In order to process your application, we will perform credit and identity checks on you with one or more Credit Reference Agencies (“CRAs”). If you open product with us, we may also make periodic searches at CRAs to manage your account with us.

To do this, we will supply your personal data to the CRAs and they will give us information about you. This will include information from your credit application, your financial situation and financial history. The CRAs will supply to us both public (including the electoral register) and shared credit information including fraud prevention information.

We will use this information to:

• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt and any default. This information may be supplied to other organisations by CRAs.

When we complete a search for any information about you at any CRA, they will place a search footprint on your credit file that may be seen by other lenders and gambling organisations.  Where we have an existing relationship with you, we may rely upon information we already hold upon you, to assess applications by you for further lending on existing and other products we offer. This will not result in another search footprint appearing on your credit file.

If you are making a joint application, or tell us that you have a financial associate, we will assess your application based on the records of yourself and your financial associate where appropriate. You should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on yours and their files until such time as you or your financial associate successfully files for a disassociation with the CRAs to break that link.

Where you have made an eligibility enquiry or an application for a product, only where we have your permissions, will we obtain information about your credit file from the credit reference agency.  We may use your information and that of any of your financial associates to review your credit file and tell you about other similar Vanquis products and services and those of the Vanquis Banking Group that you may be eligible for. We may do so for up to three years.

We may also obtain information from your credit file and use it, only where we have your permissions, to enhance our understanding of our customers’ needs and to help us develop products and services to meet these.  This may contain credit information about you for up to seven years from the date of your last contact with us. Your credit file and your ability to obtain credit elsewhere will not be affected by this activity. You have the right to tell us to cease using your data for these purposes (see the section Your data subject rights and how to exercise them).

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal data, data retention periods and your data protection rights with the CRAs are explained in more detail on the Credit Reference Agency Information Notice (‘CRAIN’), which may be accessed via the links to the CRAs detailed below.

• TransUnion (formerly Callcredit)
• Experian
• Equifax

We may also use services from TransUnion for purposes not described in the CRAIN, such as fraud prevention and identity verification. Full details of these purposes are contained in TransUnion’s privacy notice.

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud, money laundering and terrorist financing, and to verify your identity. These checks require us to process personal data about you.

The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

Details of the personal information that will be processed include, for example:

• full name
• title
• address
• date of birth
• contact details
• financial information
• employment details
• device identifiers, including IP address
• vehicle details

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Automated Decisions

• As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk if our processing reveals your behaviour to be consistent with money laundering or known fraudulent conduct, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity. You have rights in relation to automated decision making: if you want to know more contact us using the details below.

Consequences of Processing

• If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.
• A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. If you have any questions about this, contact us on the details below.

Data Transfers

Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place.

Your Rights 

• Your personal data is protected by legal rights, which include your rights to object to our processing of your personal data, request that your personal data is erased or corrected, and request access to your personal data. 
• For more information or to exercise your data protection rights, contact us using the contact details below. 
• You also have a right to complain to the Information Commissioner’s Office, which regulates the processing of personal data.

With fraud prevention or law enforcement agencies, in the event false or inaccurate information is provided and fraud or money laundering is identified. We and other organisations will also access and use this information to prevent fraud and money laundering, for example when checking details on applications for credit and credit related and other facilities, managing credit and credit-related accounts or other facilities, recovering debt, checking details on proposals and claims for all types of insurance, and checking details of job applicants and employees.

We will request that information held by credit reference and fraud prevention agencies, other industry participants and the Motor Insurance Database be disclosed to us and other organisations to, for example:

• Prevent fraud and money laundering, for example by checking details on applications for credit and credit-related or other facilities, proposals and claims for all types of insurance and job applications and employee records

• To identify you when you contact us or visit our website, and to prevent and detect fraud or money laundering. This may involve the use of voice detection technology to analyse recordings of your telephone calls with us
• Recover debts that you owe and trace your and the goods whereabouts
• Manage credit accounts and other facilities
• Verify your identity
• Make decisions on credit, insurance and other facilities about you, your financial associate(s), members of your household or your business
• Carry out statistical analysis to help with decisions about credit and account management

Checking the vehicle you have selected is fully insured under a comprehensive insurance policy.