Privacy notice for respondents to the Fair4All Finance Customer Insights programme

16th Mar, 2022

Background

We are providing you with this privacy notice because you are responding to our customer research survey (the ‘Research Survey) to better understand access to financial services. This Research Survey will allow us to understand the different customer groups (or segments) who can benefit from using affordable credit and other affordable products, how people access these products (or other financial products) today, and understand how people research and shop for different products.

By sharing your information with us, you will help us understand how we can improve access to financial services and how we could make it better for all.

This Research Survey is being conducted by Trajectory Limited on behalf of Fair4All Finance Limited. Fair4All Finance helps community finance organisations to offer affordable credit, and works with other organisations to improve access to financial services for people on low incomes or who are excluded from financial services. The information collected in the Research Survey will also be shared with CACI Limited for processing with their existing data about people in the UK.

To complete this work, we will need to collect and process certain information about you. This privacy notice explains how we use the personal data (information about you) that you provide in this survey.

Who are we?

Fair4All Finance Limited is in charge of the way your personal data is used as part of the Research Survey. For the purposes of data protection law therefore, Fair4All Finance Limited is the data controller:

Fair4All Finance Limited
PO Box 2nd Floor,
28 Commercial Street,
London, E1 6LS

If you would like to contact us about any aspect of this privacy notice or would like to exercise your rights or obtain further information about the way that we process your personal data, then please contact: data@fair4allfinance.org.uk

We are also working with two organisations to deliver the outcomes of this research project, they are referred to as data processors:

Trajectory Limited
New Derwent House,
69-73 Theobalds Road,
London, WC1X 8TA.

CACI Limited
Kensington Village
Avonmore Road
London, W14 8TS

What personal data are we collecting and why?

As part of the Research Survey we will collect and use different types of personal data about you that you provide through this survey. By taking part in the survey, you consent to us using the data for the purposes that we have set out below:

Purpose 1:

Why we are collecting your personal data

To understand different customer groups (or segments) there is personal information we will collect in the survey to understand people’s lives. This includes;

  • Demographic data
  • Information about your financial circumstances

This will help us to understand the different financial circumstances, including debt, credit, income,  and savings, of different customer groups. We also want to understand the different demographic groups (age, family make-up, home ownership, background, race, health). This will help us to identify different segments, and help community finance providers to reach and serve different customer groups more effectively.

What personal data we are collecting

This will include:

  • Your postcode and the area you live in
  • Information about you (such as your age, gender, ethnicity, marital status, financial dependants and property ownership)
  • Information about your personal and financial circumstances (such as your income, expenditure, employment status, whether you are receiving benefits, your savings, information about loans you may have applied for, the reason you want to take out a loan)
  • Information about your health and caring status
  • Information about your financial product holdings (such as whether you have a current account, credit card, insurance, loan or other products, and who you hold these products with)

Lawful basis (as explained below)

You have provided us with your consent to use this information

To the extent that the information you provide is a special category data (see below), we do so on the basis of your explicit consent.

Purpose 2:

Why we are collecting your personal data

To understand what is important to different customer groups when researching and selecting different financial products

What personal data we are collecting

  • Information about your financial product holdings (such as whether you have a current account, credit card, insurance, loan or other products, and who you hold these products with)
  • Information about how you interact with financial services providers (for example whether you shop online, over the phone or in branch) and how you research product information

Lawful basis (as explained below)

You have provided us with your consent to use this information.

Purpose 3:

Why we are collecting your personal data

To understand marketing preferences for different customer groups so we can support community finance organisations to better reach customers who can benefit from their products.

What personal data we are collecting

  • Information about the organisations you hold financial products with, which organisations you are aware and your feelings towards them
  • Your views on marketing messages from different organisations
  • The types of media you use (such as TV, radio, newspapers)

Lawful basis (as explained below)

You have provided us with your consent to use this information.

Some of the personal data we need to collect in connection with this work is more sensitive. We call this “special category personal data”. Special category personal data is defined in law as meeting any personal data that relates to health, racial or ethnic origin, political opinions, sexual orientation, sexual life, religious and philosophical beliefs, as well as genetic and biometric data (where used for identification purposes).

We are processing special category data to understand the financial circumstances of  people from different backgrounds, with different beliefs and with different health conditions to understand where some groups are more excluded from financial services than others. We only process the following types of special category personal data:

  • Information about your race and ethnic origin. This helps us to make sure that our Research Project is inclusive and includes all people, and to understand if some people are more excluded from finance than others;
  • Information about your health (including details of any disabilities) to understand the impact on financial circumstances, and

For all of the above, we will also overlay additional demographic, product and lifestyle data from CACI (www.caci.co.uk) to help us understand how you, or other people like you, interact with financial services, your financial circumstances and your marketing preferences.

We will then build segmentations – this is often described as “profiling” and we create “profiles” using combinations of the information you provide, and data from other places, including publicly available data (such as the electoral register and the UK Census) or derived from surveys and questionnaires.

This will help us design the right products and services, and deliver appropriate marketing, to customers who can most benefit from different products. While the segmentation will involve profiling, no organisations will make decisions on an individual from this data, instead it will be used to inform marketing, operational and product strategies.

 

Our lawful basis for processing your personal data

Data protection law requires us to have a valid legal reason (also known as a “lawful basis”) to process and use your personal data.  In connection with the Customer Insights work, we rely on the following lawful bases:

  • Consent: we will rely on your consent for your personal data to be used. By taking part in this survey, you are providing consent for your data to be used for the reasons outlined above

When processing special category personal data, we also need to identify an appropriate condition for processing this information (in addition to a lawful basis). For this Research Survey, this is;

  • Explicit consent: Where you have given us your explicit consent to use your special category personal data. By completing this survey and providing this information, you are providing explicit consent for us to use the data for the reasons set out above.

 

How we use your personal data and how we keep it secure

We understand the importance of security of your personal data and take appropriate steps to safeguard it.

When we use your personal data we will take steps to make sure it is more difficult to identify you from the information we use (for example, by using statistics instead of information on an individual level, and removing personally identifiable information as soon as reasonably possible).

We always ensure that only authorised persons have access to your personal data, which means only those who need to access your data to fulfil their roles. Everyone who has access to personal data is appropriately trained and aware of their obligations to ensure confidentiality and security of your personal data.

 

Sharing with third parties and transfers outside the UK

We may share your data with other third parties to support our aims of increasing access to financial services. This data will not be personally identifiable to you, and will be at an aggregated level or after any identifiable data has been removed. Third parties may include:

  • Community finance providers so they can understand more about people who are aware of their brand, who use their products or who live within their common bond (the geographic areas they serve)
  • Organisations with similar aims to increase access to financial services (for example Money and Pensions Service, Fair By Design and other organisations)
  • Data analytic specialist organisations we appoint to help us analyse the data

We do not plan to transfer your personal data outside the UK at this stage, but we will let you know if this changes.

 

Source of your personal data

Usually, the personal data we process will come directly from you. In some cases, however, we may also collect your information from third parties, for example, if we are using responses to another survey that you have completed. In this scenario, we will not be seeking to identify respondents individually, only to use the data at an aggregate level.

 

How long we store your personal data

We delete or destroy personal data securely when the purpose for collecting it has been met and there are no other legal reasons for keeping it. For instance, we propose to retain most records relating to the customer insights work for approximately 6 years. This will allow us to set a baseline to measure changes and impacts of our work, as well as compare future customer research data with the outcomes of this research.

We continually review the personal data we hold and will securely delete or anonymise personal data which is no longer required. If you would like further information about our retention periods for specific types of information, please get in touch.

 

Your rights

Under data protection law, you have various rights over the personal data we hold about you. In particular, you have the right to:

  • be informed about how we collect and use your personal data;
  • ask for access to your personal data;
  • require us to correct any mistakes in the personal data we hold about you;
  • ask for the information we hold about you to be erased in certain circumstances;
  • ask for our processing of your personal data to be restricted in certain circumstances;
  • in certain circumstances, receive your data in a form allowing you to transit it to another data controller (portability); and
  • object to us processing your information in certain circumstances.

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Please note, if you decide to withdraw your consent, that doesn’t mean that our use of your personal data before you withdrew your consent is against the law.

If you wish to exercise any of your rights, please contact us using the information in the “Who are we?” section above.

 

Complaints

We have high standards when it comes to protecting your personal data. If at any time you are not happy about the way we are processing your personal data then please contact us using the details in the “Who are we?” section above.

If you are not happy with our answer to your complaint then you can complain to the Information Commissioner’s Office, which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk.