would like to occasionally send you marketing information on products and services that we think will be of interest to you and we will ask for your consent to do this. We promise to treat your contact details with the utmost care, and to never pass them to companies outside of the Places for People Group.
If we have consent to use your personal information to send you information about other Places for People Group companies products and services, you have the right to remove it at any time. Places for People Financial Services Ltd provide access for you to update your consents to marketing, you can do this at any time by logging on to your online account or alternatively email email@example.com.
We only use what we need
Where we can, we’ll only collect and use personal information if we need it to deliver a service or meet a requirement.
If we don’t need personal information we’ll either keep you anonymous if we already have it for something else or we won’t ask you for it. For example in a survey we may not need your contact details so we’ll only collect your survey responses.
If we use your personal information for research and analysis, we’ll keep you anonymous or use a different name unless you’ve agreed that your personal information can be used for that research.
We won’t sell your personal information to anyone else.
We may share your information with other companies within our group, we will always ask for your consent to do this and you can ask us to stop at any time.
We will always provide an option for updating your marketing preferences on our communications with you.
Visiting our websites
When you visit one of our websites, we collect standard internet log information for statistical purposes.
- We do not make any attempt to identify visitors to our websites. We do not associate information gathered from our sites with personally identifying information from any source.
- When we collect personal information, for example via an online form, we will explain what we intend to do with it.
Our websites contain links to various third party websites. We are not responsible for the content or privacy practices of any external websites that are linked from our sites.
How we use your telephone number and email address
Text messages and contact via telephone or email provide a direct way to contact and share information with you about the services we can deliver to you. It can also help you receive important messages about your products or information that may interest or a help you to you such as new online services.
If you provide your telephone number or email address we may keep in contact with you by these methods:
Operational SMS/text/email messaging and calls
If you supply us with your telephone or email contact details, we may use them to call or send you operational text messages.
Examples of operational text messages include:
- Confirmation codes to help you e-sign for your loan
- Notifications of missed payments
- Asking you to contact a named person or department
- Satisfaction surveys
Sharing your telephone number with third parties
We may pass your telephone number to third parties so that we can meet our contractual obligations with you. We may also share your telephone numbers if we are required to by law.
We may supply the details to our approved third party contractors who are delivering or performing services on our behalf, and these companies must not use your information for any other purpose. We never share or sell your telephone numbers to telesales/marketing companies.
Who do we share your information with?
We use a range of organisations to either store personal information or help deliver our services to you. Where we have these arrangements there is always an agreement in in place to make sure that the organisation complies with data protection law.
It is not always possible for us to tell you that personal information is being shared, for example when we are working with the police or other agencies to help the investigation or detection of a crime as to do so may prejudice that investigation.
We are likely to share your personal information with the following:
Credit References Agencies
In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates.
The Direct Debit scheme
If you use Direct Debits we will share your information with the Direct Debit scheme
Debt management companies or other selected representatives
We may share your personal information with companies acting on your behalf such as debt management companies or advice services. We will ensure that we have your consent to do so before sharing information
Product Review sites
We may share your email address with product review sites so that we can invite you to review our products or services
We may share information on the performance of your loan account where we have links with your landlord. This will not affect your tenancy agreement with them in any way.
The Department for Work and Pensions
We may share your personal information with The Department for Work and Pensions for the purposes of recovering any outstanding debts owed to us
We may share your personal information with the police for the purposes of preventing or detecting a crime or fraud.
Debt Recovery Agents
We may share your personal information with debt recovery agents for the purposes of recovering any outstanding charges owed to us.
Legal Services and Partners
We may share your personal information with our legal services or solicitors if we are preparing or defending a legal claim.
The Financial Conduct Authority
We may share your personal information with our regulator to fulfil our regulatory requirements
The Financial Ombudsman
We may share your personal information with our Ombudsman to fulfil our regulatory requirements, for example to respond to or defend a complaint.
Places for People Group companies
We may share your information with shared service functions within the Places for People Group, such as for the purpose of financial transactions when we fund a loan or when you are making payments to us. Places for People Group shared services comply with and process personal information within the same privacy standards and procedures.
We may share your information with service functions outside the Places for People Group, such as for the purpose of financial transactions when we fund a loan or when you are making payments to us or where they provide a software system that we use. These companies are contracted to us and are obliged to process personal information within the same privacy standards and procedures.
Company mergers and takeovers
We may choose to sell, transfer, or merge parts of our business, or our assets.
During any such process, we may share your data with other parties involved. We’ll only do this if they agree to keep your data safe and private. If the change to our business happens, then other parties may use your data in the same way as set out in this notice
Where there is a high risk to your personal information we will complete a privacy assessment before we share personal information to make sure we protect privacy and comply with the law.
Sometimes we have a legal duty to provide personal information to other organisations, this is often because we need to give that data to the police, courts, local authorities or government bodies.
We may also share your personal information when we feel there’s a good reason that’s more important than protecting your privacy. This doesn’t happen often, but we may share your information:
- in order to detect and prevent a crime and fraud or
- if there are serious risks to the public, our staff or to other professionals
Keeping your information secure
We store personal information both electronically and in paper form.
We implement security policies, processes and technical security solutions to protect the personal information we hold from:
- Unauthorised access
- Improper use or disclosure
- Unauthorised modification
- Unlawful destruction or accidental loss
We’ll do what we can to make sure we hold records about you (on paper and electronically) in a secure way, and we’ll only make them available to those who have a right to see them. Examples of our security include:
- Encryption, meaning that information is hidden so that it cannot be readwithout special knowledge (such as a password). This is done with a secret code or what’s called a ‘cypher’. The hidden information is said to then be ‘encrypted’
- Pseudonymisation, meaning that we’ll use a different name so we can hide parts of your personal information from view. This means that someone outside of the Places for People Group could work on your information for us without ever knowing it was yours
- Controlling access to systems and networks allows us to stop people who are not allowed to view your personal information from getting access to it
- Training for our staff allows us to make them aware of how to handle information and how and when to report when something goes wrong
- Regular testing of our technology and ways of working including keeping up to date on the latest security updates (commonly called patches)
When you contact us, we may ask you to provide us with some information so that we can confirm your identity. If other people (e.g. family members, support workers, solicitors) act on your behalf we will take steps to ensure that you have agreed for them to do so. This may include asking them to provide us with supporting information to indicate your consent. We do this to protect you and to make sure that other people cannot find things out about you that they are not entitled to know.
Employees and third parties who have access to, or are associated with the processing of, your personal information are obliged to make reasonable efforts to safeguard it.
Where in the world is your information?
The majority of personal information is stored on systems in the UK. But there may be some occasions as our technology services progress where your information may leave the UK either in order to get to another organisation or if it’s stored in a system outside of the EU.
We will always have additional protections on your information if it leaves the UK ranging from secure ways of transferring data to ensuring we have a robust contract in place with that third party.
We’ll take all practical steps to make your personal information is not sent to a country that is not seen as ‘safe’ either by the UK or EU Governments.
How long do we keep your personal information?
There’s often a legal or a contractual reason for keeping your personal information for a set period of time. We will keep your information as per our published retention schedule available in our Frequently Asked Questions section. When your contract has ended we will keep your personal data for a set time for auditing and reporting purposes and for legitimate interest purposes, after that time we will either anonymise or destroy your information.
The law gives you a number of rights to control what personal information is used by us and how it is used by us.
You can ask for access to the information we hold on you
You have the right to ask for the information we have about you. When we receive a request from you in writing, we must give you access to what personal information we’ve recorded about you.
However, we can’t let you see any parts of a record which contain:
- Confidential information about other people; or
- May be held in preparation to defend legal claims
This applies to personal information that is in both paper and electronic records. If you ask us, we’ll also let others see your record (except if one of the points above applies).
A request for personal information can be made via email or in writing. This is known as a subject access request. In order to make a subject access request you will need to provide the following information:
- your name
- your address
- proof of identity and signature
- enough information to identify your records, such as your loan number
What types of documents could I submit as proof of ID?
- Copy passport with signature (please remove your passport number)
- Copy driving license picture with signature (please remove your driver number)
You can write to us at the following address:
Places for People Financial Services Ltd
Data Protection Request
South Rings Business Park
18 Craven Drive
Alternatively email us at firstname.lastname@example.org. (Please ensure you attach your identity documents with the document reference numbers removed).
We will not start your subject access request until we are satisfied that you have provided us with enough information for us to identify you.
Once you have made a request you will receive an acknowledgement and your request should be answered within one month. In certain circumstances, we are allowed to take longer but we will tell you if we feel we may need longer without undue delay from when we receive your request.
If you can’t ask for your records in writing, we’ll make sure there are other ways that you can. If you have any queries about access to your information please call us on 01772 666122.
You can ask to change information you think is inaccurate
You should let us know if you disagree with something we may have recorded about you.
We may not always be able to change or remove that information but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
Please email us at email@example.com or call 01772 666122 to discuss.
You can ask to delete information (right to erasure)
In some circumstances you can ask for your personal information to be deleted, for example:
- Where your personal information is no longer needed for the reason why it was collected in the first place
- Where you have removed your consent for us to use your information (where there is no other legal reason us to use it)
- Where there is no legal reason for the use of your information
- Where deleting the information is a legal requirement
Where your personal information has been shared with others, we’ll do what we can to make sure those using your personal information comply with your request for erasure.
Please note that we can’t delete your information where:
- we’re required to have it by law
- it is for historical research, or statistical purposes where it would make information unusable
- it is necessary for legal claims
You can ask to limit what we use your personal data for
You have the right to ask us to restrict what we use your personal information for where:
- you have identified inaccurate personal information, and have told us of it
- where we have no legal reason to use that information but you want us to restrict what we use it for rather than erase the information altogether
We will assess whether you have a right to a restriction and where restriction of use has been granted, we’ll inform you before we carry on using your personal information.
Where possible we’ll seek to comply with your request, but we may need to hold or use information because we are required to by law or we have a legal basis to do so, such as a contract.
You can ask to have your information moved to another provider (data portability)
You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.
However this only applies if we’re using your personal information with consent (not where we are processing your personal information for contractual, legitimate interests, legal obligations or vital interests as a legal basis) and if decisions were made by a computer and not a human being.
It’s likely that data portability won’t apply to most of the services you receive from Places for People Financial Services Ltd
Right to understand Automated Decisions made about you
We will make automated decisions about your application. You can ask to have any computer made decisions explained to you, and details of how we may have ‘risk profiled’ you.
You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you’ve consented to it.
If you have concerns regarding automated decision making, or profiling, please contact the Data Protection Officer at firstname.lastname@example.org who’ll be able to advise you about how we are using your information.
How to tell us of a data breach
Places for People Financial Services Ltd and Places for People Group takes responsibility to protect the personal information we hold about those with whom we work seriously. We are accountable for our processing and take necessary technical and operational steps to information security protections.
If you suspect your personal information or that of others may have been at risk of a data protection breach please tell us by using the breach notification link: Incident Reporting Portal
The above link has been made available to everyone with whom we deal so that customers, employees and supply chain processors can tell us without undue delay of potential or actual breach.
Where can I get advice?
If you have any questions about how your personal information is handled please contact our Data Protection Officer at email@example.com
For independent advice about data protection, privacy and data sharing issues, you can contact the Information Commissioner’s Office (ICO) at:
Information Commissioner's Office
Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number.
This section of our privacy notice relates to Open Banking and should be read in conjunction with the other clauses in our terms and conditions. In the event of conflict with any other clauses, this clause shall prevail. If you require this in another format please contact us on 01772 666100.
What is Open Banking?
Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose. Registered providers and participating banks and building societies are listed under the Open Banking Directory. Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector.
As a forward thinking lender, we support the use of Open Banking as it allows us to process loan applications efficiently, securely and in our customer’s best interests.
By permitting access to your bank or building society account information we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.
Further information about Open Banking is available from www.openbanking.org.uk.
How will my personal data be shared and used for the purposes of Open Banking?
By proceeding with your loan application and using the service supplied by OohMoolah (provided by Perfect Data Solutions Limited (“PDS “)) you expressly consent to sharing your transaction data with our registered Open Banking partner PDS, who are also a credit reference agency. During your loan application we shall safely and securely direct you to PDS’s secure portal (“the Portal”) for the purposes of granting PDS access to your bank or building society account information (“Transaction Information”).
As soon as your Transaction Information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”).
Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com.
Is Open Banking secure?
Yes, PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards.
We are responsible for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information. You will not be required to share your banking password or log in details with either us or PDS. Once you have given your explicit consent to share your bank account information on the Portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.
How will my Shared Personal Data and Transaction Information be used?
PDS shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.
As PDS are also a credit reference agency they may also share and keep a record of your Transaction Information.
Will you use my Transaction Information data for any other purpose?
The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.
Do I have to provide you with my consent to proceed?
No, this service is optional – it is however a faster and more secure way of sharing transactional information with us than post or email. Once we receive your information into our system we will be processing it under our legitimate interest, in order to form a contract with you. Details of our retention policy, which informs you of how long we may keep your data, can be found within our FAQ section on our website or you can request this to be sent to you or read to you if you prefer (please call us on 01772 666100 or email firstname.lastname@example.org).
Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.
Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.