Focus Finance Limited (“Focus”) is the Data Controller and Processor for the data we collect and subsequently process.  This means that we make decisions about how and why we use your personal data.  We are responsible for making sure your personal data is used in accordance with applicable data protection laws and this privacy policy.

Registered in England & Wales Number 04168180 at Paddock Farm, Scallows Lane, West Wellow, Romsey.  SO51 6DX

Focus Finance Limited is a finance broker and not a lender.  We deal with a panel of multiple lenders and are independent.  When we make an introduction to a lender we may receive a commission for doing so.

Focus Finance Limited are authorised and regulated by the Financial Conduct Authority: FRN 797598

ICO Reference Number: ZA347827

For the data we collect and subsequently process we are the “Data Controller” and the “Processer”.  This means that we make decisions about how and why we use your personal data. We are responsible for making sure that your personal data is used in accordance with applicable data protection laws and this Notice.

Our approach to data protection is built around the GDPR seven key principles.

Lawfulness, fairness and transparency

Purpose limitation

Data minimisation

Accuracy

Storage limitation

Integrity and confidentiality

Accountability

Data protection law allows us to use your personal data if we have a lawful basis to do so.  The reasons we may process your personal data are:

Contract: the processing is necessary for a contract you have with us, or because you have asked us to take specific steps before entering into a contract, such as to obtain a finance quotation or credit approval.

Legal obligation: the processing is necessary for us to comply with our legal or regulatory obligations such as HMRC reporting, Credit Reference Agencies or financial crime.

Legitimate interests: the processing is necessary for our legitimate interests to process the personal data, such as to advise you of relevant services in the future, and they are not overridden by your rights.

Consent: we may also use your data when you give clear consent for us to process your personal data for a specific purpose.  You can withdraw this consent at any time, in which case we will cease to use it, unless we have a right and a need to continue processing it for one of the other reasons above.

We collect sufficient information to enable us to provide the services you have requested, inform you of the services we offer and provide a personalised and hassle free interaction with us.

The personal data that we may collect from you may include any special types of information or location-based information, including but not limited to:

• Contact details such as names, phone numbers, email addresses and physical
• Dates of birth
• Copies of documents for ID, address and signature verification, which may include passport, driving licence, utility bill
• Bank related information such as bank accounts details, card details, personal and business bank statements
• Financial information such as company accounts, management accounting information, forecasts and business plans
• Employment information such as salary and cv
• What we learn about you from verbal or written correspondence with you or anyone acting on your behalf
• Recordings of telephone calls for training, monitoring and e-signature verification
• Information obtained from fraud prevention agencies and credit reference agencies including but not limited to associated contacts, address history, voters roll and financial information such as credit account data
• Details of agreements we arrange and financial transactions with us
• Vehicle or equipment registration and chassis numbers
• We collect some information about you automatically when you visit our websites or use our services, like your IP address and device type.  You can read our cookie policy here https://www.focus.finance/cookie-policy/

We collect your data in a number of different ways both directly from you and indirectly. 

Directly: from application forms including web, electronic and paper, by email, over the phone and face to face.

Indirectly: from third parties which can include but are not limited to suppliers of equipment or services, accountants, credit reference agencies and publicly available sources such as Companies House.

We need to know your basic personal data to provide you with an accurate recommendation for your personal circumstances.  We will not collect any personal data from you we do not need to provide and oversee this service to you.

For processing of data to be lawful under GDPR, Focus Finance Limited use:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)

We use information about you in the following ways:

• To process enquiries that you or a third party acting with your consent have submitted to us
• To comply with any contractual obligations such as administering and managing your account as well as to trace and recover debts
• To meet our legal and regulatory requirements
• To help us identify you, any accounts you hold with us and keep this information up to date
• To provide customer service, including responding to your requests if you contact us with a query
• To share your personal data with certain third party service providers such as payment services, credit reference agencies (CRAs) and fraud prevention agencies (FPAs) – see sections below
• To notify you about changes to our website, services or terms and conditions
• To enable us to review, improve and provide you with information about our products and services which we feel may interest you
• To deal with requests from you to exercise your rights under data protection laws
• To obtain a credit decision for a finance application Focus Finance Limited will pass your data to one or more funders or banks to facilitate the approval of a credit facility.  A list of their privacy policies can be found here: focus.finance/third-party-privacy-policies.

Credit Reference Agencies

This information may be shared with other organisations by the CRA.  A record of any searches will be kept and may be used by other lenders in assessing applications from you for credit in the future.  Any information held about you by the CRAs may already be linked to records relating to one or more of your partners, including previous and subsequent names of parties to an account.  In this case, this application may be treated as financially linked and assessed with reference to any “associated records”.  For joint applications a new “association” may be created at the CRAs (except for limited companies and partnerships) which will link your financial records.  In the case of joint applications, you must be entitled to disclose information about your co-applicant and/or anyone else referred to by you, and to authorise the lender to search and/or record information at CRAs about both of you.  When an application is received from a business, information may be sought from CRAs on the company directors and/or partners as individuals.  Lenders may make searches at one or more CRAs.

Fraud Prevention Agencies

To detect and prevent criminal activity such as fraud and to verify what you have told us is correct we may perform identify checks, anti-money laundering checks and checks with FPAs.  Lenders will check your details with fraud prevention agencies and if false or misleading information is given on the application and fraud is suspected, this will be recorded.  Other lenders will check this information to help prevent fraud.

When we pass your data to funders or banks they may use automated decision-making or credit scoring in respect of your application for finance.  Declines based on this automated technique can be reviewed manually on request.  You can request human intervention and challenge a decision made this way by contacting privacy@focus.finance.

At times we may disclose personal data to people within our group of companies.  We do not give or sell your personal data to third parties for marketing or advertising purposes but third party disclosure may occur for the following reasons:

• When we are legally required to do so by government or regulatory bodies
• To banks or funders for the purpose of considering a credit facility
• To suppliers of equipment and services to advise about credit decisions and correspondence or delivery contact information
• To agencies that help in fraud prevention including credit reference agencies
• To allow auditors to complete their regulatory and contractual requirement;
• For the provision of services on our behalf (for example processing card payment and direct debit transactions)
• Should we sell any or all of our business to a third party
• Companies we have a joint venture or agreement to co-operate with and companies you ask us to share your data with

All the personal data we use is controlled by Focus Finance Limited in the UK, however when we use cloud based software, from time to time, your data may be transferred to and stored in a country outside the EEA in relation to provision of the services. 

The laws in these countries may not provide you with the same protection as in the EEA but the service provider will take steps to ensure that the necessary levels of protection are in place.  This may include measures such as entering into a written agreement with us to provide a contractual undertaking that they will keep your personal information secure.

By providing your personal data to us, you agree to this transfer and storage.

You can find more information about processing undertaken by our cloud service providers here:

https://docs.microsoft.com/en-gb/legal/gdpr

https://www.xero.com/uk/about/legal/terms/data-processing-terms/

Our internal and cloud based systems are password protected and only accessible to employees where required.  All employees undertake GDPR training on induction with ongoing monitoring and training to ensure our policies are complied with.  In the event of non-compliance an employee may be subject to disciplinary action.  In the event of any suspected data breach we will take immediate action to mitigate any issues and notify the relevant authority.

We will retain your data only for as long as necessary in accordance with applicable laws.  We may keep your data for up to seven years after your contract with us has ended as we may not be able to delete your data before this time due to our legal and/or accountancy obligations.  For our protection, certain data relating to criminal activity and fraud will be kept indefinitely.

We will retain your personal information for longer than seven years where you do not object or opt-out of receiving email marketing communication from us about similar products and services.  In this case we will store your personal information until you object or opt-out.

In the case of call recordings these are automatically deleted by our telecommunication cloud provider after 12 months.

Under data protections laws you have a number of rights in relation to the collection and use of your personal data:

• The right to access to the information we hold about you
• The right to rectification so you can have your personal data corrected if it is inaccurate and to have incomplete personal data completed
• The right to erasure – you have the right to request that we delete your personal data from our records.  We will not be able to delete your personal information whilst we are still providing our services to you.  This right is not absolute and requests for erasure may be refused in some circumstances such where the personal data must be retained to comply with a legal obligation, to exercise/defend legal claims or to prevent financial crime
• The right to restrict how we use your personal information
• The right to object to the collection and use of your personal information at any time
• The right to obtain a copy of your personal data in a legible and compatible format such as Excel or Word

More information about your rights can be found on the Information Commissioners website https://ico.org.uk/

You should notify us of any changes to your status, contact and payment details without delay in order that the data we hold for you is kept up to date at all times.

If you wish to make a complaint about how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

Please let us know by sending an email to privacy@focus.finance.  We will review and investigate your complaint, and get back to you within a reasonable time frame.

If you are not satisfied with our response or believe we are processing your personal data outside of the law you can complain to the Information Commissioner’s Office (ICO).

The ICO is the regulator who makes sure that we use your personal information in a lawful way.  You can do this by calling 0303 123 1113 or visit www.ico.org/make-a-complaint/

Phone: 01722 448050

Email: privacy@focus.finance

Letter: Focus Finance Limited, Paddock Farm, Scallows Lane, West Wellow, Romsey.  SO51 6DX