Privacy Policy
Naylors Finance Ltd is the Data Controller responsible for your personal Data. We are a family business with over 40 years trading history.
Head Office Address
Naylors Finance Ltd
97 Bridge Road
Horbury Bridge
Wakefield
WF45NN
Contact Details
Tel: 01924 283939
Email: admin@jrnaylors.com
Data Protection Officer, Steve Maycock
dpo@jrnaylors.com
The Design of our Privacy Policy
To manage your personal information in accordance with General Data Protection Regulation (GDPR), we must process your information fairly and lawfully.
The policy is set out in clear, plain language to ensure you can understand as a respected data subject, our commitment to protecting your information.
This also means you are entitled to know how we intend to use your information.
You may then decide whether or not you want to give it to us so we can provide the product you applied for.
Everyone at Naylors Finance Ltd receives regular GDPR training and their obligations to you are taken seriously.
In addition, our policies and procedures are regularly audited, including this update which was refreshed on 27/01/2020.
If you do not understand any of the information in the policy do not hesitate to contact us by any of the above methods. Normal security will apply.
Previously we explained we would ensure the policy must be clear and easy to understand.
This is our chance to explain;
• What information we may collect and how we may collect it.
• How and why we may use it.
• The methods we use to keep it secure.
• Your rights in respect of your personal data
Personal Information we may use… and where it’s come from.
To operate our business and provide our products, we gather several different categories of personal data.
Some data is gathered from you while using our online website, during conversation using the office call centre, or more than often while using your local agent.
We may use this data where we have a legal obligation regarding contracts, credit reference agencies, fraud prevention, your bank, or maybe any third party you have instructed to act on your behalf who will need to contact us.
The process starts from the moment you make an application and continues throughout the terms of your loan agreement.
Transparency
Some information we use everyday as data subjects, but as Naylors Finance Ltd is a family business we feel transparency must be key to all involved, so here are categories of personal data that we may use.
• Your name, date of birth, your address and previous addresses, contact mediums i.e. mobile phone numbers, landline numbers, email addresses, relationship and family status including dependants, if you share your home. This also includes any and all contractual data while you are with us.
• Financial information, employment data that you provide or we obtain from credit reference agencies or your bank, dependant on your payment method.
• Data captured to perform analysis of you and your account.
• Technical data gathered from use of our website(s). This may but does not always include IP addresses.
• Communication and marketing preferences.
Naylors Finance will ensure that it and any third parties whom it engages to process Personal Data on its behalf will process the Personal Data in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. Naylors Finance will ensure that a written contract (a “Data Processor Agreement”) is put in place with third party processors and the terms of that Data Processor Agreement will comply with requirements of the Data Protection Legislation.
Be clear about what we do with your application
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (CRA’s). Where you take banking services from us we may also make periodic searches at CRA’s to manage your account with us.
To do this, we will supply your personal information to CRA’s and they will give us information about you.
This will include information from your credit application and about your financial situation and financial history. CRA’s will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and 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 CRA’s while you have a relationship with us, and will also inform the CRA’s about your settled accounts.
If you borrow and do not repay in full and on time, CRA’s will record the outstanding debt. This information may be supplied to other organisations by CRA’s.
When CRA’s receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application 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 lodging the application. CRA’s 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 CRA’s to break that link.
Credit Reference Agency Information Notice (CRAIN)
The identities of the CRA’s, 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 CRA’s are explained in more detail in the Credit Reference Agency Information Notice (CRAIN). CRAIN is accessible from each of the three CRA’s;
Clicking on any of these three links will also take you to the same CRAIN document:
• Transunion
• Equifax
• Experian
Your Rights
You have several rights in regards to how we use your personal information.
• The right to withdraw consent at any time where we are processing your data relying on consent.
• The right to ask us to rectify any inaccuracies regarding your personal data.
• The right to ask us to grade or restrict processing of your personal data if you feel it is no longer necessary for us to process in accordance with any contracts or legal obligation or legitimate interest.
• The right to Opt-In to any marketing campaigns or Opt-out at a later stage.
At Naylors Finance Ltd, your rights will always remain our priority so we would like to keep the communication options simple. For your ease, you can exercise any of the above rights by contacting us using any of the options below;
• Through your local agent
• In writing to: Naylors Finance Ltd, 97 Bridge Road, Horbury Bridge, Wakefield, WF45NN
• Phone: 01924 283939
• Email:admin@jrnaylors.com
Open Banking
This section of our Privacy Policy relates to Open Banking and should be read in conjunction with the other clauses in our Privacy Policy. In the event of conflict with any other clauses, this clause shall prevail.
What is Open Banking?
Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose.
Registered providers and participating banks and building societies are listed under the Open Banking Directory.
Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector.
As a forward thinking lender, we support the use of Open Banking as it allows us to process loan applications efficiently, securely and in our consumer’s best interests.
By permitting access to your bank or building society account information we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.
Further information about Open Banking is available from www.openbanking.org.uk
How will my personal data be shared and used for the purposes of Open Banking?
By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Perfect Data Solutions Limited (“PDS”) who are also a credit reference agency. During your loan application we shall safely and securely direct you to PDS’s secure portal (“the Portal”) for the purposes of granting PDS access to your bank or building society account information (“Transaction Information”). As soon as your Transaction Information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”).
Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com.
Is Open Banking secure?
PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599. Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards.
We are responsible for the secure transmission of any Shared Personal Data to PDS, for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information.
You will not be required to share your banking password or log in details with either us or PDS. Once you have given your explicit consent to share your bank account information on the Portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.
Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with PDS or with your own bank or building society.
How will my Shared Personal Data and Transaction Information be used?
PDS shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.
PDS shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.
PDS shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on the Portal, which you will be required to read and consent to once directed there via our website.
As PDS are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.
Will you use my Transaction Information data for any other purpose?
The Transaction Information we receive about you will only be used for the Permitted Purpose. We do not sell or share Transaction Information with any third party.
Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.
Do I have to provide you with my consent to proceed?
To proceed with your loan application, you have the option of using our Third Party Bank Account Aggregation Supplier to send us details about your bank accounts where we will require your consent. Our current supplier is Lending Metrics Ltd and its product Open Bank Vision (OoMoolah), or such other persons as stated on the applications page of our Website. The supplier will require you to log in to your on-line bank account information via that supplier’s or its sub-contractor’s service, so that they can retrieve your financial information and verification of your identity from your on-line account. The supplier may capture your log-in credentials solely to provide this service, and will encrypt them and store them securely for a limited period required to provide the service.
The supplier will aggregate or re-present your financial information and supply it to us, for the purposes described in our privacy policy. Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under there particular Open Banking terms and conditions.
Are any of my other rights under this Privacy Policy affected?
Your individual data protection and privacy rights including the right to access, correct, delete, object, restrict, withdraw consent, request transfer and/or make a complaint, continue to apply to relevant personal data we control or process and are dealt with elsewhere in this Privacy Policy.
Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.
Information Retention
While you are a customer with Naylors Finance Ltd we will keep your information. When you stop being a customer we will keep all your personal data no longer than 6 years. We are obliged to hold transactional
data for up to 6 years to answer any regulatory enquiries or respond to any complaints during this period.
Cookies: Last updated: 24/03/2021
We use cookies on this Website.
By using this Website, you consent to the use of cookies.
Our Cookies Policy explains what cookies are, how we use cookies, how third-parties we may partner with may use cookies on the Website, your choices regarding cookies and further information about cookies.
What are cookies?
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you. Cookies can be “persistent” or “session” cookies.
How we use cookies
When you use and access this Website, we may place a number of cookies files in your web browser. We use cookies for the following purposes:
To enable certain functions of the Service,
To provide analytics,
To store your preferences,
To enable advertisements delivery, including behavioural advertising.
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
Essential cookies.
We may use essential cookies to authenticate users and prevent fraudulent use of user accounts. For the full disclosure section, including all types of cookies (from essentials to advertising cookies).
Third-party cookies
In addition to our own cookies, we may also use various third-parties cookies to report usage
statistics of the Service, deliver advertisements on and through the Service, and so on.
Naylors Finance Ltd Telephone conversations
Naylors Finance Ltd has a very strict policy regarding fairness and transparency.
For this reason, we will record any incoming or outgoing telephone conversation for training and monitoring purposes.
If at any point during the conversation, sensitive data is being discussed, like bank card details for example, we observe the capability to pause the recording in order to ensure that those details are not stored.
Credit Reference Agencies Information
Naylors Finance Ltd currently use the company Transunion.
You have the right to access information held by a credit reference agency.
Should you need to access your information you must contact Transunion directly on either of the options below;
Online: https://www.transunion.co.uk
Telephone: 0113 388 4300
Complaints
If you are unhappy with the service we have provided as your personal data controller, please contact our Data Protection Officer via email at dpo@jrnaylors.com
Alternatively, see previous communication options.
Should you still not be satisfied, you have the right to complain to the Information Commissioners Office (ICO).
Please bear in mind that should you contact the ICO, they will first ask you if you have raised the matter with us beforehand.
You can access the ICO on any of the options below
Online: ico.org.uk
Telephone: 0303 123 1113
Live Chat: Click Here
Email: Contact by email
Disclosures
You must be over 18 Yrs to use the website.
Complaints Policy
As an overriding principle we believe in “Treating Customers Fairly”. Naylors Finance Limited are committed to providing you with a high quality customer service.
If you are dissatisfied with the service you have received through Naylors Finance Limited, we want to know about it. Issues that arise are taken very seriously. Our aim is to ensure complaints are dealt with thoroughly in accordance with this procedure.
Upon receiving your complaint we will:
Acknowledge your complaint within two business days;
Inform you of the person dealing with your complaint;
Attempt to resolve the complaint as soon as possible;
Keep you informed of the investigation process at all times;
Send our final response within eight weeks following the receipt of the complaint.
If the matter has not been resolved by the fourth week after receiving the initial complaint, we will update you on progress.
We will provide you with our final response and include details of how you may complain to the Financial Ombudsman Service if you remain dissatisfied, or if we have been unable to resolve your complaint within 8 weeks. The details will also include how to, if you remain dissatisfied with our response, refer your complaint to our Trade Association. Generally, your complaint must reach the FOS within six months after receipt of our final response. You may complain to the FOS at an earlier point but please note, we are allowed eight weeks after your initial complaint to resolve any issues you may raise.
Please note your right to complain to the FOS is entirely separate to and not affected by your right to complain to us or the Trade Association (of which we are a member). You can complain to all three bodies at the same time if you so choose, or in any order you wish. Generally, however, you should complain to the FOS within six months of the matter which is the subject of your complaint being brought to your attention.
Consumer Credit Trade Association (CCTA),
Airedale House,
Aire Valley Business Park,
Dowley Gap Lane,
Bingley,
West Yorkshire,
BD16 1WA
www.ccta.co.uk
The Financial Ombudsman Service
Exchange Tower,
London,
E14 9SR,
www.financial-ombudsman.org.uk
How to make a complaint
Find out more here
01924 283939 (Calls to this number are normally free from a “fixed line” phone but charges may apply if you call from a mobile)
Write to us at Naylors Finance ltd, 97 Bridge Road, Horbury Bridge, Wakefield WF4 5NN
Or email us Here.