Who we are
Elderbridge Limited (‘Elderbridge’) is the “Data Controller” of any personal information that is collected and processed for the purposes of managing your loan account.
This privacy notice applies to all personal information we collect and process about you as a customer of Elderbridge ‘Personal information’ meaning any information about a living individual who can be identified from that information, either by itself or when it is combined with other information.
We respect our customers rights to privacy and to the protection of their personal information. This notice provides information regarding how we use your information, who we share it with, the circumstances under which we share it and what steps we take to protect it.
In this notice, any reference to ‘we’, ‘us’ or ‘our’ are references to Elderbridge Limited.
Our contact details
- Our postal address: Elderbridge Limited, PO BOX 908, Newport, NP10 9NX
- Our Customer Service phone number: 0345 6506237
- Our website address: elderbridge.co.uk.
The type of personal information we collect
We collect, hold and process information for the duration of your loan and, potentially, beyond the end of the term of your loan (subject to any retention periods noted below). Collection and processing activities will be strictly limited to what is absolutely necessary for us to achieve the legitimate purposes we have identified in this notice (below).
The information we collect may include some or all of the following:
- Standard personal information such as your name, address, date of birth and contact details (including your telephone number(s) and email address)
- Financial information including historic and current transactional activity and bank account details
- Where necessary (for example, where we need to consider setting a payment arrangement on an account) details about your personal and financial circumstances, income and expenditure information and information about other outstanding debts
- Documents provided for identification and verification purposes (for example a copy of a passport, divers licence and/or bank statements)
- Information captured as part of recorded telephone conversations with us
To ensure the information we hold about you is kept accurate and up to date, we rely on you to inform us if anything changes as soon as possible. Failing to notify us of any changes is a breach of the terms and conditions of your loan and may adversely affect your legal position if you fail to provide us with the information necessary to effectively maintain your account.
From time to time you may also choose to give us additional information to help us with the administration of your loan, such as information relating to your health. This type of information is classified as ‘special categories of personal data’ and will only be used for specific and limited purposes. We will only record and use this type of information with your explicit consent or where are lawfully permitted to do so if your consent cannot be obtained. Where you provide us with your consent, you can subsequently choose to withdraw your consent for us to hold this type of information at any time by telephone and/or in writing using the contact details provided above.
If you provide us with information relating to another person in relation to your account, for example a dependant/family member or to allow someone to act on your behalf, it may be necessary to collect and hold their personal information on your account. They should be made aware of this notice and agree to us processing their information as described.
Where do we obtain your personal information from?
We have obtained your personal data and other relevant financial information from your previous loan administrator. You may also choose to directly provide us with additional information during, and potentially beyond, the term of your loan.
For the purposes of administering your account, where it is deemed necessary to verify the accuracy of the data and/or for the purposes of collecting the outstanding balance we may access third party data sources and combine and process data from those sources with your personal data. Third party data sources may include one or more of the following:
- Government agencies and registers.
- Credit Reference Agencies (CRAs).
- Fraud prevention and law enforcement agencies.
- Postcode/address search databases and telephone number verification databases.
- Third parties who provide services to you and/or us, (for example Solicitors, debt advice agencies and field agents).
How your personal data will be used by us
We will store, access and use your personal data:
- For the purpose of administering your loan account and collecting the sums outstanding from you,
- To help investigate, prevent and detect fraud or financial crime. This will involve sharing your personal data with CRAs, government agencies and fraud prevention agencies for the performance of credit and identity checks,
- To carry out data analytics so that we can better understand your circumstances and preferences, and so that we can improve our products and services,
- To retain a history of your account for future reference by you and/or us in case of any legal claim.
We will only use your personal information for the purposes for which we collected it. If we need to make any changes to the way we use your information we will notify you before any changes take place, we will also update our privacy notice to reflect those changes.
Legal grounds for our use of your personal data
Our use of your personal data (as described above) is necessary for:
- Our performance of the loan agreement between us,
- Compliance with our legal and regulatory obligations,
- Our legitimate interests which include:
- Helping to prevent and detect fraud and financial crime,
- Carrying out data analytics so that we can better understand your circumstances and preferences, and so that we can improve our products and services,
- Retaining a historical record of your loan account in case of any future legal claim.
Our lawful basis for processing any information you have provided to us specifically relating to your health is your consent. You can withdraw your consent at any time by contacting us using the details provided above.
Who we may share your personal data with?
We may share your information where we have your express permission, or permission from a suitably authorised third-party representative, for example where they may be in possession of a power of attorney document.
We share information with Credit Reference Agencies (CRAs) on an ongoing basis. The information we share will include your personal data, such as your name and account number, and other information regarding the performance of your loan account, such as your payment history and any missed payments or arrangements you may enter in to.
We share information with third parties that provide services to us in connection with the ongoing administration of your loan account. They may include loan administration service providers, debt collection agencies, Solicitors, asset managers, tracing agents, print houses, payment service providers, telephony service providers, providers of specialist services for alternative format communications (such as audio and braille) and storage companies.
We may also be required to share your information with third parties such as law enforcement agencies, judicial bodies, government entities and tax authorities in relation to suspected or actual fraud, financial crime and/or criminal related activities.
We may also share your information with the beneficial owner of your loan. This is the entity who retains the beneficial rights, title and interest to your loan. As the beneficial owner, they may also be the ‘Data Controller’ for any subsequent processing they may conduct involving your personal information. Elderbridge are not responsible for any processing activities directly undertaken by the beneficial owner, details of such activities should be described in their own privacy notice and provided to you.
Keeping your personal information safe
We are committed to ensuring that the information we hold is kept safe and secure. We have a range of physical and technological security measures in place to help us maintain the integrity and safety of your information and help us to achieve and maintain compliance with applicable data protection laws.
Where it is necessary for us to share your personal information with a third service party provider, we will ensure that the transfer of the information is done in a secure and controlled manner. All third-party providers instructed to act on behalf of Elderbridge are only able to process the information shared with them to perform specific tasks or services and must act accordance with applicable data protection laws.
It may be necessary to process your personal data in countries outside of the United Kingdom (UK) and/or the European Economic Area (EEA). If this happens, we will ensure the transfer is compliant with data protection legislation and appropriate physical and/or technological safeguards are in place to protect your personal data. Where a destination country is not deemed to already have adequate safeguards in place to protect personal data, our standard practice is to use approved ‘standard contractual clauses’ for such transfers.
Retention of your information
We will retain personal data for the entire period that your loan remains active and for an additional specified period after the loan has been closed, typically a period of 13 years for a secured loan and 7 years for an unsecured loan.
The criteria that determines the necessary retention period include:
- Our obligation to comply with regulatory or legal requirements,
- Our legitimate interests in complying with good practice in the industry,
- Our legitimate interests, for example to help us respond to queries or complaints, fraud and financial crime, responding to requests from regulators, etc,
- Our legitimate interests in dealing with any disputes or concerns that may arise in the future.
Upon expiration of the specified retention periods (as noted above), your personal data will be deleted. We retain the right to periodically review and amend our retention periods and change them should there be a legal, regulatory, or business requirement to do so.
Your data protection rights
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
- Your right to withdraw consent – Where we rely on your consent to process your personal information you have a right to withdraw it at any time.
- Your right to complain – You have a right to raise a complaint directly with us, the ICO or with both if you are unhappy with the way in which we have handled or processed your personal information.
If you would like to make a request for any of the above, you can contact us in writing or by telephone us using the contact details provided at the top of this notice.
Making a complaint
If you have any concerns about our use of your personal information, you can make a complaint directly to us in writing or by telephone using the contact details provided at the top of this notice.
You can also complain directly to the ICO if you are unhappy with how we have handled or processed your personal information.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
ICO helpline number: 0303 123 1113
Further data protection help and guidance
If you would like more information, help and advice about data protection regulations and your rights as an individual, you can visit the ICO website: https://www.ico.org.uk