WHO IS SALARY FINANCE?
When we refer to “Salary Finance”, “we”, “our” or “us” in this Privacy Notice, we mean Salary Finance Limited and each of its group companies (including parent, subsidiary and joint venture undertakings).
Salary Finance Limited and Salary Finance Loans Limited are authorised and regulated by the Financial Conduct Authority (firm reference numbers: 758053 and 734585). Salary Finance Limited is registered as a small payment institution money remittance firm (firm reference number: 788485).
For Borrow Salary Finance Limited acts either as lender, or credit broker exclusively for associated company Salary Finance Loans Limited.
Advance is not a regulated lending product.
Salary Finance Limited and Salary Finance Loans Limited are registered in England & Wales (company numbers: 09677777 and 07643748) at registered address: Salary Finance, Scale Space, 58 Wood Lane, London, W12 7RZ.
Salary Finance Limited and Salary Finance Loans Limited are registered with the Information Commissioner’s Office under numbers ZA152606 and ZA099501.
How you can contact us
PART 1 – BORROW, SAVE, ADVANCE, SALARY DEDUCTION FOR HELP TO SAVE AND PROTECT
Part 1 sets out how we collect your personal data and how we use it. It applies in relation to the following products:
- Loans repayable by salary deduction and/or direct debit (including, top-up loans) (“Borrow”);
- Salary deduction for savings accounts with Yorkshire Building Society, including our “Jars” feature that we offer in partnership with NEST pensions (collectively referred to as “Save”);
- Advances of accrued earnings (“Advance”); and
- Salary deduction for the HM Government Help to Save scheme (“Salary Deduction for HtS”).
In relation to Protect, Salary Finance processes your data on behalf of Legal & General Assurance Society Limited (“Legal and General”), which provides the Protect cover. As Legal and General is the “controller” of your personal data when providing Protect, it is responsible for determining how it handles your personal data. You can find out more about how Legal & General processes your data here.
The availability of the products and services referred to above on our Site and/or the App is at our sole discretion and subject to your employer’s arrangement with us. Not all of our products and services are available to all users.
What information we collect
We will need to ask you and your employer or any membership organisation (as applicable) and (if applicable) their outsourced payroll providers for certain personal information to provide you with the best possible experience when you engage with us (via our Site or on the App or otherwise) and when you use our products and/or services.
We also work with certain organisations (“External Organisations”), including Legal & General (in relation to Protect), Yorkshire Building Society and NEST pensions (in relation to Save and Jars), and HM Revenue & Customs (“HMRC”) (which is the part of HM Government responsible for Help to Save) and National Savings & Investments (“NS&I”) (in relation to Salary Deduction for HtS). Certain information about you is shared between Salary Finance and such External Organisation in order to provide you with the products/services you have applied for.
In relation to Borrow, information about you is also shared between us and credit reference agencies to make sure that any Salary Finance products and/or services are affordable to you and suitable for your needs, and to manage your account.
Where we seek information from you, giving this information is your choice and if you choose not to give all or some of it to us, this may affect our ability to provide you with the products and/or services you require.
The information that we may collect about you is set out below. The personal information that we collect about you depends on various factors, including the products and/or services you apply for and use.
Information we collect from you
Information to create your Salary Finance account
To use the products offered on the Salary Finance platform, you will be required to create a Salary Finance account. To do this, we will ask you to provide the name of your employer, your full name, email address, date of birth, payroll ID and mobile number and create a password. You will provide this information to us directly, however, if you are registering for Protect (and you have no other Salary Finance product), you will provide these details to Legal & General (who provide the Protect cover) and they will share this information with us when you access another product made available on the Salary Finance platform so you don’t have to re-enter your information again.
Information to register for and use our products and services
We may ask you to provide information, which may include some or all of the following:
- full name
- residential address
- telephone number
- email address
- job title
- work start date
- ongoing gross annual income (and any other employment income)
- previous period net pay
- payroll/employee ID number (and, if applicable, national insurance number, or any other form a personal identifier)
- current or anticipated employment status (for example, active, leaver, sick leave, maternity/adoption/parental leave, redundancy).
- information to help us (in addition to the above) to assess your eligibility and suitability for Salary Finance products and/or services, for example: address history, residential status, date of birth, partner’s income, number of dependents.
- bank account details
Information about your behaviour
We collect information about your behaviour in relation to your obligations under our products and/or services - for example, whether you make repayments on time.
Site and App usage
Provided you consent to us doing so, we will also collect information about how you use our Site and/or our App. This might be through our analytics monitoring and visitor recording (or other such systematic methods) that enable us to see how you interacted with our Site or App and services, or through you accepting to share your screen with us in order for us to provide support services (for example, through our live-chat function). We do this so we can respond to your queries and provide you with the best customer experience possible.
Information we collect from your device
We collect, store and use information about your computer, tablet, mobile or other device through which you access the Site or use the App. This includes the following information:
- technical information - including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform; and
- location information – depending on the products or services you have requested, we may collect your location data. If you wish to use this particular feature, we will notify you and you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location data in your settings. Certain functions of the App may make use of location data sent from your device to provide and improve location-based products and services or may require access to your camera. You can turn off these functionalities at any time by adjusting the location services and camera access settings for the App on your device.
Recording our calls
We may record and monitor our telephone calls, and keep a record of such calls, to help improve the products and/or services we provide to you.
Responses to prize draws, competitions, customer offers, surveys and other promotional activities
We may also record information from prize draws, competitions, customer offers, surveys or other promotional activities that you take part in.
Information we collect from third parties
From time to time, we may ask third parties (such as your employer, a credit reference agency, a credit broker or our relevant External Organisations (if applicable)) for information about you. This could be to:
- confirm that the information you provide us with is correct (and remains correct) and to update any inaccuracies;
- monitor your repayment obligations (if you are a Borrow customer); or
- offer you products and/or services that may be suitable for you.
We may also do this to improve your user experience – for example, if your employer has provided us with information for the purposes of Protect or any other product available on the Salary Finance platform, we will use this information for any other such product you may apply for so you don’t have to re-enter your information again.
We collect the following information from third parties:
- Information to create your Salary Finance account (see data points above) – I f you are registering for Protect (and you have no other Salary Finance product), you will provide these details to Legal & General (who provide the Protect cover) and they will share this information with us when you access another product made available on the Salary Finance platform so you don’t have to re-enter your information again.
- Information to register for a product (see the Information we collect from you section above) – We will check some of the information you provide to us with your employer or membership organisation (as applicable) and (if applicable) their outsourced payroll providers, and they may provide us with updated information. In particular, we check your employment start date, payroll ID, date of birth and ongoing gross annual basic salary with your employer or membership organisation (as applicable) and (if applicable) their outsourced payroll providers.
- General contact details - Your friends, colleagues and family may provide us with some of your personal information required to register for a product, for example, through our “Refer a Friend” schemes. If your friends, colleagues or family members refer you to us, we will always ask that friend, colleague or family member to confirm that you have consented to them sharing your contact details with us.
- How you are paid your salary - When you register for Advance (if this is available to you), we will obtain details of how you are paid, such as how your salary accrues and whether it is paid to you in arrears. For example, if you are an hourly paid worker your employer will provide us with your ongoing hourly pay and number of hours worked in a pay period.
- Information provided from our savings provider (Yorkshire Building Society) - Where you have Save or Jars, we will ask our savings provider for details that they hold about you which may include some or all of the following: title, forename(s), surname, date of birth, address, email, phone number, account number and sort code and other details about your savings account (including account close date, inactive date, balance).
- Information provided from HMRC and NS&I where you are a Salary Deduction for HtS customer - HMRC (and/or NS&I) will provide us with data required for Salary Deduction to HtS, which may include one or more of the following: your first and last name, date of birth, whether or not you are eligible for an NS&I Help to Save account and details about your NS&I Help to Save account, including your account number, headroom, account status, current balance, any restrictions on adding funds and (if applicable) your bonus estimate.
- Information provided by aggregators acting as credit brokers – When you apply for a loan on an aggregator’s website and choose the offer made to you by Salary Finance, you would be redirected to our website to complete your loan application and receive a final decision from Salary Finance. As part of this process, the aggregator will share your personal information with Salary Finance which may include (but is not limited to) some or all of the following: your full name, address history, employer name and income.
- Credit reference agencies - In relation to Borrow, as a responsible lender, we perform automated credit searches with the credit reference agencies, Experian and/or TransUnion to check your credit history. This may include (but is not limited to) some or all of the following: details of credit accounts held and repayment performance, as well as public information such as inclusion on the electoral roll, bankruptcies and county court judgements. When you initially complete an application, we will perform a "soft" search. This is visible only to you on your credit file. Should you choose to proceed with the loan we offer you, we will conduct a "hard" credit seach that will be visible on your credit file to other lenders. We also receive data from Experian to monitor your obligations under the loan agreement you have with us and for internal risk decisioning (for example, to identify whether you are eligible to apply for additional loans with us). To find out more about how credit reference agencies use your information, see the Credit Reference Agency Information Notice for Experian here and for TransUnion here.
How we use your information
We use your personal information in a number of ways to fulfil your request and make our products and/or services as effective as possible. We only retain your data for as long as is necessary and for the purposes specified in this policy.
We may use any of the information we collect about you for any of the following purposes (as well as for the reasons set out above).
To create a Salary Finance account
We will use the information you provide us or Legal & General (in relation to Protect only) to create a Salary Finance account. We will store your account details in our account services database. We will search this database to find accounts when a relevant person logs in to Salary Finance for any product. When you try to create an account or sign in, Salary Finance will check whether you already have an existing account by checking the data you enter against this database. This will allow you to use the same set of log-in details across any product you access on the Salary Finance platform.
To enable you to apply for, and to use, our products and/or services
We will use your information to register you as a user and to provide you with our products and/or services. This includes, for example, using your information:
- to contact you about your application and the products and/or services you have with us;
- to verify your eligibility and suitability for our products and/or services;
- to decide whether to offer you our products and/or services;
- in relation to Borrow, to search your credit files;
- to enhance the accuracy of information we hold and which your employer or membership organisation (as applicable), and (if applicable) their outsourced payroll providers, holds about you;
- to make payments, on your behalf, to your third party creditors (where you are using our direct debt consolidation service);
- to advise the payroll team of your employer or membership organisation (as applicable) of your registration;
- to manage your account;
- to send you newsletters;
- to conduct internal analysis and reporting;
- to fulfil our contractual and legal obligations as a lender;
- in relation to Borrow, to determine the method by which your loan repayments will be collected;
- in relation to Borrow, to administer the disbursal of loan payments and the collection of loan repayments (whether by salary deduction or otherwise);
- where you have Advance (if this is available to you), to administer the disbursal of payments, make adjustments to the earnings you receive on your usual pay day and determine the method of collecting any payments that you’re not entitled to but that may have been paid to you;
- where you have Save including Jars, to share relevant data about you with our savings provider so that we can reconcile data that they hold about you with data that we hold about you;
- where you have Save including Jars, to administer collections of savings deducted from your salary; and
- where you have Salary Deduction for HtS (if this is available to you), to help you set up a Help to Save account (if you don’t already have one), to link your Help to Save account with your Salary Finance account, to administer the transfer of funds from your earnings to NS&I and to provide you with details about your Help to Save account.
Where you have been accepted for a Salary Finance loan, we will ask you to provide your bank account so that we know where to send your loan funds and also to allow us collect repayments via Direct Debit if making loan repayments from your salary is not possible (whether because your employer does not support repayments by salary deduction or because you have left your employer or otherwise).
When you register for Advance (if this is available to you), we may ask you to provide your bank account details and other associated details to allow us to make sure that we pay Advances to the bank account to which your earnings are paid and to allow us to set up a Direct Debit (if appropriate).
When you register for Salary Deduction for HtS (if this is available to you), we will ask you to provide your bank account details so that, if NS&I are not able to credit your Help to Save account with the amounts deducted from your earnings (“Deductions”), we can return the Deductions (or the difference between the Deduction and the amount credited to your Help to Save account) to you. We may also share your bank account details with HMRC and NS&I in order to set up a Help to Save account on your behalf.
When you register for Save or Jars (if this is available to you), we will ask you to provide your bank account details so that, if we are unable to credit your Yorkshire Building Society account with the Deductions, we can return the Deductions (or the difference between the Deduction and the amount credited to your Yorkshire Building Society account) to you.
To validate your identity and authenticate the information you provide
We will confirm your identity and authenticate the information you provide for security purposes.
To send and receive information about your credit history and to carry out other background checks
In relation to Borrow, we and credit reference agencies (Experian and/or TransUnion) will share information with each other to check your credit file (as described above). We also work with the credit reference agencies like Experian and TransUnion to carry out other background checks. These processes help to verify whether our products and/or services are suitable for you and to run appropriate fraud, anti-money laundering or background checks. We also receive data from Experian during the course of your loan for monitoring purposes. We are required to tell credit reference agencies how you run your relationship with us, including whether or not you make your loan repayments on time, if you default on your loan or enter into any repayment arrangements. This reporting may make obtaining future credit more difficult. We report to Experian, TransUnion and Equifax. To find out more about how credit reference agencies use your information, see the Credit Reference Agency Information Notice for Experian here, for TransUnion here, and for Equifax here.
To set up a Direct Debit
We will use your information to set up a Direct Debit with your bank account in order for us to collect repayments of loans you have with us (if your loan is not being repaid by salary deduction) or any other amounts due.
To enforce our terms and conditions
We will use your information to enforce the terms and conditions that apply to you when you have and/or use our products and/or services.
To provide and improve customer support and experience
We will use your information to be able to provide and improve the customer support and experience we provide to you (for example, queries about our products/services, access/log-in, account management etc.).
To process payments and collect arrears
We will use your information to process the payments you commit to when signing up to our products/services and for the collection of any future payments or overdue amounts for those services.
To personalise Site and App experience
Salary Finance may use your data to monitor and to enable Site and App personalisation and improve your online experience.
We may use your data to generate non-personal statistical data, for example relating to the size of our customer base, the levels of Site and App usage and customer behaviour. This will only be group data (also known as “aggregated data”), such as the age range of Site and App users, and will not include any information that could personally identify you. This may then be shared with third parties and your employer or membership organisation (as applicable) and (if applicable) their outsourced payroll providers.
Salary Finance may ask particular customers to participate in market research (for example, a survey or a questionnaire). If you accept this invitation, we will use the feedback you give us to improve our products and services and/or other research purposes.
Administration of prize draws, competitions, customer offers, surveys and other promotional activities
From time to time, we will run prize draws, competitions, promotions and surveys and, we will use the information you provide to us, to run such activities (including contacting you to see if you want to take part) and to do what we agree to do as part of them.
Marketing (including electronic marketing)
We will use your information for marketing purposes and/or to keep you informed of any of our products, services or offers, or those of our third party partners, that may interest you. We or they may contact you about them (including by post, email or SMS).
Where we are required by law to obtain your consent to use your personal information for marketing purposes, we will ask for this consent separately and clearly. Additionally, Legal & General may ask for your consent on our behalf when you register for Protect.
You can opt out of marketing communications at any time by emailing firstname.lastname@example.org or by clicking the unsubscribe link in any marketing email you receive from us.
Crime or fraud investigation, detection and prevention
We may use your information for the investigation, detection and prevention of crime and/or where we feel that it is a necessary action to protect the property, rights or safety of Salary Finance or any other party, and/or to provide suitable security for your account and the information that we hold about you.
Reporting and analytical purposes
We will use your information for reporting and analytical purposes to meet our legal, regulatory and contractual obligations to enable us to improve our products and services and to provide appropriate levels of support to our customers.
To maintain our records and other administrative functions
Salary Finance needs to ensure that it maintains comprehensive and up-to-date and accurate records of the ways we process your personal information and other operational activities and therefore we will process the information you provide for record-keeping and general administrative purposes.
Complaint and dispute resolution
Whilst we will try to make sure that you are satisfied with the service we provide, if you do complain to us, we will use the information we have about you to help us manage your complaint.
To comply with the law
We are required to comply with many laws and regulations. We will, where necessary, use your personal data to the extent required to enable us to comply with these requirements.
The lawful basis for our collection of personal information
Where we process your personal information, we will ensure that we have a lawful basis to do so.
Performance of contract
We may rely on this basis for processing personal information where the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, or for compliance with a legal obligation to which we are subject. Failure to provide personal data for these purposes may mean that we cannot perform the services requested or you may not be able to use the products and/or services we offer.
We may rely on this basis for processing where we process personal information for the following purposes:
- to enable you to apply for, and to use, our products and/or services (for example, entering into a consumer credit agreement or our terms and conditions);
- to validate your identity and authenticate the information you provide;
- to send and receive information about your credit history;
- to set up a Direct Debit;
- to enforce our terms and conditions;
- to provide and improve customer support and experience;
- to process payments and collect arrears;
- to personalise Site and App experience;
- to investigate, detect and prevent crime or fraud investigation;
- for reporting and analytical purposes;
- to maintain our records and other administrative functions;
- to resolve complaints and disputes; or
Compliance with laws
We may rely on this basis to process personal information if the processing is needed to comply with a common law or statutory obligation.
We may rely on this basis for processing where we process personal information for the following purposes:
- to investigate, detect and prevent crime or fraud investigation;
- to maintain our records and other administrative functions;
- to resolve complaints and disputes; or
We may rely on this basis to process personal information where the processing is necessary for the purposes of legitimate interests pursued by us (or by a third party) (except where such interests are overridden by your interests or your fundamental rights and freedoms).
We may rely on this basis for processing where we are processing data for the following purposes:
- to check for your account details when you log in to access any product available on the Salary Finance platform or when you attempt to create another Salary Finance account when you already have one;
- to enable you to apply for, and to use, our products and/or services (for example, entering into a consumer credit agreement);
- to notify you that are you eligible to apply for another loan with us (including top-up loans);
- to assess whether you are eligible for another loan with us (including top-up loans);
- to validate your identity and authenticate the information you provide;
- to send and receive information about your credit history;
- administration of prize draws, competitions, customer offers, surveys and other promotional activities;
- marketing material (including electronic marketing);
- to maintain our records and other administrative functions; or
The legitimate interests we are typically pursuing are:
- Provide you with a single set of log-in details for all products offered by Salary Finance (including Protect) – the Salary Finance platform offers multiple products, including Protect cover which is provided by Legal & General. To improve your customer experience, you can use one set of log-in details across all products offered by Salary Finance.
- Provide a personalised service for relevant people – including sending targeted communications (such as emails) to the right people, for example customers who are eligible for additional Salary Finance products and/or services, instead of sending mass communications that may not be relevant to some of the recipients.
- Provide beneficial products and/or services to our customers – a top-up loan customer will benefit from the utility provided by the additional funds. This may be because they are able to consolidate additional higher cost debt.
- Promote responsible lending – responsible lending means that lenders only sell products that are affordable and suitable for the borrower’s circumstances.
You may request to opt out of us processing your personal data on the basis of legitimate interests by emailing us on email@example.com. For further details, see ‘Your rights in respect of the processing below’.
We may also rely on you providing consent to our processing in the following scenarios:
- internal research purposes;
- administration of prize draws, competitions, offers, surveys and other promotional activities;
- viewing how you use our website when you agree to give access to your screen in our live-chat function;
- marketing (including electronic marketing);
We will also seek your explicit consent in the event we need to process any of your “Special Category Data”. This is personal data which is afforded a higher degree of protection under data protection laws due to its sensitive nature and includes information relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; health; sex life, sexual orientation; or genetic or biometric information.
If you choose not to give your consent, or you later remove your consent, this may affect our ability to provide the services you want to you.
Where we are required to obtain your consent by law, we will ask for this consent separately and clearly.
Who do we share and disclose your personal information with?
We will share your information with various third parties for the purposes set out above (and where Salary Finance has a lawful basis to do so).
We will only share your personal data with third parties where they ensure an adequate level of protection in relation to your personal data.
We may share your personal information with the following third parties.
Employers or membership organisations
We may share relevant information (such as contact details, date of birth, gross basic annual salary, previous period net pay, start date of your employment, payroll or membership number, and any product-specific orders which are to be processed via payroll) with your employer or membership organisation (as applicable), and (if applicable) their outsourced payroll providers, in order to improve the accuracy of our respective records and to determine the method by which your loan should be repaid (if you are a Borrow customer).
Partners, Suppliers and External Organisations
We may share your personal information with partners or suppliers who provide services to us and who require access to your personal information in order to process it for the reasons set out above.
Our partners and suppliers include:
- brokers, lenders and providers of credit and financial products;
- our own finance providers and investors, agents and trustees acting in connection with our financing arrangements;
- customer support services and developers (which may be based outside the European Economic Area);
- IT providers (such as communications management providers or suppliers that assist with user analytics, visitor recordings etc.).
We will share your personal information with our External Organisations in order to provide you with the products and/or services that you applied for, for example to enhance the accuracy of the data that we each hold about you or to link your Salary Finance account with your NS&I Help to Save account or Yorkshire Building Society account (as applicable). In order to help you set up an NS&I Help to Save account, we will provide HMRC with data required for Salary Deduction for HtS, which may include one or more of the following: your email address and bank account details. We will transfer savings amounts to NS&I to be credited to your NS&I Help to Save account (subject to NS&I account rules, including limits on amounts that may be credited each month).
We will share your personal information (name, email address, mobile number, date of birth and payroll ID and password) with Legal & General if you are eligible for the Protect proposition when you log in to your Salary Finance account to access Protect. When you do this, we will search for your account in our account services database and if you have an account, we will share your account details with Legal & General to enable you to use the Protect services.
We also share your personal information with companies within our group, or our business partners, who manage some parts of our products and/or services.
Regulatory and law enforcement bodies
We may also provide personal information to fraud prevention agencies, public bodies, law enforcement bodies and other judicial or regulatory bodies.
We may also share your personal data with third parties where such third parties are acting in a professional capacity, for example an auditor, and there are appropriate confidentiality and privacy measures in place.
Credit Reference Agencies
In relation to Borrow, we share your personal information with credit reference agencies, Experian, TransUnion and Equifax (as described above). This includes reporting default or repayment arrangements to credit reference agencies. This reporting may make obtaining future credit more difficult. To find out more about how credit reference agencies use your information, see the Credit Refererence Agency Information Notice for Experian here, for TransUnion here, and for Equifax here.
We may share your personal information with introducers, aggregators, brokers or financial advisers you may have engaged on your behalf.
In relation to Jars, we may share your information (which we may anonymise) with NEST pensions and/or research organisations for the purpose of conducting surveys or research. We will only share this information where you have given us your consent. If you wish to withdraw your consent, please let us know at firstname.lastname@example.org.
In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective or actual seller or buyer of such business or assets.
Using other websites
Our Site and App may contain links to websites which are owned or controlled by parties other than Salary Finance. These links are provided for your convenience and do not imply that we have reviewed or condone the third-party sites, their content or their privacy policies.
Our Site may also automatically transfer you to a third party site in order to fulfil the services we provide to you. In such cases, we will carry out due diligence to ensure third parties have the appropriate data protection requirements in place.
When you access linked third party websites, you do so at your own risk. These sites may place their own cookies or other files on your computer, collect data or solicit personal information from you. We will not be held liable for any misuse of your information or other misconduct by the third party.
Where in the world we send information
Salary Finance Limited is based in the UK, and this is where we operate our software platform. However, in order to provide our services to you, a reduced subset of your personal information may be transferred outside the UK and European Economic Area to make use of certain services. Whenever Salary Finance transfers your personal data outside of the UK and European Economic Area, we impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the UK and European Economic Area. We may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing. For example, transfers to certain organisations in the United States of America will be subject to appropriate additional safeguards as required by applicable data protection laws
To make sure we keep your personal information safe, we apply strict safeguards when transferring it overseas. For further information about these safeguards, please contact our Data Protection Officer at email@example.com.
How long we keep your personal information for
- legal and regulatory requirements and guidance;
- limitation periods that apply in respect of taking legal action;
- our ability to defend ourselves against legal claims and complaints;
- good practice; and
- the operational requirements of our business.
These reasons vary from one piece of information to the next depending on the products and/or services you have signed up for, so the amount of time we keep your personal information for may vary.
In all cases, our need to use your personal information will be reassessed on a regular basis, and information which is no longer required for any purposes will be disposed of.
For further information about our retention periods, please contact our Data Protection Officer at firstname.lastname@example.org.
In some instances, our use of your personal information may result in automated decisions being taken (including profiling) that legally affect you or similarly significantly affect you (for example, whether you are accepted for a loan).
By “automated decisions” we mean decisions made solely by automated means (for example, software algorithms) without any human review. By “profiling” we mean automated processing of personal data to evaluate certain things about you. For example:
- we use automated decisions and profiling to assess your suitability for our products and/or services (including affordability), the interest rate we should offer you, if you are eligible for a product with different contractual terms, e.g. loan amount and/or term and to predict the likelihood of you making loan repayments; or
- if our processing reveals your behaviour to be inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity, or you appear on an official sanctions list, our systems may automatically determine that you pose a fraud or money laundering risk.
The personal information that we may use as part of any automated decisions (including profiling) includes the information that you (or third parties) provide to us, as described above in the Information we collect from you and the Information we collect from third parties sections.
Automated decision-making is used so that we can determine efficiently and accurately whether to offer you the products and/or services you apply for (and therefore whether we can enter into a contract with you) or offer suitable alternatives (if eligible) and so that we can perform our obligations under our contract as a responsible lender.
We have implemented measures to safeguard the rights and interests of individuals whose personal information is subject to automated decision-making. When we make an automated decision about you, you have the right to contest the decision, object to profiling, to express your point of view, and to require a human review of the decision. You can exercise this right by emailing us at email@example.com. If you object to automated decision-making or profiling of your personal data, this may affect our ability to provide you with the products and/or services that you request.
Your rights in respect of the processing
It is important that you understand your rights in relation to your personal information and how you can contact us if you have any concerns or queries. You have the following rights (subject to certain exemptions/qualifications permitted by law or regulation):
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure/be forgotten
- The right to restrict processing
- The right to data portability
- The right to object
- Rights relating to automated decision making and profiling
Where you have given us consent to process your personal information, you have the right to withdraw that consent at any time by contacting us at firstname.lastname@example.org. This will not affect the lawfulness of processing based on your consent carried out prior to you withdrawing your consent.
You have a right to request access to or rectification of your personal information (including any information we have used to create any profile) that we hold about you.
You also have the right to erase your personal information, to restrict or stop processing or delete it. It’s worth noting that in some cases if you do ask us to correct, delete or stop processing it, we won’t always be required to do so. In such instances, we will explain why.
To exercise any of the above rights, please submit your request via email to email@example.com and provide your name, postal address and telephone number and any other proof of identification that we may request. If you are contacting us on behalf of someone else, you must provide signed authority from the individual whose data is required. We will normally have up to one month to respond to your request (although this may be extended in certain circumstances).
Where requests are made this will be in accordance with legal, regulatory, accounting requirements and our retention policy.
The security of your Personal Information is very important to Salary Finance. We use physical, electronic, and administrative controls that are designed to protect your Personal Information from loss, misuse and unauthorised access, disclosure, alteration and destruction. We adhere and are certified to the ISO 27001 standard for information security management systems.
We have several layers of security measures in place to protect your information, including:
- Enterprise-level security infrastructure, including physical security measures, to guard against unauthorised access to systems;
- Up-to-date, automated, and centralised anti-virus software to protect against viruses damaging data and infrastructure;
- Regular reviews of our information collection, storage and processing practices, including backups, encryption, and retention; and
- On-going governance and auditing in line with industry best practices and international certification standards.
How to make a complaint about the use of your data
We endeavour to deliver the best levels of customers service however if you think we are falling short please contact our data protection officer at firstname.lastname@example.org.
If you’re unsatisfied with any aspect of how we handle your personal information you have the right to contact the Information Commissioner’s Office, the supervisory authority.
- Going to their website at https://ico.org.uk.
- Phone on 0303 123 1113.
- Post to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, K9 5AF.
PART 2 - WORK REPORT
Work Report enables you to digitally access and share information about your employment with your chosen trusted third parties in seconds. These trusted third parties may be providers of financial products you are applying for, or parties who require information about you, for example, as part of a tenancy or new employment check.
Work Report makes the sharing of employment information simple and secure, accelerating the time it takes for application decisions to happen – for example for mortgage, credit, tenancy, employment, insurance, utilities or telecoms decisions.
Work Report (provided by Experian) provides digital access to employment information from some of the UK’s largest employers. Salary Finance is a partner of Work Report, so when you use Work Report to verify your employment and income information, Salary Finance will share such information with Experian and its affiliates for the purposes of Work Report.
If you are completing an application with a business that is partnered with Work Report (for example a mortgage provider), they could give you the option to digitally verify your employment information via Work Report instead of providing payslips or a letter from your employer.
When would I use Work Report?
There are many examples of when you might be able to use Work Report:
- As part of an employment check when you get a new job
- As part of a mortgage or remortgage application
- As part of an application for a personal loan, car loan or credit card
- As part of a tenancy check when renting a house or flat
- As part of receiving insurance quotes or to make a claim
- As part of receiving tailored product offerings on price comparison websites
- As part of an application for telecoms or utilities services
What will happen with my data?
When you wish to share your employment or income data, the provider of the product or service or checks that you’re using (the “Data Recipients”) will tell you whether you can use Work Report to verify your employment and income information (instead of manually providing this information, for example, by uploading copies of payslips). To do this, the Data Recipient will share certain information about you with Work Report to enable Work Report to determine whether your employment and income information is held by Salary Finance.
If so, you will be able to use Work Report to verify your employment and income information digitally. Through Work Report, you will be able to access employment information held about you by your employer, and choose to share this information with your Data Recipients.
What is Salary Finance’s role in Work Report?
PART 3 - CIFAS PRIVACY NOTICE
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity.
If fraud is detected, you could be refused certain services, finance, or employment.
For further information, please see the CIFAS Privacy Notice here.