IMPORTANT NOTICE - USE OF YOUR INFORMATION
We are PSA Finance UK Ltd (company number 01024322) and we are the data controller in respect of your personal information. If you have any queries about our handling of your personal information, you can contact us by writing to our Data Protection Officer at 61 London Road, Redhill, Surrey RH1 1QA or by email to firstname.lastname@example.org.
This policy explains how we will use the personal information that you provide to us or that we obtain about you in the ways described under ‘When we collect personal information’. This policy applies if you are acting as a guarantor for a customer of ours.
If you are a driver of one of our vehicles by virtue of your employment and your employer is a customer of ours, we will be the data controller in respect of any personal information that your employer gives to us about you and this policy applies, where applicable.
This policy was last updated on 3 October 2019.
When applying for finance
Upon visiting a dealer within our network (which are dealers with a Peugeot, Citroen or DS franchise of trade under Autobank Financial Services), using a broker or when you use our website (https://www.psa-finance.co.uk) you may wish to obtain a proposal for finance. The dealer or broker will provide us with personal information provided by you, or we will ask you for your personal information, in order to assess your creditworthiness and affordability for finance in accordance with our credit policy. Please see ‘Personal information we collect’ for further details on the types of data we collect about you.
When entering into an agreement with us
When entering into an agreement with us you supply us with personal information. We’ll also gather information about you during your agreement such as your payment history, correspondence between you and us (by letter, email, telephone, online or by social media). If you ask us to have contact with a third party on your behalf, we’ll also process information about them, such as their relationship with you, their name and contact information and payment information if they make a payment on your behalf.
When you contact us
We’ll keep copies of correspondence if it is material. We may also record and store conversations between you via different methods such as online, (for example email and web chat) or by telephone. We’ll keep it for a limited period. We’ll keep a record on our systems of any contact we have with you, but we won’t keep or record anything that’s unnecessary.
When using our websites
When you visit one of our websites (https://www.psa-finance.co.uk, https://myfinance-bpf.mpsa.com or https://personalcontracthire-dsautomobiles.co.uk/) we collect industry standard log data that will provide us with information about your visit. This includes but is not limited to information such as your location, browser type, operating system, which pages you have visited and how you have reached our website. We use this information to provide you with relevant information and ensure that our site is working properly. We may ask for further information from you should you report a problem with our websites. If you apply for finance online, we may ask you to complete electronic identification sections.
When you register for a My Finance account
In order to manage your account online you are required to register for My Finance. When you register an account we will ask for personal information to identify you as the account holder along with your email address and password.
Once registered, you have the ability to amend details of your agreement such as your address, bank details and payment date. We will collect this information to update your account information for the purpose of your agreement.
When entering into a web chat conversation
We may from time to time offer web chat services to assist in answering certain enquiries. This is an optional online service and is available through MyFinance.
When completing a survey
Following interaction with our teams we may send you a survey to provide you with the opportunity to give feedback on our performance and your satisfaction. Should you complete this survey we will collect the data provided, including any comments, to help improve our service to you.
When receiving an email
In order to perform our contract with you, we may occasionally send you (or third parties on your behalf) emails if you have asked us to.
The personal information we collect from the activity described above is as follows:
Personal information you give to us:
This is information about you that you give to us via your dealership, broker or online. This consists of the following categories of information:
- date of birth
- residential address and address history
- contact details such as email address and telephone numbers
- financial information
- employment details
- vehicle details
- information contained in identification documents, including passport, driving licence and household bills
- information contained in verification documents, including proof of home ownership, proof of disability and wage slip
We may also collect sensitive personal data about you in relation to our regulatory obligations including to treat customers fairly and, separately, our provision of ancillary products and services to you (including liaising with your insurers for claims handling purposes). Where required, we will ask for your specific consent to use your sensitive personal data.
Personal information we may receive from other sources:
We obtain certain personal information about you from your dealer or broker (where applicable) and credit reference and fraud prevention agencies. Please see ‘Use by credit reference agencies’ and ‘Use by fraud prevention agencies’ below for further information. We may also obtain information from your vehicle’s devices such as telematics and geolocation data.
If you fail to provide us with any information that we request from you, we will not be able to proceed with the credit reference and fraud prevention checks described below and, subsequently, we will not be able to consider your application nor propose an offer to you.
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are as follows:
Performance of the contract with you or to take steps to enter into it. This includes verifying your identity, assessing your application, underwriting and claims handling (where you apply for insurance), and, if we enter into an agreement with you, administering the agreement including tracing your whereabouts to contact you and recover debt and to provide you with the service under that agreement (i.e. managing your account, communicating with you, providing updates on the status of your account, dealing with any complaints and notifying you of any changes to this statement). When you use our website, we’ll process your information to enable you to make use of our site.
Legitimate interests or that of a third party. This includes:
- sending you information about products, services, offers, special promotions or competitions by post;
- marketing activities (other than where we rely on your consent) e.g. to tailor marketing communications or send targeted marketing messages via social media and other third party platforms;
- creating a better understanding of you as a customer;
- analysis to enhance and personalise your customer experience including asking you about your experiences;
- assessing your application and lending and insurance risks;
- checking insurance proposals and claims;
- making decisions on credit, hire arrangement, insurance and other services, about you or your financial associate(s), members of your household or your business;
- preventing fraud and money laundering, and to verify your identity, in order to protect our business and to comply with laws that apply to us;
- carrying out statistical analysis to help with decisions about credit and account management;
- recovering debt and tracing your whereabouts;
- monitoring communications between us (or via our contact centres) to prevent and detect crime, to protect the security of our communications, systems and procedures, and for quality control and training purposes;
- contacting you to ask you to participate in satisfaction surveys and to undertake and analyse the results of those surveys, this is to allow us to benchmark our services and evaluate new and existing products and services;
- passing your details to another dealer if your supplying dealer is no longer active or no longer has a contract in place with us;
- for market research in order to continually improve the products and services that we and our dealers/ brokers deliver to you;
- network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access; and
- management of queries, complaints, or claims.
Compliance with a legal obligation. This includes things such as verifying your identity, establishing and defending of our legal rights, activities relating to the prevention, detection and investigation of crime, to conduct credit, fraud prevention and anti-money laundering checks, assisting HMRC, the police, the Driver and Vehicle Licensing Agency (DVLA) and other public authorities or criminal investigation bodies and for compliance with our legal and regulatory responsibilities. This may also include processing special categories of data about you, for example for our compliance with our legal obligations including to treat customers fairly. This also includes when you exercise your legal rights under data protection law.
- if we introduce you to third party insurers we may ask you for sensitive personal data (such as information about your health) and criminal convictions in order to assess risk. We will not use such sensitive personal data about you or others except for the specific purpose for which you provide it and to provide the services described in your policy documents. You will have been asked for your explicit consent for us to use this information when you submitted your application. Please ensure that you only provide us with sensitive information about other people with their agreement; and
- during the course of our relationship with you, you might need to disclose to us sensitive personal data about your personal circumstances so that we can provide support to you. If this is the case, we’ll ask you for your explicit consent for us to use this information; and
- you have given us your consent to contact you with marketing information about our goods and services and promotions and offers and/or to share your information with our group companies and/or our recommended third party partners (who will be identified to you at the time we ask for your consent) for them to contact you with marketing information about their products and services.
You may withdraw your consent at any time. Please see ‘Your Rights’ below for information about how to do this.
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (CRAs). To do this, we will supply your personal information to CRAs and they will give us information about you. This will include (but not limited to) information from your credit application and about your financial situation and financial history, directorship searches and other relevant commercial or corporate checks. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
We will use this information to:
- assess your creditworthiness and whether you can afford to take the product you have applied for;
- 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. This information may be supplied to other organisations by CRAs.
If you are making a joint application, asking us to appoint a guarantor on your behalf, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before making an application to us. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
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 information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.experian.co.uk/crain or www.equifax.co.uk/crain or www.callcredit.co.uk/crain (please note that the Credit Reference Agency Information Notice is the same for each of the CRAs).
The CRAs we use are as follows:
0344 481 0800
0800 014 2955
0330 024 7574
Before we provide services, goods or financing to you, or allow you to act as a guarantor, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process your information. If we or a fraud prevention agency, as a result of our processing of your personal data, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested 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, please contact the appropriate fraud prevention agency using the details provided below.
0300 123 2040
We disclose your information to the following third parties:
- Our group of companies. We are members of the PSA Peugeot Citroen group of companies. We may pass on your details to any company within our group. This includes Peugeot Motor Company plc, Citroen U.K. Ltd, Banque PSA Finance SA, Peugeot SA, Santander Consumer UK plc and Santander UK plc.
- Our group of companies or suppliers whom will use your information to better understand you as a customer and for reporting and analysis purposes to assist in the development and improvement of existing and new products and services.
- Credit reference agencies and fraud prevention agencies (as detailed above).
- Insurers, third party underwriters and reinsurers where you have applied for an insurance product involving us.
- Your dealer or broker (or any dealer or broker that acquires your dealer’s or broker’s business) to assist us with administering your application and your agreement with us. Their privacy notice will apply to any processing of information they carry out about you.
- When you ask us to, a different dealer or broker to provide a settlement figure to them.
- When you ask us to, your insurer in connection with your insurance policy and any claim.
- Third party suppliers engaged by us to undertake services on our behalf, including debt collecting agencies to recover monies owed to us, vehicle recovery services and fine administration. You can find a list of the third parties we use at https://www.psa-finance.co.uk/partners-suppliers
- Third parties acting on our behalf, such as back-up and server hosting providers, IT software and maintenance providers and their agents and third parties that provide income verification services, affordability checks and communication fulfilment services.
- Third parties that you asked us to deal with on your behalf this may be a friend or relative to assist you in the management of your account or it could also be a third party advisor or debt manager.
- Law enforcement agencies in order to detect, investigate and prevent crime (we or any fraud prevention agency may pass your information to law enforcement agencies).
- Any third party to whom we sell your debt. If we do this, you will be notified and that third party will become the data controller of your information.
- Courts in the United Kingdom or abroad as necessary to comply with a legal requirement, for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations.
- Any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of funding arrangements, a merger, re-organisation, or similar event.
- Our professional advisors, auditors and regulators as necessary.
We may also share data that doesn’t identify you with third parties, this includes data from your vehicle’s telematics device and your vehicle’s chassis information.
During the course of the agreement, you may ask us to deal with or communicate with a third party on your behalf. If this is the case we’ll store limited information about the third party on our systems. The information will be removed at your or their request or otherwise will be retained in the same way as your other account information. You can terminate the authorisation at any time. We will not use your authorised third party’s information for the purposes of marketing.
As part of our processing of your personal information, we may take decisions by automated means.
Your information will be used to assess your credit risk using an automated decision-making technique called ‘credit scoring’. Various factors help us to assess the risk; a score is given to each factor and a total credit score obtained, which will be assessed against a confidential pre-set pass score. Your credit risk is not determined solely from an automated decision, and we take other factors into account (such as the finance product, your loan to value rate, the duration of your contract and the particular vehicle you’re seeking to fund). You may contest a decision made about you by automated means, please contact us by emailing email@example.com or writing to us at the address detailed above.
In regard to fraud prevention checks, you may automatically be considered to pose a fraud or money laundering risk if our processing reveals your behaviour to be:
- consistent with that of known fraudsters or money launderers;
- inconsistent with your previous submissions; or
- you appear to have deliberately hidden your true identity.
We store your information on servers located within the European Economic Area (EEA). The third parties listed under ‘Use by third parties’ may be located outside of the EEA or they may transfer your information outside of the EEA. Those countries may not have the same standards of data protection and privacy laws as in the UK. Whenever we transfer your information outside of the EEA, we impose contractual obligations on the recipients of that information to protect your personal data to the standard required in the UK or requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing. Any third parties transferring your information outside of the EEA must also have in place appropriate safeguards as required under data protection law.
If your application for finance is declined or if your application is accepted but you do not proceed, we keep your information for 7 years or as long as necessary to comply with our legal obligations. If your application is accepted and you proceed, we hold your information for 7 years from the date at which your agreement ends or as long as necessary thereafter to deal with any queries you may have or our legal duties.
Credit reference agencies will retain the account information that we give to them for 6 years after your account is closed (please see ‘Use by credit reference agencies’ for more information about the information that we give to them).
For some product features such as payment waiver, contract hire plus or finance lease plus, we insure our risk with our group insurance company in Malta (PSA Insurance Europe Limited). They will retain your data for a period necessary to comply with their legal and regulatory duties which could be a period of up to 12 years.
Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your information can be held for up to 6 years.
We may hold your information for a longer or shorter period from that described above where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law; and
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website and any transmission is at your own risk. Once we have received your personal information, we put in place reasonable and appropriate controls to ensure that it remains secure against accidental or unlawful destruction, loss, alteration, or unauthorised access.
Where we have given (or where you have chosen) a password which enables you to access your My Finance account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to change your password regularly.
Our website may contain links to other websites run by other organisations. This policy does not apply to those other websites‚ so we encourage you to read their privacy statements. We cannot be responsible for the privacy policies and practices of other websites even if you access them using links that we provide. In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 30 days after we have received this information or, where not required, after we have received your request.
- To be informed about the processing of your information. This is what this privacy notice sets out to do.
- Accessing your personal information. You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address above. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Correcting and updating your personal information. The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know by contacting us on the details provided above. We encourage you to keep us up to date in changes in your information to keep it safe and to keep your credit file up to date and consistent as it could affect other lender’s assessments of any applications you make.
- Withdrawing your consent. Where we rely on your consent as the legal basis for processing your personal information, as set out under ‘Use of your information’, you may withdraw your consent at any time by contacting us using the details above. If you would like to opt out of marketing from us, please follow the unsubscribe instructions in the relevant marketing communication. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
- Objecting to our use of your personal information and automated decisions made about you. Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purposes, as set out under Use of your information, you may object to us using your personal information for these purposes by emailing or writing to us at the address above. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data. You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool, if applicable. You may also contest a decision made about you based on automated processing by emailing or writing to us at the address above.
- Erasing your personal information or restricting its processing. In certain circumstances, you may ask for your personal information to be removed from our systems by emailing or writing to us at the address above. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request. You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. We may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
- Transferring your personal information in a structured data file. Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with a contract we have with you, you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
- You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
- Complaining to the UK data protection regulator. If you have concerns about the way we have handled your personal information, we encourage you to contact us and we will seek to resolve any issues or concerns you may have. You will find our contact details above. You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details.
If you want to exercise any of these rights, please contact us using the details above.
As we are continuously looking for new and innovative ways to respond to the needs of our customers, this policy may change over time. Any changes will be notified to you by posting an updated version on our website and/or by contacting you by email or post. Any changes will take effect 7 days after the date of our email or letter or the date on which we post the modified terms on our website, whichever is the earlier.