Legal and Privacy Notice
Last reviewed 19th February 2019
This Privacy Notice sets out what information The Loans Engine (TLE) will collect about you and how we use and protect that information.
This Privacy Notice applies to the processing of personal data of all applicants who are party to the loan application. By progressing your enquiry, you are confirming that you (and any co-applicant) agree to the conditions set out in this Privacy Notice and that you have permission to provide personal data on behalf of your co-applicant.
This Privacy Notice was last updated 19th February 2019. We may make changes to this Privacy Notice from time to time and any changes will be published on our website. If we make any significant changes to the way we use your personal information that may impact your data rights, we will notify you.
Call are recorded for training and monitoring purposes.
This Legal and Privacy Notice, and your access to and use of our website is governed by and interpreted in accordance with the laws of England and Wales.
About Central Loans Limited
The Loans Engine is a trading name of Central Loans Limited. We are a broker not a lender and are authorised and regulated by the Financial Conduct Authority for regulated mortgage and consumer credit activity.
- Registered in England and Wales 4205508
- Registered Office: St Crispins House, Duke Street, Norwich, NR3 1PD
- Registered with the Information Commissioner's Office - Registration number Z5775723
- Financial Conduct Authority - Firm Reference Number 708606
- VAT number 765 3535 12
Central Loans Limited is a member of the Association of Finance Brokers (AFB). For more information, visit their website: www.theafb.net
What information do we collect about you?
During the loan enquiry / application process, we may collect personal and financial information from you including (but not limited to):
- name, address history & contact information (telephone number(s) and email addresses);date of birth, marital status & nationality;
- property details and value (including 2nd homes and Buy-to-lets where relevant);
- household Income, employment type and history;
- details about your monthly expenditure, financial circumstances and requirements; and
- credit and mortgage information including credit reference agency data.
Special categories of data
We do not request ‘special categories’ of data (health / medical records, etc…) during the application process, however, if sensitive information is provided to us, we will ask for your explicit consent prior to recording it. As part of application process, the lender may invite you, on a voluntary basis, to disclose information that would enable them to assist you in the loan process in making an informed borrowing decision, and to ensure its lending decision is informed and responsible.
How do we collect the information about you, and who provides it?
Your data may be provided to us by:
- You or your co-applicant through our online application, phone calls, emails and/or in the form of physical documents;
- Introducing partners, whose websites you may have visited in order to make an enquiry; or
- Your Introducing financial adviser or mortgage broker, acting on your behalf
Alternatively, we may request your personal data from relevant third parties, for example; property surveyors, existing mortgage providers, your financial adviser/mortgage broker and Credit Reference Agencies (CRA).
Why do we collect your information and how will we use it?
- In order to provide our service – (in legal speak, as a necessity to perform our contract with you), we will process your personal data to:
a) Assess eligibility and suitability of loan products offered by lenders on our panel;
b) Process your application and arrange its completion;
c) Carry out credit reference agency searches;
d) Keep your Introducer (if any) informed about the progress of your loan application; and
e) Electronically verify your identity.
Such processing is a requirement of the service we provide in sourcing and arranging the finance you have requested. If you do not agree to how we will use your information we will not be able to provide our service.
- In order to comply with the laws and regulations that apply to TLE, for example:
a) to inform fraud prevention and/or law enforcement agencies where fraud or money laundering is identified or suspected; or
b) to obtain or retain appropriate records, for example evidence of:
- Suspected fraud or money laundering;
- Mortgage advice;
- Proof of your identity:
- Complaints investigations and outcomes.
- In the course of running our business – (in legal speak, where we have a legitimate interest to do so –i.e. processing that isn’t strictly necessary for providing our service but is important for us as a business), including:
a) to improve our products and services;
b) to record and respond to complaints;
c) to generate statistical analysis and research; and
d) where applicable, to contact and inform you of the end of your loans initial rate period.
- Where you have given your consent– we will ask for your consent for us to keep you informed about service and products and updates to them.
- Where there is a vital interest to do so - In other words we may pass your information onto relevant agencies such as the Police where we believe there is a risk to life.
When you enquire, our initial credit search which is used to assess eligibility and generate your loan quote, is a ‘soft’ search (enquiry search) which does not impact upon your credit rating. This type of search is recorded as a multi-footprint “SQ” Search Quotation which you will be able see on your credit report, however other credit providers will not be able to take these into account when deciding whether to offer you credit in the future. The Credit Reference Agency (CRA) will record details of the search whether or not your application proceeds.
If you decide to proceed with a loan application we will perform an ‘Application Search’ on behalf of the lender, we will do this only once we have received your signed paperwork.
An application search can affect your credit rating as it may be taken into account by lenders when deciding whether to lend you money. In certain circumstances, for example if you decide to proceed with a different lender during the application process, it may be necessary to complete more than one application search.
Where you have made an enquiry in joint names with a spouse or financial associate and we have carried out a credit search, a financial association will be created between the applicants if one does not already exist.
CRA data will be used to by us to verify your identity, assess product suitability and your eligibility for loans we offer. Lenders may also use the information in assessing your application, to manage your account and recover debts
The Information, shared between to us and the CRAs, about you and those with whom you are linked financially, may also be used to trace and recover debts, and prevention of criminal activity.
Further information on how CRAs use, store and retain personal data and how to contact them, can be found at https://www.equifax.co.uk/crain.html.
Who might we share your information with?
We will share some or all of the information obtained during the application process with prospective lenders in order to assess your eligibility and process your application to completion. A list of prospective lenders can be found in our ‘Terms of Business’ or on our website.
Where your personal data has been shared with a lender they will process the data in line with the conditions of this notice, otherwise, the lender will inform you of how they process your personal data. You can find links to our lenders websites and their own privacy notices on our own website using the following links:
For Residential and Buy to let lenders - click here
For Bridging and Commercial lenders - click here
We may need to contact your mortgage provider, property surveyors, accountant, and/or any other relevant third party, in order to gather evidences that we need to support your application as required by lenders’ criteria. The information that is provided to each is limited to only what is required to grant the information request.
Credit reference agencies (CRAs)
We will provide your personal data to credit reference agencies to obtain credit and electoral roll information required to assess your eligibility for loan products available through the lenders on our panel. We only provide CRAs with your name, address (including previous addresses) and date of birth in order for them to supply us with your credit file.
Fraud prevention agencies
If you give us false or inaccurate information and we suspect or identify fraud, we will record this and may pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
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.
Introducers and financial advisors
We will keep your introducer (if applicable) informed of the progress of your application. We will also share information requests and documentation relating to the application with any financial advisor or mortgage broker that is acting on your behalf.
Other third parties to improve our service
We may ask you to provide feedback upon successful completion of your loan application using a third party online provider. We only provide them with your name and email address in order to provide you with a link to the feedback service.
Third parties that assist us in managing promotional email communications
We use an automated marketing platform to send promotional emails (where you have consented to this), requiring us to temporarily store your name and email address on their system. Third parties selected are GDPR compliant and do not store data outside of the European Union.
How long do we keep your information for?
Your personal data will be retained by us in the order to process your enquiry and arrange finance for you, in line with the table below:
Stage of application / Processing activity
What Personal data is retained
How long do we hold it?
Why do we retain it?
You have made an enquiry but we have not conducted a credit search or arranged finance for you.
Personal, contact information and basic loan application data.
6 months from the end of the enquiry.
In order to contact you and attempt to help to arrange finance for you.
You have made an enquiry and we have completed a credit search but not arranged finance for you.
Personal, contact information, full loan application data including credit search data.
12 months from the end of the enquiry.
In order to contact you and attempt to help to arrange finance for you. To help resolve complaints that may arise.
We have provided mortgage advice.
Personal and contact information, full loan application data including credit search data. Loan information and records of mortgage advice provided.
3 years from the end of the enquiry.
To meet our regulatory and legal obligations to keep accurate records.
We have successfully arranged finance for you.
Personal and contact information, full loan application data including credit search data. Loan information and records of mortgage advice provided
3 years from the end of the contractual loan term.
To investigate and resolve complaints/defend legal claims, and to notify you of the end of your fixed rate product period that we arranged for you.
In addition, where certain activities have taken place some of your personal data may be retained by us independent of the data above for the following purposes and durations:
What Personal data is retained
How long do we hold it?
Why do we retain it?
Completing due diligence checks on behalf of the lender or reporting suspicious activity
Evidence of proof of identity, income and address (where we have arranged finance).
Records of suspicious activity Investigations and external reports to fraud prevention agencies
5 years from end of enquiry or from date of suspicious activity report
To comply with our legal obligations to prevent financial crime.
Investigating and responding to complaints.
Records of complaint investigation notes, supporting evidence including loan application data, copies of documents and records of communications.
3 years after end of contractual loan term.
To comply with our regulatory obligations and to able to identify and respond to duplicated claims or complaints made against us.
Sending promotional information and updates regarding our service and products.
Personal contact details.
While we have your consent and you are happy to continue to receive updates.
To keep you informed of our services and changes to products that may be of interest to you
Your data protection rights
Your personal data is protected by legal rights, which include:
- The right to be informed - You are entitled to know how we will use your personal data. This privacy notice is designed to meet your right to be informed.
- The right to access - You are entitled to obtain a copy of your personal data and other supplementary information.
- The right to rectification - You are entitled to have inaccurate personal data corrected, or completed where it is incomplete.
- The right to erasure – In some circumstances, you are entitled to have your personal data deleted. This is not an absolute right, please contact our Data Protection Officer for further information.
- The right to restriction – In some circumstances, you are entitled to limit (supress) the use of your personal data. This is not an absolute right, please contact our Data Protection Officer for further information.
- The right to portability - You are entitled to obtain your personal data in a structured, commonly used, ‘machine readable’ format which allows you to transfer that data easily and securely electronically. This only applies to personal data collected from you using automated means (for example filling out our online enquiry form).
- The right to object – In some circumstances, you are entitled to object to the processing of your personal data. This is not an absolute right, please contact our Data Protection Officer for further information. However, you do have the absolute right, at any time, to stop us processing your personal data for direct marketing purposes.
If you wish to exercise any of the above rights please contact our Data Protection Officer as set out in the Contact Us section below. You should expect to receive a response within a month (30 days).
We may require further information to enable us to handle your request, for instance to verify your identity or to evidence inaccuracy of data held. In these circumstances you should expect to receive a response within a month of us receiving the additional information.
You also have a right to complain to the Information Commissioner's Office (https://ico.org.uk/) which regulates the processing of personal data.
How do we keep your data secure?
We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:
- Company security and Data protection policies and standards
- Staff training and awareness
- Role based access controls to prevent unauthorised access to the information
- Password protection of customer documents
- Anti-malware technologies
- Security monitoring and testing
- Secure archiving and deletion
- Compliance with industry regulation and legislation
- Telephone: 01923 280000
- The Loans Engine, 1st Floor, Building 2, Axis, Rhodes Way, Watford, WD24 4YW
- E-mail: firstname.lastname@example.org
For more information, or to exercise your data protection rights, please contact our data protection officer using the details above or by email at DPO@theloansengine.co.uk
If you are unhappy about how your personal data has been used, further information about our complaints procedure can be found on our website here