PERSONAL AND BUSINESS DATA AND LLOYDS TSB COMMERCIAL FINANCE LIMITED

For the purposes of this fair processing notice:

• "We/us/our” means Lloyds TSB Commercial Finance Limited and its successors and assigns;
• “Our Group” means the Lloyds Banking Group which includes us and a number of other companies using brands including Lloyds TSB, Halifax, Bank of Scotland and their associated companies.  More information on the Lloyds Banking Group can be found at www.lloydsbankinggroup.com.  For these purposes “associated companies” includes Lloyds Banking Group plc and any subsidiary, affiliate or other firm directly or indirectly controlled from time to time by either Lloyds Banking Group plc or us;
• “You/your” means the business or organisation whether it be a sole trader, partnership, limited company, limited liability partnership, or unincorporated association (for example, a club or charity) and, where appropriate, the individuals connected with the business or organisation whose personal information is provided to and/or held by us including your customers / clients.
  

To comply with the terms of the Data Protection Act, we are required to advise you of a range of actions which we may wish to undertake. The purpose of this note is to explain to you what these actions are and to clarify your legal rights and our obligations. 

Data that we hold about individuals is protected by the Data Protection Act.  The Data Protection Act does not apply to Partnerships in Scotland, Limited Companies or Limited Liability Partnerships.   If we do hold any personal data given to us by you, the individual concerned has a legal right to object to the processing of his personal data as described below.  Individuals connected with the business whose data we hold also have the right, on payment of a fee, to receive a copy of the information we hold about them, which may include personal records connected with the business.  To request such information apply to our Data Protection Officer in writing.  The address is:

Lloyds TSB Commercial Finance Limited
No 1 Brookhill Way
Banbury
OX16 3EL 

You may also obtain details of the credit reference and fraud prevention agencies from whom we obtain and with whom we record information about you. You may contact our Data Protection Officer in writing or, initially, by telephone on 01295 202066.

When you transact with us, we will acquire information about your business.  This includes but is not limited to:

• details you give us during financial reviews and interviews; 
• our analysis of your transactions; 
• what we know from operating your account.

Companies in our Group may use and update this centrally held information to:

• provide you with services; 
• identify products and services which might be suitable for you; 
  assess lending and insurance risks;
• recover debts;
• prevent, detect and prosecute fraud and other crimes;
• manage our and any member of our Group’s relationship with you; 
  update our own records about you,

Our Group may also use this information for research and statistical analysis with the aim of improving our services and provide this information to our auditors, advisers and agents.
We treat all personal data and information related to the business or organisation as private and confidential (even when you are no longer a client).  We will not reveal your personal details to anyone outside our Group other than in the following circumstances:

• If we are required to provide the information for legal and/or regulatory reasons;
• If there is a duty to the public to reveal the information;
• If our or our Group’s interests require us to give the information, for example, where we suspect fraud.  But we will not use this as a reason for giving information about you (including names and addresses) to anyone else including other companies in our Group for marketing purposes; 
• If you ask us to reveal the information or if we have your permission to do so;
• If it is needed by our agents and other involved in running the accounts and services for you;
• If we or others need to investigate or prevent crime; 
• In other circumstances provided for by this notice.
  

We may administer your accounts and provide other services from centres in countries outside the European Economic Area (EEA) (such as India and the USA) that do not always have the same standard of data protection laws as the UK.  However, we will ensure that your information is adequately protected, and we will remain bound by our obligations under the Data Protection Act even when personal information is processed outside the EEA. 

If we or any other company in our Group wishes to sell or transfer all or part of its business and assets or any associated rights or interests, or to acquire a business or enter into a merger, we/it may disclose your personal data and confidential business information to any potential buyer or transferee, merger partner or seller and its advisers and any other persons we/it may reasonably decide, provided that each person to whom information is disclosed undertakes to keep it confidential.  If the sale or transfer is completed, the buyer, transferee or merger partner may continue to use and disclose the information subject to the same provisions set out here.

If we are asked to respond to a status enquiry about you, we will make sure we have written permission from you before we give it.

We may monitor or record phone calls with you to check that we have carried out your instructions correctly and to help improve our quality of service.

Credit Reference and Fraud Prevention Agencies

The possible actions that we need to bring to your attention are as follows:

• We will check our own records for information we hold on you and we may search your record at one or more credit reference agencies from time to time. These agencies will add to your record details of our searches and any other organisations carrying out later searches will be able to see that these searches have been made and use this record to verify identities of individuals associated with the business.   
• We may check or share information with fraud prevention agencies to prevent fraud and money laundering. 
• We may provide information about your payment record to credit reference agencies. 
• We may make periodic searches of our Group’s records and credit reference agencies to manage your account including to make decisions whether to continue or extend existing credit. 
• We may use scoring methods and automated decision making systems to assess applications from you and to verify identities.

Credit reference agencies may form a link between any previous or subsequent names that individuals associated with your business use in the records the agencies hold about them. 
If false or inaccurate information is provided or fraud is suspected, details may be passed to fraud prevention agencies or other relevant agencies.  Law enforcement agencies may access and use this information.

We and other organisations may also access and use the information recorded with fraud prevention agencies to prevent fraud and money laundering, for example, when: 

• Recovering debt; 
• Checking details on proposals and claims for all types of insurance; 

We, credit reference and other organisations may use credit reference agencies’ records about you for the purposes set out in the above paragraph and also to check your credit history, verify identities including those of individuals associated with the business if they apply for other services, to trace your whereabouts or the whereabouts of individuals associated with your business, and undertake research, statistical analysis and system testing.

We and other organisations may access from other countries the information recorded by fraud prevention agencies. 

Information about you may be used by us and our Group for training purposes, credit or financial assessments (including establishing credit limits and providing credit ratings for the benefit of other clients), market research and product analysis and preparing statistics, and to recover monies and prevent fraud and money laundering. Such information may affect the credit terms we can offer you.

Marketing

We may also contact you about products and services available from Lloyds Banking Group companies, and from selected companies outside the group, which we believe may interest you or benefit you financially; or for market research purposes. We may do this by post or by phone unless you have told us not to; and by email or other electronic means if you have told us that we can or as otherwise allowed by law. You may tell us at any time if you change your mind.