Data Privacy Notice
Within this document we make references to other documents which can be found at the following links:
• Terms & Conditions
• Data Retention Policy
Adrian Welch Finance Brokers is hereinafter referred to as "AWFB."
Last updated: 22/05/2018
1.0 PROTECTING YOUR PRIVACY
We are committed to protecting the privacy and security of our customers and site visitors. We respect how important privacy is. If you have any questions about how we protect your privacy, please contact the data controller at firstname.lastname@example.org.
AWFB act as the Data Controller and will therefore make every reasonable effort to comply with data protection regulation.
This document compliments our Terms and Conditions linked above.
AWFB is a business providing the following services:
• Personal Finance
• Business Finance
• Vehicle Finance
In providing these services, AWFB needs to gather and use certain information about individuals in the provision of those services – it is a Data Controller. These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact (“data subjects”).
This policy describes how this personal data must be collected, handled and stored to meet the business’ data protection standards – and to comply with relevant law and regulation.
1.2 WHY THIS POLICY EXISTS
This data protection policy ensures that AWFB:
• Complies with data protection law and follows good practice
• Protects the rights of employees, customers and partners
• Is open about how it stores and processes individuals’ data
• Protects itself from the risks of a data breach
1.3 RELEVANT LAW AND REGULATION.
The following laws and regulations describe how organisations – including AWFB – must collect, handle and store personal information:
• The Data Protection (Bailiwick of Guernsey) Law, 2017 (the “Guernsey Law”)
• Ordinances and regulation promulgated under the Guernsey Law
• The General Data Protection Regulation (the “GDPR”) of the European Union – with respect to its extraterritorial nature
• Any other international or foreign legislation that may, by reason of its extraterritorial nature, have impact on the processing of personal data in the Bailiwick of Guernsey
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the relevant laws and regulations, personal information must be collected and used fairly, stored safely, kept up to date and not disclosed unlawfully.
The requirements of data protection laws and regulations are underpinned by seven principles, the first six of which state that personal data must:
• Be processed lawfully, fairly and in a transparent manner
• Be obtained only for specific, explicit and legitimate purposes and must not be processed in a manner incompatible with the purpose for which it was collected
• Be adequate, relevant and limited to what is necessary in relation to the purpose for which it is processed
• Be accurate and, where applicable, kept up to date with reasonable steps being taken to ensure that personal data that is inaccurate is erased or corrected without delay
• Not be kept in a form that permits identification of the data subject any longer than is necessary for the purpose for which it is processed
• Be processed in a manner that ensures its security appropriately, including protecting it against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures
The seventh principle applies to data controllers, including AWFB, and states that such data controllers are responsible for, and must be able to demonstrate, compliance with the other six principles.
Data controllers also have an obligation to facilitate exercise of the rights of data subjects (the “Rights”).
1.4 POLICY SCOPE
This policy applies to:
• All staff of AWFB
• All contractors, suppliers, outsource providers and other people working on behalf of AWFB
It applies to all data that the business holds relating to identifiable individuals, whether or not that data falls under the provisions of relevant data protection legislation, including:
• Names of individuals
• Postal and physical addresses
• Email addresses
• Telephone numbers (including mobile telephone numbers)
• Purpose for loan
• Marital Status
1.5 DATA PROTECTION RISKS
This policy helps to protect AWFB from data security risks, including:
• Breaches of confidentiality, for example information being given out inappropriately
• Failing to offer choice, for example all individuals should be free to choose how the business uses data relating to them
• Reputational damage, for example the business could suffer if hackers successfully gained access to sensitive data
1.6 DATA STORAGE
These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the person responsible for data protection as named above.
When data is stored on paper, it should be kept in a secure place where unauthorised people cannot see it. This also applies to data that is usually stored electronically but has been printed out.
• When not required, the paper or files should be kept in a locked drawer or filing cabinet.
• Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer.
• Data printouts should be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts:
• Data should be protected by strong passwords that are changed regularly and never shared between employees.
• If data is stored on removable media (CD, DVD, USB flash drive or external hard drive), these should be kept locked away securely when not being used.
• Data should only be stored on designated drives and computers, and should only be uploaded to an approved cloud computing service.
• Servers containing personal data should be sited in a secure location.
• Data should be backed up frequently. Those backups should be tested regularly, in line with the business’ standard backup procedures.
• Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
• All servers and computers containing data should be protected by approved security software and a firewall.
2.0 DATA USE AND INFORMATION SUPPLIED
Personal data is of no value to AWFB unless the business can make use of it. However, it is when personal data is accessed and used that it can be at the greatest risk of loss, corruption or theft.
• When working with personal data, employees should ensure the screens of their computers are always locked when left unattended, this includes mobile devices upon which data is stored should it be collected via telephone or other methods.
• Personal data should not be shared informally. In particular, it should never be sent by email, as this form of communication is not secure.
• Data must be encrypted before being transferred electronically.
• Personal data should never be transferred outside the Bailiwick of Guernsey, the European Economic Area or an equivalent jurisdiction, unless previously approved by the board due to there being some mechanism in place.
• Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.
2.1 YOUR NAME AND CONTACT & OTHER PERSONAL INFORMATION
This information is a requirement for us to deliver a service to you when you make an application.
We use your information to contact you in regards to your application, and the details will be shared with third party providers to help progress your application.
2.2 CONTACT HISTORY
When you email / text / call us we retain details of our communications, this is to ensure data accuracy and be able to provide you with the which we offer.
2.3 YOUR APPLICATION HISTORY
Application history is stored in accordance to our regular filing method. Upon successful application this will be kept for as long as necessary, guided by AWFB’s Data Retention Policy which can be found here
Unsuccessful applications are destroyed on decision and are unrecoverable.
2.4 SUPPORTING DOCUMENTS
When an application is successful further documents will be required to verify your identity and adhere to local laws.
These documents will be shared with relevant third-party providers as necessary.
2.5 INFORMATION FROM YOUR COMPUTER OR DEVICE
When you browse our website, information is sent to us which includes your IP address, what pages you have visited, your device type and internet browser details. Your IP address may give us information about your location.
This data is used for analytical information to help us improve our website, and so we can monitor our service levels.
The information we store can also be used to help prevent fraud.
2.6 DATA RETENTION
All data is stored for the periods outlined within our Data Retention Policy, which can be found here.
2.7 DATA ACCURACY
The law requires AWFB to take reasonable steps to ensure data is kept accurate and up to date. IT is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible.
• Data will be held in as few places as necessary. Staff should not create any unnecessary instances of personal data.
• Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call.
• AWFB will make it easy for data subjects to update the information held in respect of them.
• Data should be updated as inaccuracies are discovered and as clients advise that it requires updating.
2.8 SUBJECT ACCESS REQUESTS
All individuals who are the subject of personal data held by AWFB are entitled to:
• Ask what information the company holds about them and why
• Ask how to gain access to it
• Be informed how to keep it up to date
• Be informed how the company is meeting its data protection obligations
If an individual contacts the business requesting this information, this is called a subject access request. Subject access requests can be received from the data subject by mail or email.
An individual making a subject access request can request a single copy of their data free of charge. The business will aim to respond to this within 14 days. If the individual requests further copies of their data then administrative costs can be charged at standard rates.
The business will always seek to verify the identity of the individual making a subject access request prior to providing them with any information.
2.9 DISCLOSING DATA FOR OTHER REASONS
There are other circumstances where personal data may be disclosed, without consent of the data subject. This includes situations where the data must be disclosed by reason of local legislation or international agreement.
Under these circumstances, AWFB will disclose the requested data. However, the data controller will seek to ensure the request is legitimate, with approval from the board and legal advisers as appropriate.
3.0 COOKIES & ONLINE ADVERTISING
Like many companies, AWFB may target banners and adverts to you when you are on other websites and apps.
Currently AWFB only advertises using Facebook and the information shared can be controlled by your own settings on the Facebook platform.
3.1 COOKIES WE USE
• Google Tag Manager – this is a required cookie when using the Google Analytics framework.
• Google Analytics Cookie – This provides us with the capability to view user behaviour on the Google Analytics Platform. The data is anonymised and will only display to us as a user and its behaviours.
4.0 YOUR RIGHTS
You have the following rights relating to your personal information;
• The right to be informed about how your personal information is being used (this page)
• The right to request access to the personal information we hold about you.
• The right to request the correction of inaccurate personal information we hold about you.
• The right to request that we delete your data, or stop processing it or collecting it, in some circumstances.
• The right to request that we transfer or port elements of your data either to you or another service provider.
• The right to complain to your data protection regulator.
If you want to exercise your rights, have a complaint, or just have questions, please contact us.
5.0 CHANGES TO HOW WE PROTECT YOUR PRIVACY
We may change this page from time to time, to reflect how we are processing your data. Please check this page for updates. If we make changes the date of the change will be updated at the bottom of this page.
If we make significant changes, we will make that clear on the AWFB website, or by some other means of contact such as email, so that you are able to review the changes before you continue to use adrianwelch.gg.
We will not change the way we use your data without informing you and where required, requesting your consent to do so.
In the event that you wish to make a complaint about how your personal data is being processed by AWFB, you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ODPC.
The details for each of these contacts are:
The person responsible for data protection at AWFB is Adrian Welch: email@example.com.
The Office of the Data Protection Commissioner (ODPC)
Data Protection Office
Guernsey Information Centre
St. Peter Port
Telephone: +44 (0) 1481 742074