Your privacy is very important to us. We have put in place measures to ensure that any personal information or data that we obtain from you or third parties is processed in accordance with the accepted principles of good information handling.
This policy sets out the basis on which we collect your personal data and the basis on which it will be processed. Please read the following carefully to understand our views and practices regarding your personal information.
For the purpose of the General Data Protection Regulation and any other applicable data protection laws, the data controller is PCF Bank Limited (Company Number 02794633) having its registered office at Pinners Hall, 105‐108 Old Broad Street, London EC2N 1ER.
We have a data protection officer whose contact details are below.
It is important that the information given to us is accurate, complete and not misleading. You warrant the accuracy of all information provided as part of or in connection with an application. We will check your details and/or the details of any person on whose behalf you are submitting an application and those of any director, partner or guarantor, with fraud prevention agencies and, if you give us false or inaccurate information and we identify or suspect fraud, we and they will record this.
We will use reasonable endeavours to ensure that the information that we hold about you (i) is accurate and up to date, (ii) that we do not keep it for longer than necessary and (iii) that appropriate measures are in place to protect the information from any unauthorised use, except where disclosure is made at your request or with your consent or where we are required by law to disclose it. If any of your information changes after you provided it to us (e.g. your name, address, email address) please tell us as soon as possible so that we can update the information we hold about you.
Joint Accounts /Applications
Where you apply for or have a joint account or make a joint application for a loan and one of the joint account holders or joint borrowers provides personal data about the other account holder or joint borrower, you confirm that: a) as the provider of the information that you have the consent of the other account holder or joint borrower to provide us with that information and b) as the other account holder or joint borrower, that the provider of the information has your consent to provide us with your information. Where you apply for, or have a, joint account or joint application we may collect information that relates to both you and the other joint account holder.
Also, we may share information about (i) one joint account holder with the other joint account holder or (ii) one joint borrower with the other joint borrower.
Information About You That We Collect
The information that we may collect about you includes:
a) Information You Provide To Us: We may collect information: (i) when you visit our website; (ii) when you register with us; (iii) that you provide to us in your application form; (iv) that you provide to us when you contact us (e.g. to make an enquiry or a complaint); (v) that you provide when you apply for products or services from us; (v) that you provide when you update any information we hold about you; and (vi) that you provide when you give us an instruction in relation to your account or application (e.g. to make a payment from your account, repay your loan or to close your account). Where you apply for, or have a, joint account or make a joint application we may collect information that relates to both you and the other joint account holder or joint borrower. Where the applicant is a company or other incorporated entity, we may collect information about the applicant's directors, partners, shareholders, members or employees.
This includes your name, your business name, e‐mail address, date of birth, postal address, telephone/mobile number, fax number, financial details, national insurance number, security questions, employment status, details of your income, physical forms of identity verification, details of any overseas residency (including your tax details in that overseas territory) payment card details, bank account details of your Nominated Account and any information you provide when you contact us or make an enquiry and your marketing preferences. As the application process progresses, we may ask for additional information either because we require it or a third-party credit reference agency or fraud prevention agency requires it.
We may also record and monitor our telephone calls and electronic communications.
b) Information We Collect From Third Parties: If you apply to register with us or apply for any product or services with us, we may also obtain information about you from third parties such as credit reference agencies and fraud prevention agencies as to your financial status, whether you are subject to civil or criminal proceedings, whether you are undergoing medical treatment or have unspent criminal convictions not including minor motoring offences.
If you are applying for a savings account, we will obtain information about you from third parties such as CallCredit Limited who perform daily sanctions checks on our behalf of our account holders.
If you are applying for a loan, we will obtain information about you from third parties such as a credit broker applying on your behalf, Experian Ltd or fraud prevention agencies.
c) Information We Collect About You: With regard to any contact you may have with us or to each of your visits to our website, we will automatically collect the following information:
i) electronic messages, recordings or transcripts of recordings of telephone conversations made between us;
ii) technical information, including, without limitation, the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug‐in types and versions, operating system and platform; and
iii) information about your visit, including, without limitation, the full Uniform Resource Locators (URL), clickstream to, through and from the site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse‐overs), methods used to browse away from the page and any phone number used to call us.
We may also collect financial information about you (e.g. details of the accounts and payments you hold and related payments and transactions).
How We Use Your Information
Once registered you are no longer anonymous to us. We use the information we have collected about you in the following ways:
a) Provide Our Services to You:
We process, transfer and disclose your information in order to verify your identity, perform anti‐fraud and credit checks on you, decide whether to allow you to use this website, whether to go ahead with your application, open an account or grant your application and otherwise onboard you as a customer, and in case we have any queries.
Once you become our customer, we will process, transfer and disclose your information: (i) to provide you with products and services, to collect payment from you, trace any debtors, collect unpaid debts and deal with your transactions; (ii) to manage our relationship with you (including sending you information relevant to your account, details of any changes to your account and sending you marketing if you have agreed to it) and to carry out surveys, business analysis and market research; (iii) for the internal operational requirements for us and our group companies (including, for example, product development and IT systems testing); and (iv) to detect any fraud or website abuses.
If you have a savings account, we may also contact the bank of your Nominated Account to check that the payment has been received.
We may transfer such data to companies within our group, professional advisers, third party service and administration companies and any entity providing funding to us or members of our group of companies either now or in the future and their professional representatives.
b) Respond to your Enquiries: We may also collect and store some of the above information and the nature of your enquiry when you make an enquiry. We use that information for responding to your enquiry. If you contact us we may keep a record of that correspondence and if another registered user contacts us about you, your activities on this website or your postings on this website, we may collect such information in a file specific to you.
c) Fraud Prevention and Credit Risk Reduction: We may exchange information with third parties for the purposes of credit checks, fraud prevention and credit risk reduction. This information may be provided as part of our application process or as part of our ongoing monitoring of account holders.
When reviewing your record at a fraud prevention or credit reference agency, the agency will add to the record of the person searched, details of the search and the application and this will be seen by other organisations that make searches. We may also search the record of any person financially associated with an applicant, borrower, lessee or account holder.
Currently, these agencies are: a) CallCredit Limited if you are applying for a savings account and b) Experian Limited if you are applying for a loan but they may change over time. For more information on credit reference agencies, the type of information they make available to us and how they use your data, visit: http://www.experian.co.uk/crain/index.html.
You expressly agree that we may undertake a search with CallCredit Limited, the credit reference agency we use, for the purpose of verifying your identity in relation to your application for a savings account and/or Experian Limited, the credit reference agency we use to obtain information about you in relation to an application for credit facilities. To do so CallCredit and/or Experian Limited may check the details you supply against any particulars on any database (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes. A record of the search will be retained.
We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. The Bank, credit reference agencies and fraud prevention agencies will also use your records for statistical analysis about credit, insurance and fraud.
d) Legal Obligations: We reserve the right to pass information about you or your account to third parties for administrative purposes, fraud prevention, terrorism prevention, money laundering, debt tracing, preventing, investigating or fighting crime or where we are required to do so by law. We may disclose it to HM Revenue & Customs and other authorities.
We may also disclose your information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else that could be harmed by such activities. We may disclose your information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services offering.
e) Sale of Our Business: We may transfer our databases containing your personal information if we sell our business or part of it. In such circumstances, we will notify you of any change in ownership.
f) Website: We may also use information we collect about you to ensure that content from the site is presented in the most effective manner for you and for your computer. We will also use the information to measure or understand the effectiveness of advertising we send to you and others, and to deliver relevant advertising to you. We may also match the data collected from our website with third party data to produce aggregated statistics and / or to personalise the website.
g) Statistical Analysis: We and the credit reference agencies and fraud prevention agencies may use your record and those of any director, shareholder, member, partner, employee or anyone financially associated with the application (e.g. a guarantor) for statistical analysis about credit and about insurance and fraud. We shall also be entitled to collect, publish and otherwise use site analysis statistics and aggregated user data as we deem appropriate provided that you or anyone else as an individual cannot be identified from such statistics and aggregated data.
h) Customer Satisfaction Surveys: We may also use your information in relation to customer satisfaction surveys or offers of both our current and future products or services.
Why We Use Your Information
We require certain types of information to verify details for compliance with legal and regulatory requirements relating to our anti-fraud, anti-money laundering and know your customer obligations. It is also necessary in the public interest that we can verify identities and prevent fraud. If this information is not provided we cannot agree to provide a product or service to you.
Information we collect from credit reference agencies is required to help us make the best possible assessment of your overall situation before we make a decision about your application. We have a legitimate business interest in assessing the risk associated with your application.
Once you become our customer, we need to process your personal information to perform our contract with you and to provide you with the products or services you have requested. We also have a legitimate business interest in processing your personal information for the purpose of collecting unpaid loans or debt owed by you to us.
Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We have a legitimate interest in ensuring that we comply with our regulatory and legislative obligations and in resolving complaints. We will not delete personal information if it is relevant to an investigation or dispute. It will continue to be stored until those issues are fully resolved.
We also use your personal information because we have a legitimate business interest in: telling you about the various products and services we can offer; in improving our services and better understanding how our customers use them; ensuring that we are better able to personalise our services for you; understanding customer feedback; responding to customer communications in a consistent manner; and in maintaining a public profile.
We use information we collect through your use of our website because we have a legitimate business interest in understanding how our website is accessed, how it is used and any problems users have with it.
Certain types of information are more sensitive than others. This "special information" about you includes information about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometrics or religion]. We may collect and receive special information about you where you have given us explicit consent to do so. We will use this special information for the purposes of providing relevant support to you in accessing our products and services.
Automated Decision Making
We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide a savings account or other products or services to you based on anti-money laundering or credit checks. Such checks may be informed by credit scoring where we share your information with credit reference agencies, screening on databases and confirmation of your information (including by third parties). Submitting to an anti-money laundering check is necessary for us to offer you our savings account products. If this information is not provided we cannot agree to provide a savings account or other products or services to you. If you are not happy with the response you receive, you may, within one month of receiving our response, tell us the basis of your objection and ask us to arrange for the decision to be reviewed by one of our savings or credit underwriting team. We will notify you of the steps taken and of the outcome of complying with your request.
Disclosing Your Information
We may transfer your personal information:
a) To any member of our group, which means our subsidiaries, our ultimate holding company and our subsidiaries, as defined in section 1159 of the UK Companies Act 2006; and
b) To selected third parties including:
(i) subcontractors, service providers, agents, advisers and others involved in running your savings, credit, loan or leasing accounts, managing your records or processing your application. Such third parties will be required to meet our standards on processing information and security. The information we provide to them, including your information, will only be processed in connection with the performance of their function;
(ii) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to advertisers, but will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
(iii) analytics and search engine providers that assist us in the improvement and optimisation of its site;
(iv) sanctions screening, identity and credit reference agencies for the purpose of performing our customer due diligence obligations and assessing your credit score where this is a condition of us entering into a contract with you;
(v) any other parties connected with your account, application or loan (e.g. guarantors and those who help make decisions about credit and credit‐related services for you and/or the applicant and possibly directors, partners and guarantors and members of their households.)
c) To other third parties in certain scenarios as follows:
(i) in the event that we are discussing selling all or part of our business or assets, in which case we will disclose your personal data to the prospective buyer of such business or assets under suitable terms of confidentiality;
(ii) if we, or substantially all of our assets, are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
(iii) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the terms and conditions and other agreements; or to protect the rights, property, or safety of PCF BANK, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
(iv) for the purposes of our funding or securitisation arrangements;
(v) if we are defending a legal claim your information may be transferred as required in connection with defending such claim.
d) as required as part of our duty to protect your accounts, application or loan account (e.g. disclosure of your information to the UK Financial Services Compensation Scheme);
e) where required by law to do so for reasons of fraud prevention, terrorism prevention, money laundering, debt tracing, preventing, investigating or fighting crime. This may involve disclosure of your information to Government bodies.
We use the following cookies:
Strictly necessary cookies. These are required for the operation of the site. They include, for example, cookies that enable you to log in to secure areas of the site (if applicable).
Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way the site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These recognise you when you return to the site. This enables us to personalise content for you and remember your preferences (for example, your choice of language or region).
Targeting cookies. These record your visit to the site, the pages you have visited and the links you have followed. We will use this information to make the site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can block cookies by activating the setting on your browser that allows you to refuse the settings of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the site. If you would like more information about cookies, we can recommend www.aboutcookies.org and www.allaboutcookies.org as helpful resources. Both websites also provide instructions on how to reject cookies if you would like to do so.
Where We Store Your Personal Data
All information you provide to us is stored on its secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the site; any transmission is at your own risk. Once it has received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How Long We Keep Your Information
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. This will not normally exceed a maximum of 6 years from the time that no further sums are owed to us or to you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We have listed the rights you have over your information below. These rights are subject to certain restrictions and may only apply to certain types of information or processing. Should you wish to exercise or discuss any of these rights, please contact our Data Protection Officer whose details are given below.
Right of Access: You are entitled to obtain from us details concerning the processing of your personal information. This includes details of the data being processed, the purposes of the processing, any recipients of that information, the period for which the information is processed, the source of the information (if it is not provided by you), any transfers of the information and the protections we put in place to protect your information. You are entitled to a copy of the personal information we process about you (including in electronic form). Additional copies may be subject to a reasonable administrative fee.
Right to Rectification: You are entitled to have any incomplete and inaccurate personal information held by us rectified.
Right to Erasure ('be forgotten'): In certain circumstances you are entitled to have personal information erased. However, we may continue processing the information in certain circumstances. If you request that we erase your personal information we shall advise you if we consider that there are on-going grounds permitting us to continue processing your information.
Right to Restrict Processing: You can ask us to restrict the processing of personal information we hold about you in certain circumstances. We will advise you if we do not agree with your request to restrict processing and our reasons.
Right to Data Portability: Where you provide personal information to us and consent to us using it and the processing is carried out by automatic means you are entitled to receive a copy of that information in a machine-readable format and for that to be provided to another data controller, where technically possible.
Right to Object: You are entitled to object to our collection, use of and otherwise processing of your personal information where the basis for the processing is our legitimate interests or the processing is in the public interest. You may object to processing for direct marketing purposes at any time. In such circumstances we shall cease processing your personal information unless we are otherwise permitted to process the information under applicable data protection laws.
Contacting you about Products and Services
We will use your personal information so we can provide you with product details and offers that are relevant to you if you have consented to receive such details and offers or if we are otherwise entitled to do so by law.
You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
We will not provide information about you to third parties to use for their own marketing purposes unless you have given us your consent.
Data Protection Officer, PCF Bank Limited, Pinners Hall, 105‐108 Old Broad Street, London EC2N 1ER or [email protected] or telephone 020 7222 2426.
The Information Commissioner may be contacted by writing to:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow SK9 5AF
Phone: 0303 123 1113 Web-site: www.ico.org.uk