Privacy Notice

How your personal information is used by Ray McLennan and his Group companies

 

Last updated 6th March 2019

 

Your information will be held by Ray McLennan and his Group of companies. (More details below on the individual companies.)

 

More information on the Main Company can be found at: www.RayMcLennan.com

 

How we use your personal information

 

This privacy notice is to let you know how Ray McLennan and or companies within the Group will promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a client/customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

 

Our Privacy Promise

 

We promise:

  • To keep your data safe and private.
  • Not to sell your data.
  • To give you ways to manage and review your marketing choices at any
    time.

Data Protection laws (GDPR) changed on 25 May 2018

 

This notice sets out most of your rights under the new laws.

 

Who we are

 

Ray McLennan and The Group is made up of many different legal entities. We'll let you know which you have a relationship with, when you take out a product or service with us.

 

You can find out more about us at: http://www.RayMcLennan.com

 

If you have any questions, or want more details about how we use your personal information, you can ask us using our secure online contact form.

 

Or you can call us on: 01778 344898 (+44 1778 344 898 from outside the UK).

 

How the law protects you

 

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

 

Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside the Group. The law says we must have one or more of these reasons:

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.

 

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

 

What we use your personal information for:

Our reasons

Our legitimate interests

• To manage our relationship with you or your business.
• To develop new ways to meet our customers’ needs and to grow our business.
• To develop and carry out marketing activities.
• To study how our customers use products and services from us and other organisations.
• To provide advice or guidance about our products and services.

• Your consent.
• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty.

• Keeping our records up to date, working

out

which of our products and services may

 interest

you and telling you about them. 
• Developing products and services, and what we

charge for them.
• Defining types of customers for new products

or services.
• Seeking your consent when we need it to

contact you.
• Being efficient about how we fulfil our legal duties.

• To develop and manage our brands, products and services.
• To test new products.
• To manage how we work with other companies that provide services to customers.

• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty.

• Developing products and services, and what

we charge for them.
• Defining types of customers for new products

or services.
• Being efficient about how we fulfil our legal

and contractual duties.

• To deliver of our products and services.
• To make and manage customer payments.
• To manage fees, charges and interest due on customer accounts.
• To collect and recover money that is owed to us.

• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty.

• Being efficient about how we fulfil our legal and

contractual duties.
• Complying with regulations that apply to us.

• To detect, investigate, report, and seek to prevent financial crime.
• To manage risk for customers.
• To obey laws and regulations that apply to us.
• To respond to complaints and seek to resolve them.

• Fulfilling contracts.
• Our legitimate interests.
• Our legal duty.

• Developing and improving how we deal

with

financial crime, as well as doing our legal

duties in this respect . 
• Complying with regulations that apply to us. 
• Being efficient about how we fulfil our

legal and contractual duties.

• To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.

• Our legitimate interests.
• Our legal duty.

• Complying with regulations that apply to us. 
• Being efficient about how we fulfil our

legal and contractual duties.
 

• To exercise our rights set out in agreements or contracts.

• Fulfilling contracts.

 

 

 

Groups of Personal Information

 

We use many different kinds of personal information, and group them together like this.

 

Types of personal information

Description

Financial
 

Your financial position, status and history.

Contact

Where you live and how to contact you.

Socio-Demographic

This includes details about your work or profession,

nationality, education and where you fit into general

social or income groupings.

Transactional

Details about payments to and from your accounts

with us, and insurance claims you might make.

Contractual

Details about the products or services we provide to you.

Locational

Data we get about where you are, such as may come

from your mobile phone, the address where you connect

a computer to the internet, or a shop where you buy

something.

Behavioural
 

Details about how you use our products and services.

Technical

Details on the devices and technology you use.

Communications

What we learn about you from letters, emails, and

conversations between us.

Social Relationships

Your family, friends, and other relationships.

Open Data and Public Records

Details about you that are in public records such as the

Electoral Register, and information about you that is

openly available on the internet.

Usage Data

Other data about how you use our products and services.

Documentary Data

Details about you that are stored in documents in

different formats, or copies of them. This could include

things like your passport, driving licence, or birth

certificate.

Special types of data
 

The law and other regulations treat some types of

personal information as special. We will only collect

and use these types of data if the law allows us to do so:

 

1. Racial or ethnic origin

2. Religious or philosophical beliefs

3. Trade union membership

4. Genetic and bio-metric data

5. Health data including gender

6. Criminal convictions and offences

Consents
 

Any permissions, consents, or preferences that you give

us. This includes things like how you want us to contact

you, whether you get paper statements, or prefer

large-print formats.

National Identifier
 

A number or code given to you by a government to

identify who you are, such as a National Insurance

number.

 

Where we collect your personal information from:

 

We may collect personal information about you (or your business) from other companies within our Group of companies and from these sources:

Data you give to us:

  • When you apply for our products and services
  • When you talk to us on the phone or in branch
  • When you use our websites, mobile device apps, web chat or SignVideo services
  • In emails and letters
  • In other documents
  • In reviews and interviews
  • In customer surveys
  • If you take part in our competitions or promotions.

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

  • Payment and transaction data.
  • Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties we work with, include but not restricted to:

  • Companies that introduce you to us
  • Financial advisers
  • Card associations
  • Credit reference agencies
  • Insurers
  • Retailers
  • Comparison websites
  • Social networks
  • Fraud prevention agencies
  • Payroll service providers
  • Land agents
  • Public information sources such as Companies House
  • Loyalty scheme operators
  • Agents working on our behalf
  • Market researchers
  • Government and law enforcement agencies.

Who we share your personal information with

  • Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
  • HM Revenue & Customs, regulators and other authorities
  • UK Financial Services Compensation Scheme
  • Credit reference agencies
  • Fraud prevention agencies
  • Any party linked with you or your business’s product or service
  • Companies we have a joint venture or agreement to co-operate with
  • Organisations that introduce you to us
  • Companies that we introduce you to
  • Market researchers
  • Independent Financial Advisors
  • Price comparison websites and similar companies that offer ways to research and apply for financial products and services
  • Companies you ask us to share your data with.

We may need to share your personal information with other organisations to provide you with the product or service you have chosen:

  • If you have a debit, credit or charge card with us, we may share transaction details with companies, which help us to provide this service (such as Visa and Mastercard).
  • If you have a product, which has a loyalty scheme, like Avios, we will share your data with that scheme.
  • If you use direct debits, we will share your data with the Direct Debit scheme.
  • If you apply for insurance through us, we may pass your personal or business details to the insurer, and onto any reinsurers.
  • If you make an insurance claim, information you give to us or the insurer, may be put on a register of claims. This will be shared with other insurers.
  • If you have a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property.

We may also share your personal information if the make-up of the Group changes in the future:

  • We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
  • During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
  • If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.

How we use your information to make automated decisions

 

We sometimes (but rarely) use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.

 

Here are the types of automated decision we make:

 

Pricing


We may decide what to charge for some products and services based on what we know.

 

Tailoring products and services
We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.

 

Detecting fraud
We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.

 

Opening accounts
When you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking age, residency, nationality or financial position.

 

Approving credit
We use a system to decide whether to lend money to you or your business, when you apply for credit such as a loan or credit card. This is called credit scoring. It uses past data to assess how you’re likely to act while paying back any money you borrow. This includes data about similar accounts you may have had before.

 

Credit scoring uses data from three sources:

  • Your application form
  • Credit reference agencies
  • Data we may already hold.

It gives an overall assessment based on this. Banks and other lenders use this to help us make responsible lending decisions that are fair and informed.

 

Credit scoring methods are tested regularly to make sure they are fair and unbiased.

 

Your rights


As a person, you have rights over automated decisions.

  • You can ask that we do not make our decision based on the automated score alone.
  • You can object to an automated decision, and ask that a person reviews it.

If you want to know more about these rights, please contact us.

 

Credit Reference Agencies (CRAs)

 

We may carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.

 

If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.

 

We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

  • Name, address and date of birth
  • Credit application
  • Details of any shared credit
  • Financial situation and history
  • Public information, from sources such as the electoral register and Companies House.

We’ll use this data to:

  • Assess whether you or your business is able to afford our products and services
  • Make sure what you’ve told us is true and correct
  • Help detect and prevent financial crime
  • Manage accounts with us
  • Trace and recover debts
  • Make sure that we tell you about relevant offers.

We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time. It will also include details of funds going into the account, and the account balance. If you borrow, it will also include details of your repayments and whether you repay in full and on time. The CRAs may give this information to other organisations that want to check credit status. We will also tell the CRAs when you settle your accounts with us.

 

When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.

 

If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors.

 

You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.

 

CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.

 

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:

  • Who they are
  • Their role as fraud prevention agencies
  • The data they hold and how they use it
  • How they share personal information
  • How long they can keep data
  • Your data protection rights.

Here are links to the information notice for each of the three main Credit Reference Agencies:


Callcredit
Equifax
Experian

 

Fraud Prevention Agencies (FPAs)

 

We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.

 

Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

 

A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.

 

We will use the information to:

  • Confirm identities
  • Help prevent fraud and money-laundering
  • Fulfil any contracts you or your business has with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.

 

FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

 

The information we use
These are some of the kinds of personal information that we use:

  • Name
  • Date of birth
  • Residential address
  • History of where you have lived
  • Contact details, such as email addresses and phone numbers
  • Financial data
  • Data relating to your or your businesses products or services
  • Employment details
  • Vehicle details
  • Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.

Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

 

We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.

 

How this can affect you


If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you or your business may pose.

 

This may result in other organisations refusing to provide you with products or services, or to employ you.

 

Data transfers out of the EEA


FPAs may send personal information to countries outside the European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

 

Sending data outside of the EEA

 

We will only send your data outside of the European Economic Area (‘EEA’) to:

  • Follow your instructions.
  • Comply with a legal duty.
  • Work with our agents and advisers who we use to help run your accounts and services.

If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:

If you choose not to give personal information

 

We may need to collect personal information by law, or under the terms of a contract we have with you.

 

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.

 

Any data collection that is optional would be made clear at the point of collection.

 

Marketing

 

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.

 

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

 

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

 

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

 

You can ask us to stop sending you marketing messages by contacting us at any time.

 

Whatever you choose, you'll still receive statements, and other important information such as changes to your existing products and services.

 

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

 

How long we keep your personal information

 

We will keep your personal information for as long as you are a customer of Ray McLennan or the Group Companies.

 

After you stop being a customer, we may keep your data for up to 10 years for one of these reasons:

  • To respond to any questions or complaints.
  • To show that we treated you fairly.
  • To maintain records according to rules that apply to us.

We may keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

 

How to get a copy of your personal information

 

You can access your personal information we hold by writing to us at this address:

 

Ray McLennan

c/o Morisons Solicitors (RFH)

1 Exchange Crescent

Conference Square

Edinburgh

EH3 8AN

 

Letting us know if your personal information is incorrect

 

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this.

 

If you do, we will take reasonable steps to check its accuracy and correct it.

 

What if you want us to stop using your personal information?

 

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

 

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

 

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.

 

You can ask us to restrict the use of your personal information if:

  • It is not accurate.
  • It has been used unlawfully but you don’t want us to delete it.
  • It not relevant any more, but you want us to keep it for use in legal claims.
  • You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.

 

How to withdraw your consent

 

You can withdraw your consent at any time. Please contact us if you want to do so.

 

How to complain

 

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.


Please let us know if you are unhappy with how we have used your personal information. You can contact us using our secure online contact form.

 

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern.

 

Future formats for sharing data

 

The Data Privacy laws will change on 25 May 2018. From that date you will have the right to get your personal information from us in a format that can be easily re-used. You can also ask us to pass on your personal information in this format to other organisations.

 

We are working with our industry to improve the way your data is shared. We’ll update this notice with more details on a regular basis.

 

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