At The Mansfield Building Society, we take your privacy seriously. The personal information that you provide to us and how we process it will depend on the products and services that you apply for or obtain from us.
Our Privacy Notice gives full details of the types of information we collect from you, how we use, store and share this information, together with your individual rights. You can obtain a copy from any of our branches, you can ask us to post a copy to you or download the documents below:
PRIVACY NOTICE JUNE 2020
YOUR PERSONAL INFORMATION AND WHAT WE DO WITH IT
The definition of key terms that we use in the privacy notice:
Automated decision making means a process where we make decisions about you, such as your suitability for a product, using a computer based automated system without a person being involved in making that decision (at least first time around).
Profiling means any form of automated processing of your personal information to evaluate certain personal aspects about you, such as to analyse or predict aspects concerning your economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
Process or processing includes everything we do with your personal information from its collection, right through to its destruction or deletion when we no longer need it. This includes for instance collecting it (from you), obtaining it (from other organisations), using, sharing, storing, retaining, deleting, destroying and transferring it overseas.
Legitimate interests is mentioned in our privacy notice because data protection laws allow the processing of personal information where the purpose is legitimate and is not outweighed by your interests, fundamental rights and freedoms. Those laws call this the legitimate interests legal ground for personal data processing.
The Mansfield Building Society of Regent House, Regent Street, Mansfield, Nottinghamshire, NG18 1SS is a data controller of your personal information. This means information that is about you or from which we can identify you. This privacy notice describes how we deal with your personal information. We are the data controller of this information under relevant data protection laws because in the context of our business relationship with you we decide how and why it is processed in the ways explained in this privacy notice. When we use terms such as we, us and our in this notice, we mean The Mansfield Building Society.
We can be contacted on 01623 676300 if you have queries about this privacy notice or wish to exercise any of the rights mentioned in it.
You will see at the end of this privacy notice that we mention the privacy notices of Fraud Prevention Agencies and Credit Reference Agencies. We do need to share these with you. Please read them carefully and contact those organisations if you have questions (their details are in their notices).
This privacy notice may be updated from time to time. This means we may send you an updated copy (depending on whether we are required to do that or not).
Our mortgage products and services are available direct from us as well as through professional and financial advisers and anyone else who acts as a person sitting in between you and us in relation to what we do for you. In this notice we will call these persons “brokers and other intermediaries”.
When a broker or other intermediary processes your personal information on our behalf, this privacy notice will apply and you should contact us to exercise your rights under data protection laws. When a broker or other intermediary processes your personal information as a data controller in its own right, its own privacy notice will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.
This will depend on the products or services you apply for and (if your application is successful) obtain from us. Before we explain what particular information we need in relation to our mortgages and savings products we will explain what information is relevant to all of our products and services including our mortgages and savings products.
If you make a joint application (e.g. with your spouse, partner or a family member), we will also collect the personal information mentioned above about that person. You must show this privacy notice to the other applicant and ensure they confirm that they know you will share it with us for the purposes described in it. The “What are the legal grounds” section (below) contains reference to consent and describes some limited scenarios where it may be relevant to what we do with personal information. If we ask you to obtain consent from the joint applicant (such as for marketing) you should do that using the consent capture mechanism that we give or make available to you for that purpose.
If you apply for your mortgage with a guarantor, that person will see this privacy notice when they submit their own personal information to us because they must sign the application form and provide their details in the application.
If there is somebody who has power of attorney over your affairs, that person will see this privacy notice when we make contact with them directly.
We will generally collect your personal information from you directly. If you are introduced to us by a broker or other intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.
In addition, we obtain your personal information from other sources such as Fraud Prevention Agencies, Credit Reference Agencies (CRAs), your employer, landlord, other lenders, HMRC, DWP, publically available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.
Some of the personal information obtained from CRAs will have originated from publicly accessible sources. In particular, CRAs draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about CRAs below. We have also mentioned above in the lists of personal information that we process some of the CRAs’ other sources of information (which are our own source of information too).
Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations). For some processing more than one legal ground may be relevant (except where we rely on a consent). Here are the legal grounds that are relevant to us:
CCTV systems are used throughout our branch network. The use of CCTV is necessary for our legitimate business interests and we process information collected by CCTV for the purposes of:
We will only use CCTV footage for the above purposes and will only retain it for as long as it is needed. We will only share it in limited circumstances, such as when we are permitted or required to comply with a legal or statutory requirement (e.g. in response to a Police request).
Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details above. The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data, such as about your health, or if you are a vulnerable customer (but these outcomes will be relevant only in cases where we rely on explicit consent for this).
We will tell the broker or other intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do so when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.
To comply with payment services regulations we have to share some of your personal information with other payment service providers in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. This is why if you ask to withdraw consent from what we do with your personal information where we need to have it for the purpose of the payment services regulations, we may still have to hold and use your personal information.
We are based in the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area (EEA). If it is processed within Europe or other parts of the European Economic Area then it is protected by European data protection standards. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA which do not have adequate protection under laws that apply to us. Your personal information will be transferred to India in respect of our Core System Provider (Sopra Steria Ltd).
Safeguards include contractual obligations imposed on the recipients of your personal information. Those obligations require the recipient to protect your personal information to the standard required in the EEA. Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal information. If you require additional information, this can be obtained by submitting a written request to us at Regent House, Regent Street, Mansfield, Nottinghamshire NG18 1SS.
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take banking services from us we may also make periodic searches at CRAs to manage your account with us. To do this, we will supply your personal information 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 both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. 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.
When CRAs receive a search from us they will 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.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail on our website at mansfieldbs.co.uk. The Credit Reference Agency Information Notice (CRAIN) is also accessible from each of the three CRAs through the URL links www.transunion.co.uk/crain, www.equifax.co.uk/crain and www.experian.co.uk/crain.
The personal information we collect from you will be shared with Fraud Prevention Agencies who will use it to prevent fraud and money laundering and to confirm your identity. How we share your information with Fraud Prevention Agencies is explained in more detail on our website at mansfieldbs.co.uk.
You should tell us without delay so that we can update our records by writing to us at Regent House, Regent Street, Mansfield, Nottinghamshire, NG18 1SS or by visiting one of our branches. If you were introduced to us by a broker or other intermediary who is data controller in its own right, you should contact them separately. In some cases where you exercise rights against us under data protection laws (see below) we may need to inform the broker or other intermediary but this will not always be the case.
We are unable to provide you with the mortgage or savings product or to process your application without having personal information about you. Your personal information is required before you can enter into the relevant contract with us, or it is required during the life of that contract, or it is required by laws that apply to us. If we already hold some of the personal information that we need – for instance if you are already a customer – we may not need to collect it again when you make your application. In all other cases we will need to collect it except as follows.
In cases where providing some personal information is optional, we will make this clear. For instance we will say in application forms if alternative (such as work) telephone number contact details can be left blank.
In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, face to face meetings and other communications.
We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or face to face meetings (as relevant) we will do so.
Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes.
Some of our monitoring may check for obscene or profane content in communications.
We may conduct short term carefully controlled monitoring of your activities on your mortgage or savings account where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, were we suspect fraud, money laundering or other crimes.
Telephone calls and/or face to face meetings between us and you in connection with your application and the mortgage or savings product may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls and/or face to face meetings for the quality control and staff training purposes.
This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. For instance, in relation to transactions on your mortgage or savings account, payments into your savings account from other providers, and triggers and events such as account opening anniversaries and maturity dates. We may do this to decide what marketing communications are suitable for you, to analyse statistics and assess lending and insurance risks.
We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) only where the profiling and other automated decision making does not have a legal or other significant effect on you. In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases you have the right to obtain human intervention to contest the decision (see ‘rights in relation to automated decision making which has a legal effect or otherwise significantly affects you’ below). Profiling for direct marketing can mean there is a separate right to object (see ‘rights to object’ below).
Unless we explain otherwise to you, we will hold your personal information for the following periods:
If you would like further information about our data retention practices, you can contact us using the details above.
Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to exercise any of them we will explain at that time if they are engaged or not.
You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/
If you wish to exercise any of these rights against the Credit Reference Agencies, the Fraud Prevention Agencies, or a broker or other intermediary who is data controller in its own right, you should contact them separately.
Your personal information may be converted into statistical or aggregated data which cannot be used to re-identify you. It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.
We may use your home address, phone numbers and email address to contact you according to your marketing preferences. This means we do this only if we have a legal ground which allows it under data protection laws – see above for what is our legal ground for marketing. You can stop our marketing at any time by writing to us at Regent House, Regent Street, Mansfield, Nottinghamshire, NG18 1SS, by visiting one of our branches, calling us on 01623 676300 or by following the instructions on how to do that in the marketing email or other communication.
We have mentioned that we share your personal information with Fraud Prevention Agencies and Credit Reference Agencies. They require us to pass on to you information about how they will use your personal information to perform their services or functions as data controllers in their own right. These notices are separate to our own and are available as detailed above.