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This fair processing notice applies to our customers and potential customers.
Who we are
Forbes Rentals is the trading name of F. Donald Forbes & Co. Limited (we), a company registered in England & Wales (company number 00687172) whose registered office is at 7 Wells Place, Gatton Park Business Centre, Redhill, Surrey, RH1 3DR. We are a data controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation. Our registration number at the Information Commissioner's Office is Z689716X.
How to contact us
If you have any questions about this fair processing notice or our data protection policies generally, please contact us:
|By post:||7 Wells Place, Gatton Park Business Centre, Redhill, Surrey, RH1 3DR|
|By phone:||01737 647400|
3.1: We are committed to protecting your personal data and your privacy. This fair processing notice sets out the basis on which personal data we collect from you, or that you provide to us, or that we acquire from a third party, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
3.2: Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data.
3.3: It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
3.4: This version of our fair processing notice was last updated on 14th May 2018.
What personal data do we collect and process?
4.1: Data that you give us. You provide personal data to us when you apply for our services, enter into a contract with us and during the lifetime of a contract between us. The personal data you provide may include your:
personal details (including your name, date of birth, and residential address and address history)
4.2: Data provided to us by third parties. Before we provide financing or any other services to you, we undertake credit and identity checks using external credit reference agencies (CRAs) and fraud prevention agencies, and we receive further personal data relating to you in response to such checks.
This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us public (including the electoral register) information as well as shared credit, financial situation and financial history information and fraud prevention information.
4.3: The personal data that we receive from third parties may include:
We also operate and monitor CCTV across our premises and may collect CCTV images of you.
How is your personal data used?
We process and use your personal data for the following purposes:
5.1: Verification of identity and fraud prevention
5.2: Credit checks
5.2.1: Purpose of processing. In order to process your application and before we provide financing or other services to you, we perform credit checks on you with one or more credit reference agencies (CRAs) at the time of your application. We may also make periodic searches at CRAs to manage your account with us, if we suspect fraud or if we spot that you have provided inaccurate data. These checks require us to process personal data about you.
5.2.2: To do this, we will supply your personal data to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us public (including the electoral register) information as well as shared credit, financial situation and financial history information and fraud prevention information.
5.2.3: We will use this information to:
5.2.4: Sharing of data. We will continue to exchange information about you with CRAs while you have a relationship with us. We will inform the CRAs about your settled accounts, as well as advise them of your missing any payment or otherwise not complying with the contract(s) between you and us. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
5.2.5: Consequences of processing. When CRAs receive a search from us they may place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
We may also, in certain limited circumstances, check the record of other members of your family and, if you are a partner or director in a small business, also check on your business.
5.2.6: Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with our legal obligations as a regulated financial provider and such processing is a contractual requirement of the services or financing you have requested.
5.3: Contractual Obligations
5.3.1: Purposes of processing. We will process your personal data for the purpose of entering into a contract with you and thereafter for the purposes of carrying out our obligations under any such contract(s) and if necessary of enforcing any such contract(s). Such processing will include assessing your application for services or financing against our criteria for such services or financing and such processing may include contacting you from time to time by telephone, e-mail or post for the purpose of administering your account, including informing you of any arrears.
5.3.2: Sharing of data. In the course of a contract (including enforcement of a contract), we may share your personal data with our third party service providers or agents who administer parts of the contract(s) on our behalf. Such third party service providers include banks, software service providers (including document management and customer relationship management system providers), data storage providers, debt collection agents, delivery companies, valuation companies and dispute resolution providers. Any personal data shared with a third party service provider is strictly limited to the data required for the third party to provide the relevant services relating to the contract(s) entered between you and us.
We may disclose relevant personal data to any company which provides maintenance of the asset(s) relating to the contract(s) entered between you and us.
We may also disclose your personal data to our or your legal advisors, in particular where this is necessary to enforce any contract(s) entered into between you and us.
5.3.3: Lawful basis of processing. When we, or any relevant third party service provider, process your personal data for the above purposes, we do so on the basis that this is necessary for the performance of a contract relating to you.
5.4.1: Purpose of processing. Where you have provided consent for us to do so, we will process your personal data in order to send you information about products and services which may be of interest to you.
5.4.2: Sharing of data. In the course of sending you marketing information we may share your personal data with our third party service providers or agents in their capacity as our data processors who conduct marketing on our behalf. Such third parties include software service providers including document management and marketing automation platforms. Any personal data shared with a third party service provider is strictly limited to the data required for the third party to carry out marketing services on our behalf.
5.4.3: Lawful basis of processing. When we, or our data processors, process your personal data for the above purposes, we do so on the basis of your consent.
When third party market research organisations process your data in order to collect feedback on our products and services they do so on the basis of a legitimate interest in improving our customer experience.
5.5: Administrative Information
5.5.1: Sharing of data. We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
5.5.2: We may disclose your personal data to third parties:
Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives.
5.6: Compliance with legal obligations
5.6.1: Purposes of processing. We may process (including disclose) your personal data in order to comply with any legal obligations binding on us and to protect the rights, property, or safety of our staff, our customers, or others. We may also process (including disclose) your personal data to our legal advisors for the purpose of establishing, exercising or defending our legal rights.
5.6.2: Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that such processing is necessary for compliance with a legal obligation to which we are subject (including our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015) or necessary in order to protect the vital interests of a natural person, or in our legitimate interests in establishing, exercising or defending our legal rights, respectively.
5.7: Special Category Data
5.7.1: Purpose of processing. Where you have provided consent for us to do so, we will process personal data concerning your health so that we can ensure we provide our products and services in a suitable manner.
5.7.2: Sharing of data. We may share such special category personal data with our third party service providers or agents in their capacity as our data processors who conduct services on our behalf. Such third parties include delivery and installation companies. Any personal data shared with a third party service provider is strictly limited to the data required for the third party to carry out such services on our behalf.
5.7.3: Lawful basis of processing. When we, or our data processors, process your personal data for the above purposes, we do so on the basis of your consent.
5.8 Aggregate Insights
5.8.1: Purposes of processing. Your personal data may be converted into statistical or aggregated data which can't be used to identify you, then used to produce statistical research and reports.
5.8.2: Sharing of data. We may share statistical or aggregated data with our group companies and relevant third parties such as companies which undertake marketing on our behalf.
5.8.3: Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in pursuing business aims and objectives.
5.9.1: Purposes of processing. We use CCTV recording devices across our premises in order to ensure the security of our employees, buildings, and assets. This means that, while you are onsite on any of our premises, you may be recorded by CCTV.
5.9.2: Sharing of data. If required for crime prevention purposes, we may provide footage to the police or other appropriate third parties as necessary.
5.9.3: Lawful basis of processing. When we process your personal data for the above purposes, we do so on the basis that we have a legitimate interest in preventing crime and ensuring staff safety.
Failure to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a consumer hire agreement or other services). In this case, we may have to cancel the consumer hire agreement or service you have with us but we will notify you if this is the case at the time.
7.1: As part of the processing of your personal data, decisions shall be made by automated means in connection with credit profiling and fraud or money laundering risk. This means we may automatically decline the provision of services or financing (i) based on your credit profile with CRAs; or (ii) based on information received from FPAs regarding whether you pose a fraud or money laundering risk.
7.2: You have rights in relation to automated decision-making, including the right to request a review of the accuracy of a decision that you are unhappy with. If you want to know more, please contact us using the details above.
7.3: For the consequences of processing, please see paragraphs 5.1.3 and 5.2.5 above.
8.1: Your personal data is protected by legal rights, which include your rights to:
8.1.1: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
8.1.2: Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
8.1.3: Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
8.1.4: Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
8.1.5: Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8.1.6: Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to your personal data which you initially provided to us, which is processed based on your consent or based on the performance of a contract between us and which is processed by us using automated means.
8.1.7: Withdraw consent at any time where we are relying on consent to process your personal data. Where we rely on your consent you have the right to withdraw consent at any time, although this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain financing or services to you. We will advise you if this is the case at the time you withdraw your consent.
8.2: If you want to exercise any of these rights, please contact us using the details above.
8.3: You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data
We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our contracts.
Where you are an unsuccessful applicant for a financing arrangement for any reason (including you choosing not to proceed with a quote or application), we will usually retain your personal data for twelve months following the later of the date of rejection of an application or the date of expiry of a quote or application.
Where you are a successful applicant for a financing arrangement, we will usually retain your personal data for 6 years following the expiry of all contracts with us relating to you, unless we are obliged to retain your personal data for a longer period as a result of an overriding legal obligation. Such legal obligations include our reporting obligations to the Financial Conduct Authority and HM Revenue & Customs, as well as our obligations under applicable legislation including the Money Laundering Regulations, Bribery Act 2010 and the Modern Slavery Act 2015.
We retain CCTV footage for up to 30 days, after which time the footage is automatically deleted.
We do not transfer personal data outside of the European Economic Area, but we do share personal data with fraud prevention agencies and credit reference agencies who may transfer your personal data outside of the European Economic Area.
Whenever fraud prevention agencies or credit reference agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data. Those obligations require the recipient to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.
The three main credit reference agencies Callcredit, Equifax and Experian (also called 'CRAs') each use and share personal data they receive about you that is part of, derived from or used in credit activity and this is explained in more detail in the Credit Reference Agency Information Notice (CRAIN) available at any of the following:
|Post:||Consumer Services Team, PO Box 491, Leeds LS3 1WZ|
|Phone:||0870 060 1414|
|Post:||Customer Service Centre PO Box 10036, Leicester, LE3 4FS|
|Phone:||0844 335 0550|
|Post:||PO BOX 9000, Nottingham, NG80 7WF|
|Phone:||0870 241 6212|
The two main fraud prevention agencies are:
|Post:||Consumer Affairs, Cifas 6th Floor, Lynton House 7-12 Tavistock Square London WC1H 9LT|
|Post:||PO Box 2756, Stoke-on-Trent, Staffordshire ST6 9AQ|