Privacy Policy.
This notice explains how Keys Premium Finance (2006) Ltd (referred to in this notice as Keys, we or us) collects and uses information about directors or partners of accountants and insurance brokers who enter into finance facility agreements with Keys.
This notice covers the following:
Clauses
1. Contact details
2. What is personal data?
3. How do we collect personal data?
4. What information do we collect?
5. How do we use your information?
6. What is the legal basis that permits us to use your information?
7 What happens if you do not provide the information that we request?
8 How do we share your information?
9 How do we keep your information secure?
10 For how long do we keep your information?
11 Your rights in relation to your information.
12 Complaints.
1. Contact details
Our contact details are as follows:
Address:
Suite F
, First Floor,
Block 1
, Forestview
, Purdy’s Lane
, Belfast
, BT8 7AR.
Telephone: +44 (0) 28 90660791
2. What is personal data?
Personal data is any information that tells us something about you. This could include information such as name, contact details or date of birth
3. How do we collect personal data?
From you when you contact us to request a professional fee finance facility and during our relationship with you; and from searching public records, such as companies house, to help us verify your identity.
4. What information do we collect?
- Professional contact details such as name, title, address, telephone number and email addresses;
- Identity verification documents for due diligence purposes.
- Information about your firm such as financial information including accounts.
- Details required for Money Laundering Regulations Compliance.
5. How do we use your information?
We use your information for the following purposes:
- to verify your identity
- to analyse the operation of your business accounts and make underwriting decisions;
- for the prevention of fraud and money laundering and other regulatory obligations; and
- for the purposes of debt recovery.
6. What is the legal basis that permits us to use your information?
Under data protection legislation we are only permitted to use your personal data if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your information:
- Where we need to comply with a legal obligation; and
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.
7. What happens if you do not provide the information that we request?
We need some information so that we can comply with our legal obligations. For example, we need information from your identity documents to satisfy our money laundering regulatory obligations.
Where information is needed for these purposes if you do not provide it, we will not be able to perform our contract with you and may not be able to offer lending services or continue with our relationship. We explain when this is the case at the point where we collect information from you.
8. How do we share your information?
We share your personal data in the following ways:
- With any guarantor of your liability under any agreement we have with you, so that they can assess their obligations to us or so we can enforce such obligations against them under the relevant guarantee and/or indemnity;
- With any advisers acting on our behalf, so that they can provide their services to us;
- With other companies within our group structure including Keys Premium Finance Ltd and Keys Premium (2001) Ltd;
- With our bank, or any business providing factoring or discounting facilities to us or anyone else to whom we novate or transfer our rights or duties under any agreement with you; and
- With any person to whom you have agreed your information may be given or to whom we have a legal obligation or public duty to disclose such information.
Where we share your personal data with third parties, we ensure that we have appropriate measures in place to safeguard your personal data and to ensure that it is solely used for legitimate purposes in line with this privacy notice.
9. How do we keep your information secure?
Protecting personal information held in hardcopy or electronic form with locked cabinets, password protected secure IT platforms and multi-factor authentication. We also operate an incident response plan to ensure that any security concerns are identified and addressed promptly.
Ensuring that information containing personal data, and in particular any sensitive personal data, will be handled appropriately.
We will ensure access to personal data is restricted to employees working within our group on a need to know basis. Training will be provided to any employees working within the group who need access to your personal data to ensure it is secured at all times.
10. For how long do we keep your information?
As a general rule we keep your personal data for the duration of your firm’s relationship with us and for a period of seven years after the relationship ends. However, where we have statutory obligations to keep personal data for a longer period or where we may need your information for a longer period in case of a legal claim, then the retention period may be longer. Full details of the retention periods that apply to your information are set out in our Data Retention Policy which is available on request.
11. Your rights in relation to your information
You have a number of rights in relation to your personal data; these include the right to:
- be informed about how we use your personal data;
- obtain access to your personal data that we hold;
- request that your personal data is corrected if you believe it is incorrect, incomplete or inaccurate;
- request that we erase your personal data in the following circumstances:
- if Keys is continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected;
- if Keys is relying on consent as the legal basis for processing and you withdraw consent;
- if Keys is relying on legitimate interest as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing;
- if the personal data has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation); or
- if it is necessary to delete the personal data to comply with a legal obligation;
- ask us to restrict our data processing activities where you consider that:
- personal data is inaccurate;
- our processing of your personal data is unlawful;
- where we no longer need the personal data but you require us to keep it to enable you to establish, exercise or defend a legal claim; or
- where you have raised an objection to our use of your personal data;
- request a copy of certain personal data that you have provided to us in a commonly used electronic format. This right relates to personal data that you have provided to us that we need in order to perform our agreement with you and personal data where we are relying on consent to process your personal data;
- object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data; and
- not be subject to automated decisions which produce legal effects or which could have a similarly significant effect on you; and
If you would like to exercise any of your rights or find out more, please contact info@keysfinance.co.uk.
The table at the end of this notice provides more detail about the information that we use, the legal basis that we rely on in each case and your rights.
12. Complaints
If you have any complaints about the way we use your personal data please contact Owen Graham who will try to resolve the issue. If we cannot resolve your complaint, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).
Purpose | Data Used | Legal Basis | Which rights apply?* |
To analyse the operation of your business accounts and make underwriting decisions | Personal contact details, financial information including your credit score, financial information including accounts | Legitimate interests. It is in Keys’ interest to undertake this processing to ensure that your business possesses the requisite services and financial stability to meet the Keys’ standards | The general applicable rights plus the right to object |
For the prevention of fraud and money laundering | Personal contact details | Legal obligation and legitimate interests. It is in both Key’s and its customers’ interest to ensure the prevention of fraud and crime is monitored to prevent liability or loss as a result of illegitimate activities. | The generally applicable rights plus the right to object |
For the purposes of debt recovery | Personal contact details, financial information including accounts | Legitate interest. It is in Keys’ interests to process personal data to make claims to ensure that Key’s financial interests are protected | The generally applicable rights plus the right to object |
*The following generally applicable rights always apply: right to be informed, right of access, right to rectification, right to erasure, right to restriction, rights in relation to automated decision making. Please see the “Your rights in relation to your information” section above for more detail of your rights and how to exercise them.