GDFC Full Privacy Notice – February 2018
This Policy applies in respect of hiber Limited (Company number: 10028311); GDFC Services plc (Company number: 08271985), GDFC HoldCo Ltd (Company number: 08272183), and GDFC Assets Ltd (Company number: 08272354) each Registered in England, registered office: Imperial House, 15 – 19 Kingsway, London WC2B 6UN
Using information about you:
1. In order to provide you with products and services we need to collect, use, share and store personal and financial information about you. This includes information which we:
- obtain from you or third parties, such as Green Deal Providers, Green Deal Assessors, employers, energy suppliers, credit reference agencies (who may check the information against other databases, public or private, to which they have access), or fraud prevention agencies. This information may come from your interactions with us or them, for example through applying for a Green Deal Plan or another consumer finance product; or
- ascertain from the way in which the loan is administered and managed, for example, information relating to the payments which are made to your account with your energy supplier
2. Where you provide personal and financial information about others (such as dependants, other family members and a joint energy account holder, where applicable) you confirm that you have their consent or are otherwise entitled to provide this information to us and for it to be used in accordance with this notice.
3. You authorise us to process and disclose your information relating to lifestyle, ethnic background, income and criminal offences alleged or otherwise that is provided by you or that we obtain from third parties for the purposes of:
(a) assessing and identifying products and services;
(b) applying for a product of an insurance company/organisation or finance provider;
(c) detecting and preventing crime (including without limitation fraud and money laundering);
(d) transferring your information in accordance with Paragraph 11(f); and
(e) otherwise meeting our obligations under this privacy notice.
4. Subject to applicable law, we and other companies in the Green Deal Finance Company (“GDFC”) Group may use your information to:
(a) manage your Green Deal Consumer Credit Agreement;
(b) carry out regulatory checks and meet our obligations to our regulators;
(c) protect ourselves against harm to our rights and property interests;
(d) develop and improve our services through assessment and analysis of the information (including credit or behavioural scoring (or both), market and product analysis, and market research);
(e) prepare high-level anonymised statistical reports which would contain details such as, for example, the percentage of people paying their energy supply by direct debit or the percentage of people changing energy supplier. We compile these reports from information about you and others. The information in these reports is never personal and you will never be identifiable from them. We may share these statistical and anonymised reports with third parties including non-GDFC companies;
(f) prevent and detect fraud, money laundering and other crime (such as identity theft);
(h) improve the relevance of marketing messages we may send you (which you can opt out of as stated below).
5. We may monitor or record any communications between you and us including telephone calls. We will use these recordings to check your instructions to us, to analyse, assess and improve our services to customers, and for training and quality purposes.
6. We may send you messages by post, telephone, text, email and other digital methods (including new methods that may become available in the future) about products and services (including those of others) which may be of interest to you – these are marketing messages. You can ask us to stop or start sending you marketing messages at any time by writing to us.
7. We may give your information to and receive information from credit reference agencies and fraud prevention agencies. We and other organisations may access and use this information to prevent and detect fraud, money laundering and other crimes and to make credit assessments. Examples of circumstances when your information or information relating to your partner or other members of your household may be shared include:
(a) checking details on applications for products and services, and credit and credit related, or other, facilities;
(b) managing credit and credit-related accounts or facilities;
(c) recovering debt;
(d) checking details on proposals and claims for all types of insurance;
(e) checking details of job applicants and employees; and
(f) making enquiries when you ask for any lending products.
8. Information held about you by the credit reference agencies may already be linked to records relating to your partner or members of your household where a financial “association” has been created. Any enquiry we make at a credit reference agency may be assessed with reference to any “associated” records. Another person’s record will be “associated” with yours when:
(a) you make a joint application;
(b) you advise us of a financial association with another person; or
(c) if the credit reference agencies have existing linked or “associate” records.
This “association” will be taken into account in all future applications by either or both of you and will continue until one of you applies to the credit reference agencies and is successful in filing a “disassociation”.
9. Credit reference agencies may keep a record of our enquiries and may record, use and give out information we give them to other lenders, insurers and other organisations. If false or inaccurate information is provided and fraud is identified details may be passed to fraud prevention and credit reference agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
- Checking details on applications for credit and credit related or other facilities;
- Managing credit and credit related accounts or facilities;
- Recovering debt;
- Checking details on proposals and claims for all types of insurance;
- Checking details of job applicants and employees
Please contact us at [email protected] if you want to receive details of the relevant fraud prevention agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
10. We may use credit scoring and automated decision making systems when considering any application from you for lending products and managing your loan, which may involve further searches at credit reference agencies which may affect your ability to obtain credit.
11. We may disclose information about you and the management of the loan to the following, wherever located in the world:
(a) other companies within the hiber Group (that are subject to a similar duty of confidentiality);
(b) our partners, and companies and organisations that provide marketing services to us at our request and under our direction (that are subject to a similar duty of confidentiality);
(c) other companies or organisations that assist us in reviewing your financial position, to process transactions in the exercise of our discretion under the loan where applicable or arising from recommendations made by us to you; for example, to obtain product quotes and recommend and complete a product purchase with a product provider;
(d) our service providers and agents (including their sub-contractors). This may include, for example, where we pass your details to someone who will print your statements; companies and organisations that assist us to process transactions under the loan;
(e) anyone to whom we may transfer our rights and/or obligations under the loan;
(f) any third party as a result of any restructure, sale or acquisition of any company within the hiber Group, provided that any recipient uses your information for the same purposes as it was originally supplied to us and/or used by us;
(g) your advisers (including, but not limited to, accountants, lawyers or other professional advisers) where authorised by you;
(j) where the hiber Group has a duty to do so, or if law or regulation allows us to do so.
12. Where we are sharing information with organisations in another jurisdiction, we will ensure they agree to apply equivalent levels of protection as we do. If this is not possible – for example because we are required by law to disclose information – we will ensure the sharing of that information is lawful.
14. If you end your relationship with us, or if your application for a loan or product is declined or you decide not to go ahead with it, we will keep your information afterwards. We may also continue to collect information from credit reference agencies to use after your account is closed or your relationship with us ends. We will do so for as long as we are allowed to for legitimate business purposes, to help prevent fraud and other financial crime, and for other legal and regulatory reasons.
15. You can ask for a copy of your information we hold about you by writing to us.