As a result of Data Protection legislation and associated regulation, you are entitled to be assured that your personal data is collected, processed and stored for specific purposes and that this is done so securely and confidentially. We, as Data Controllers, have responsibilities under Data Protection laws to inform you of the data we collect, why we collect it, how we process it and with whom it will be shared. This is set out in our Privacy Notice, a copy of which you may already have been given.
Should you require any further details or wish to enquire on the details we hold on you please contact the firm’s Data Protection Representative via the following:
Post: Data Protection Representative, Lombard Funding, Kemp House, 152 – 160 City Road, London EC1V 2NX
Tel: 0207 101 9598
WHO WE ARE
Lombard Funding consists of Lombard Funding Limited. Lombard Funding is regulated and authorised by the Financial Conduct Authority.
Details on Lombard Funding Limited status as regulated entities can be obtained from the FCA’s company register: https://register.fca.org.uk/
All of the above entities are registered with the Information Commissioners Office (ICO) as Data Controllers. Each firms’ entry can be searched at: https://ico.org.uk/esdwebpages/search
WHAT DATA WE COLLECT
We will only collect such data that is needed to underwrite your loan application. This includes:
- Your name
- Your current and previous address(es)
- Your date of birth
- Details on your financial profile including your income and expenditures
- Your identification documents (e.g. copies of passport or drivers licence)
- Other relevant details required to establish your identity
- Other relevant information pertinent to the application for a loan and our underwriting of the repayment probability
Details that we will never require from you include:
- Your religious views
- Your political views
- Your sexual orientation
- Your trade union memberships
WHY WE COLLECT YOUR DATA
Under Data Protection laws we must have a legal basis for the collection of your data. This means that there must be a specific reason for us to request your data. Lombard Funding collects data for the maintenance of a contract for a loan and for the preparation of entry into this contract. The information is used and processed in order for us to decide on whether we will provide you with loan funds.
SOURCES OF INFORMATION
All initial data that we gather about you will be provided by your financial adviser or broker acting under your instruction.
Using that data, we will obtain further data from those external companies who maintain data on your credit history (i.e. CRAs) and Fraud Prevention Agencies as well as the Land Registry.
WITH WHOM DO WE SHARE YOUR DATA
Your data will be shared with other, external data processors to assist us in providing you with finance. These include:
- Credit Reference Agencies (CRAs)
- Fraud Prevention Agencies
- Our regulator, the FCA
- Statutory Bodies on their lawful request, e.g. NCA, police forces
- External funders
CRAs maintain credit profile data on consumers within the United Kingdom. As part of the application process, your details will be shared with the CRA in order that we can view your credit history and profile. This provides details on loans, credit accounts, personal finance and utilities that you maintain or have maintained displaying how you have managed their repayments. While this informs our decision on providing you with finance, this is not the sole criteria for our decision.
In certain circumstances your repayment profile with Lombard Funding will be provided to the CRAs for inclusion on your credit profile, this includes any outstanding balance and the frequency and maintenance of scheduled repayments.
FRAUD PREVENTION AGENCIES
As a provider of credit to individuals and businesses, Lombard Funding also has an obligation to ensure against fraud activities. As a result we will share your data with certain Fraud Prevention Agencies. These agencies maintain a database detailing those individuals who have perpetrated or have attempted to perpetrate fraud against agency members when making application in the past. We will submit your details to these agencies for them to perform a search match against your details.
Where we identify any fraud or potential fraud perpetrated by you against Lombard Funding, we will provide details of this to the Agencies for their inclusion on their database. This will be available to those other financial institutions who subscribe to the Agency and with whom you submit other applications for finance.
Decisions that Lombard Funding make are not solely based on information that we receive in these circumstances but will result in our requesting further details from you to clarify the issues that may be raised. Should you require more details on the agencies we use and how they process personal data then please contact Lombard Funding’s Data Protection Representative via the above methods.
In some circumstances, your data will be shared with our external funders to enable them to determine whether they will be able to provide finance on the loan application you have made.
Your personal data will be submitted to a surveyor to carry out a valuation on your property. The data passed will only consist of sufficient information they require in order to carry out this specific function.
As part of the loan process, we will in certain circumstances pass your data to solicitors acting on behalf of the company. These details will only be shared to facilitate the completion of a loan and the management of the transfer of funds to that solicitor acting on your behalf.
THE FCA AND OTHER STATUTORY BODIES
Where the firm is regulated, we have an obligation to report certain personal data to the FCA, a statutory body set up under legislation. We have further requirements, where requested by other statutory bodies, such as the National Crime Agency, police forces, the Serious Fraud Office, etc. to provide specified personal data on their lawful request for information. This is done on a confidential basis and, through legislation, you will not be entitled to be informed of when this transfer of data has occurred. Details of what data we have submitted to these entities are also exempt from disclosure under a Subject Access Request.
Data Protection legislation provides you with express rights which include:
YOUR RIGHT TO OBJECT OR REQUEST ERASURE OF THE DATA WE HOLD
You may object to Lombard Funding holding or processing your personal data and/or request that we remove this data from our storage. Please be advised, however, that should you request that this takes place before a loan completes then we will be unable to provide you with funds. Where your loan does complete we have an obligation to retain your information in order to assure the performance of the loan contract so will be unable to remove your data during the term of any loan taken out with Lombard Funding. Please contact the firm’s Data Protection Representative for further details or to exercise your rights.
YOUR RIGHT TO CORRECT YOUR DATA
Where your or we become aware of an error in the data that Lombard Funding processes or holds, you have a right to have that data corrected. You can inform our Data Protection Representative of any errors that need to be corrected.
YOUR RIGHT TO A COPY OF YOUR DATA
You also have the right to request either the details of the data we hold on you or to request a copy of this. We are obliged to provide this to you within 30 days of receipt of your request. Please contact the firm’s Data Protection Representative to request this.
YOUR RIGHT TO DATA PORTABILITY
You have the right to request that data which we hold is passed to another Data Controller for their use on your behalf via a “machine readable” format. This can be requested from the Data Protection Representative of Lombard Funding.
YOUR RIGHT TO COMPLAIN
You have a right to complain, via our Data Protection Representative, in regards to how and why we process, or any errors we have made in the processing of, your data. Your complaint can also be made to the Information Commissioners Office:
Post: ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113
Lombard Funding will only retain your data for as long as is necessary. In all cases this will be for the term of the loan plus 7 years, where you drawdown on your application. Where the loan does not complete we will retain your data for 7 years from the date of final decision on whether you or we wish to proceed with the loan. We are obliged to retain your data for this period in order to meet our regulatory and legislative obligations.
All Data that Lombard Funding collects is controlled and stores within the UK. We do not transfer data to any entity outside of the UK or the EEA. Where this does occur, we will inform you of the situation and seek your consent prior to the initiation of the transfer.
A ‘cookie’ is a piece of data that a website transfers to the internet browser on your computer’s hard disk, which lets the website “remember” who you are. It will usually contain a unique, randomly generated, number. Major commercial and business websites generally employ cookies. They cannot be used by themselves to identify you, and we will not attempt to use them for this purpose. You can delete cookies manually – if you wish to do so, please consult your browser help manual. (There are also websites that help you do this.) “Session cookies” stay in your browser only until you close it. “Persistent cookies” stay in your browser for longer – how long depends on the “lifetime” of the relevant cookie.
USE OF ‘COOKIES’
We use session cookies to allow you to carry information across pages and avoid you having to re-type it. We may use persistent cookies so we can recognise your number (but not identify you further) when you return to our website, and, potentially, to enable us to note your interests, and arrange or edit content to match your interests, or those of borrowers generally, in a better way. Third parties may also serve cookies through this website. They may be used to put together statistics to help understand how people use the site, or to check whether, and how often, particular content is being viewed.
Some pages may contain these electronic markers to allow us to count up the people who have visited these pages. They collect limited information, including the time when the page was viewed, and the cookie number. We may also carry web beacons placed by third party advertisers in order to track a campaign’s effectiveness, but, again, these will not collect information that would allow you to be identified personally.