Who are we
Commercial Associates Ltd T/A CA CARS are registered with the Information Commissioner’s Office (ICO) as a “Data Controller” and we are both a data controller and data Processor of the personal data you provide to us. Our registered address is Welford Road, Kilby Bridge, Wigston Leicester LE18 3TE
What we need
In the conduct of business with you we will need to collect information about you which we will hold as data controllers under the General Data Protection Regulation (GDPR).
We collect information you provide to us which includes, but is not limited to:
Your name, email address, address or postal code, payment method and telephone number. We collect this information in several ways, including when you provide it as part of signing up to our services, inter act with our Customer Service or other employees, or participate in surveys or marketing promotions;
We will not collect any personal data from you that we do not need for providing and overseeing the services that we will provide to you.
Why we need the information
To fulfill our contract with you we have a lawful basis for processing your data, as well as a legal obligation to Financial HMRC.
In accordance with data protection legislation we will handle all information we obtain about you in the course of providing our services, lawfully and fairly in accordance with our position as a data controller.
In accordance with legal and regulatory requirements, we will retain your personal record data for a minimum period of seven years following the termination of any relationship between us. We will not act upon any request you give us to destroy records relating to your account unless all our regulatory obligations have been discharged.
What we do with it
We will use this information to ensure that our advice and services are suitable for your circumstances. All the personal data we hold about you will be processed by our staff in the United Kingdom and may also be disclosed to selected third parties such as HMRC where there is a legal requirement to do so.
In order to process your application we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess your creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
The identities of the CRAs and the ways in which they use and share personal information, are explained in more detail at https://www.experian.co.uk/legal/crain/
Please be aware that your information may be stored on a cloud-based system whose services are located within the European Union.
The information we collect, and use will depend on the nature of our business relationship with you, as follows:
In relation to the provision of our services, we may process personal data for identification purposes (prior to becoming a customer), for the purposes of anti-money laundering, counter terrorist financing, suitability and appropriateness assessments, "Know Your Client" and credit-worthiness checks, and for any other applicable legal or regulatory reasons. Failure to provide relevant information will mean that we will not be able to provide a service for you.
In relation to providing our services, we may process information collected for the purpose of account administration and other general business purposes. In addition, in order to comply with regulatory obligations, we may collect and disclose certain information about our customers and certain related persons to HM Revenue & Customs and/or other relevant tax authorities overseas.
Sensitive Personal Data
While doing business with us you may either directly or inadvertently provide us with information about your health conditions, religious beliefs or sexual orientation. This type of information is known under the law as “special category information” (you may also know this as “sensitive personal data”) and we require your explicit consent to process this type of information. Commercial Associates Ltd does not require or process this information for any purpose, nor will we actively seek to receive it.
Whilst we do take reasonable steps to keep information about you secure when in our possession we cannot guarantee the security of any information you disclose on-line. You accept the inherent security implications of providing information over the Internet and will not hold us responsible for any breach of security or disclosure of your information unless we have been negligent.
We may disclose the information we hold on you without reference to you, to other organisations seeking to verify your identity for anti-money laundering purposes.
To facilitate the provision of services by us we may also transfer information we hold about you to countries both inside and outside the European Economic Area, which may or may not have data protection laws for any of the purposes described in this clause.
We may disclose to HMRC and to any other competent regulatory authority or government agency investigators, inspectors or agents appointed by them, information relating to you or, if relevant, any of your clients or staff.
We may pass information we obtain about you to third parties:
to enable you to gain access to restricted parts of this Website or any other website;
to enable us to provide or for you to receive and/or pay for a Service;
to enable you to receive information you have requested to be sent to you in order to fulfill a request you may have made.
We rely upon the information you provide to us and any subsequent updates. You are responsible for telling us if this information changes.
You should not assume or infer we are aware of changes in any of the above on the basis of other communications, such as receipt of a cheque from a new bank account. Failure to keep us up to date with any of the above may impact the quality of the services we provide to you or affect the receipt of communications between us and you or your agent.
All information you supply will be accurate and we may, as we consider necessary, make enquiries, obtain references and undertake electronic verification checks on any data you provide to us. We may supplement the information you provide to us with information we receive from third parties.
Under the data protection legislation, you have several rights regarding the use of your personal data as follows:
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object
Rights in relation to automated decision-making and profiling
You may contact us at any point in respect of these rights. However, you should be aware that in some cases, such as restricting processing, this may result in us being unable to fulfil our contractual obligations to you, and we will therefore no longer be able to provide a service. You should also note that certain legal obligations will also take president over these rights.
From time to time we may wish to contact you regarding other services we provide or send you our newsletters that we hope you will find of interest. We will not provide this without first receiving consent from you, and you may withdraw your consent to receiving marketing contact and the associated processing of your data at any time which you can do this via telephone or email or post. At no time are you obliged to accept recommendations given in our newsletters or promotions
Please be assured that it will not affect your relationship with us or any services we provide you with if do not give your permission for us to contact you for marketing purposes.
How to complain about the use of your data
If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights mentioned above, you can contact our Data Protection Officer by e mail at firstname.lastname@example.org and we will investigate your concerns.
Alternatively, you may write to us at:
The Data Protection Officer
Commercial Associates Ltd
If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). You can find further information about the ICO and their complaints procedure at the following link https://ico.org.uk/concerns.