We have developed this notice because we want you to feel confident about the privacy and security of your personal information and because we would like to explain how we will use and process it. Morses Club PLC (“we”, “us”, “our”) is your controller and abides by applicable data protection laws.
When we refer to "personal information" in this Privacy Notice, we mean information which identifies you as an individual (whether on its own or in connection with other information that we hold about you). For example, your name, address, email address, phone numbers, and perhaps some less obvious details like a list of payments you already make. We hold, use and share data about you in your capacity as a consumer for the purposes mentioned in this Privacy Notice.
We have a Data Protection Officer who can be contacted by e-mail at DPO@Morsesclub.com, by telephone on 0330 0450749 or by post at:
Data Protection Officer
Building 1, The Phoenix Centre
1 Colliers Way
Please read this Privacy Notice carefully. It explains clearly how we will use your personal information collected when you use our website and/or apply for, and are accepted for, a loan and as part of the other services that might be included as part of this process.
This Privacy Notice applies to how Morses Club deals with your personal information which is collected through our www.morsesclub.com website (our “website”), when you apply for a loan product or when we are otherwise in contact with you (for instance when you call us or email us). It does not apply to any other company or to any other company's websites even if you access them through Morses Club. If you disclose your personal information to other companies your information will be dealt with according to their own privacy policies and practices.
In the terms and conditions of your loan agreement you will see additional information about data protection, credit checks and how we use and share your personal information. For the avoidance of doubt, this Privacy Notice is our primary Privacy Notice and any additional items covered in your loan agreement should be considered as supplemental.
You may also be required to enter into terms and conditions associated with each of our services you use (for instance, we will ask you to sign terms and conditions which are in a loan agreement if your application for a loan is successful).
We collect the following personal information from you:
|Category of Personal Data:||Collected From:|
|Your full name and initials*||You - Completing the loan application form or contacting us You – This information will be collected if you have been introduced as part of the Recommend a Friend process Brokers and other providers of loan products|
|Your postal and correspondence address(es)*||You - Completing the loan application form or contacting us You – This information will be collected if you have been introduced as part of the Recommend a Friend process Brokers and other providers of loan products|
|Your date of birth*||You - Completing the loan application form or contacting us Brokers and other providers of loan products|
|Your marital status*||You - Completing the loan application form or contacting us Brokers and other providers of loan products|
|Your contact telephone numbers (daytime and evening)*||You - Completing the loan application form or contacting us You – This information will be collected if you have been introduced as part of the Recommend a Friend process Brokers and other providers of loan products|
|Your e-mail address*|
|Your National Insurance number*||You - Completing the loan application form or contacting us|
|Your employment status*||You - Completing the loan application form or contacting us|
|Your salary*||You - Completing the loan application form|
|Details of your non-salary income*||You - Completing the loan application form or contacting us|
|Details of your regular or one-off expenses*||You - Completing the loan application form or contacting us|
|Your requested loan amount*||You - Completing the loan application form or contacting us Brokers and other providers of loan products|
|The reason for your loan*|
|Bank Name, Bank Account Number and Sort Code||You – During your loan by completing the bank details form in the Morses Club Customer App|
|Details of your payment history for (previous or current) loans taken with Morses Club*||Our records of your previous or current loans with us|
|Your credit status and history (including the information set out in Section 4 below)*||Credit reference agencies and fraud prevention agencies|
|Your history of name changes*||You - Completing the loan application form or contacting us. We will also receive information about your history of name changes from Credit Reference Agencies (see “Credit Checking and Account Management” below)|
|Your postal address history*||You - Completing the loan application form or contacting us. We will also receive information about your history of name changes from Credit Reference Agencies (see “Credit Checking and Account Management” below)|
|The number of adults in your household*||You - Completing the loan application form or contacting us|
|The number of children in your household||You - Completing the loan application form or contacting us|
|Your residential status (whether you own or rent your home)*||You - Completing the loan application form or contacting us|
|Details of whether you have any special needs or are otherwise vulnerable*||You - Completing the loan application form, contacting us or during home visits.|
|Your marketing preferences||You - Completing the loan application form or contacting us|
|Your signature*||You - Completing the loan application form or contacting us|
|Photographic evidence of your finance documentation (e.g. Wage slip), which may include information from anyone you share an account with (e.g. Joint Benefits Claim). Required when income hasn’t been verified by a CRA check.||You – Completing the loan application form|
|Details of Your Morses Club Card Account||From the prepaid Morses Club Card Provider|
|Your comments or other information entered via our “Contact Us” page, any customer satisfaction surveys and/or in any communications between you and us including home visits.||You - Completing the loan application form or contacting us, or during home visits.|
* The processing of these categories of personal data is mandatory in order for us to assess your eligibility for a loan and to enable us to administer the loan during its term. A failure to provide this information may result in us being unable to offer you our products and services.Cookies
We will use your personal information in the following ways:
|Purpose||Categories of personal data||Lawful basis for processing|
|To verify your identity and credit standing and to enable us to consider and process your application for a loan or other products or services.||All categories of personal data set out in Section 2 above except your marketing preferences.||This processing is necessary for the performance of our contract with you. This processing is necessary for compliance with legal obligations to which we are subject.|
|To assess your credit history and confirm your employment details (as explained further in Section 4.)||All categories of personal data set out in Section 2 above and Section 4 below except your marketing preferences.||This processing is necessary for the performance of our contract with you. This processing is necessary for compliance with legal obligations to which we are subject.|
|To perform actions in line with the contract we have with you (in particular, the loan agreement) including administering and servicing your account with us.||All categories of personal data set out in Section 2 above.||This processing is necessary for the performance of our contract with you.|
|To collect unpaid loans and debt that may be owed by you to us.||All categories of personal data set out in Section 2 above except your marketing preferences.||This processing is necessary for the performance of our contract with you.|
|To enable your loan to be paid directly into your nominated Bank Account through Faster Payments.||Your Bank Name, Bank Account Number and Sort Code.||This processing is necessary for our legitimate reason of providing your loan funds via Faster Payments.|
|To enable us to provide you with Morses Club Card Information.||Details of Morses Club Card Transactions||This processing is necessary under legitimate interests to allow us to manage your Morses Club Card and provide you transactional information.|
|To develop, manage and market products and services to meet your needs, to determine your eligibility for different products and services that you may be interested in and notify you about changes to our website, our services or our products.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of creating new or updated products and services to improve our service offering to existing and potential new customers.|
|To communicate with you to provide you with information about the products and services that you request from us (including for direct marketing purposes if you have opted in).||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of marketing new products and services to existing and new customers. Where necessary for direct marketing purposes, we will process your personal data with your consent.|
|Customer satisfaction surveys to monitor and improve the quality of our product and service offerings (which may involve using your data in quality and performance training).||Your full name and initials; postal and correspondence address(es); contact telephone numbers; e-mail address; comments or other information entered into via our “Contact Us” page, any customer satisfaction surveys and/or in any correspondence between us.||This processing is necessary for our legitimate interests of assessing our performance levels and evaluating new ways to improve our products and services.|
|To undertake market analysis, forecasting, business planning and auditing exercises in connection with our business.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of management planning and forecasting in relation to our business.|
|To communicate with you in connection with any enquiries or complaints that you raise.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of responding to questions and comments raised by individuals that contact us.|
|To detect, prevent and investigate actual and potential fraud and related activities.||All categories of personal data set out in Section 2 above.||This processing is necessary for compliance with legal obligations to which we are subject.|
|To comply with laws and our regulatory requirements.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of complying with laws and regulatory requirements.|
|To, establish, defend, exercise, enforce or to protect our rights, property or safety, or that of our customers, employees or other persons with whom we have a business relationship.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of establishing, defending, exercising, enforcing or protecting our rights and others with whom we have a business relationship.|
|For monitoring and recording of telephone calls and email communications where necessary for compliance with regulatory rules or self-regulatory practices or procedures relevant to our business, to prevent or detect crime, for quality, training and security purposes.||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of complying with regulatory rules and ensuring we are implementing quality checking and compliance processes.|
|To anonymise your personal data for market research, statistical and analytical purposes, including producing statistical research and reports||All categories of personal data set out in Section 2 above.||This processing is necessary for our legitimate interests of creating anonymous data sets that we can use for research, statistical and analysis purposes.|
|To enable us to contact you via the Recommend a Friend process||Your full name and initials; postal and correspondence address; contact telephone numbers (daytime and evening) and, e-mail address.||There are legitimate interests in this processing when you have decided to follow the Recommend a Friend process.|
Where we process personal data relating to whether you have any special needs or are otherwise vulnerable, we will process this only:
- where you have given explicit consent to the processing of such data;
- for the establishment, exercise or defense of legal claims;
- where the processing is necessary for the purposes of carrying out obligations and exercising specific rights in the field of social security and social protection law;
- where you have manifestly made public that personal data; or
- where the processing is necessary for reasons of substantial public interest.
If you apply for a loan we will use credit scoring and other automated systems to assess your application, assess your ability to sustainably repay your loan commitment, and verify your identity.Automated Decision Making
Our automated systems are used to make a recommendation about whether you should be accepted for a loan. These systems compare the information in your application form, historic data held by Morses Club PLC regarding your current or historic payment performance, and data gathered from credit reference agencies to assess the risk of non-payment if we were to grant you a loan. They do this by processing your name, addresses, date of birth, employment status, requested loan amount, reason for your loan, previous payment history, and credit status and history to evaluate whether you are likely to be able to repay your requested loan amount.
Our automated systems gather information from Credit Reference Agencies (see below for more information) and/or data held by Morses Club PLC about your credit score and credit history. The systems check this information against our bespoke scorecards and credit policy rules to assess the suitability for your application. If you do not meet the minimum eligibility criteria, then your application will be declined. If you exceed the minimum criteria, the systems will use the information to determine the maximum loan value that Morses Club will be able to offer you.
A final decision as to whether to accept your loan application and the value that Morses Club may loan to you will be made, by a member of our team, following an affordability assessment (based on your verified salary, details of your non-salary income, details of your regular or one-off expenses, and credit reference agency data to determine your current credit commitments) who will determine your ability to sustainably repay your loan commitment.
You have a right to request that your application is reviewed by a member of our team, to express your point of view on the decisions that we make about you and to contest our decisions.Credit Reference Agencies
We will check your records through one or more credit reference agencies (“CRAs”) when considering your application. CRAs supply us with details of your credit history and associated information as well as information from the electoral register which is used to verify your identify and your residence.
When CRAs receive a credit check search request from us, they will always record details of this search and this means they will place a search ‘footprint’ on your credit file. That footprint will be seen by other lenders and persons unrelated to us (i.e. the other customers of the CRAs) if they undertake credit checks on you in the future in connection with their own financial products and services; we will carry out “soft” searches at the CRAs after the full credit check searches if we need additional verification of your identity after receiving the result of the full credit search and if we do this no-one else except you would see that we have made this additional enquiry.
Furthermore, Morses Club may also undertake an administration search. This type of search may be conducted in order to assess a customer’s ongoing suitability/affordability for new products and offers. These searches can only be viewed by Morses Club, the customer and the credit reference agencies.
TransUnion Information Group may copy, store, use and sub-license the Input (including the electronic mail and internet protocol addresses that form part of the Input) to enable the TransUnion Information Group companies to provide services to their clients in which the Input is used to assist with identity verification and prevention of fraud/money laundering only. More information about this is available at the following link:
We will provide information about this agreement and your repayment performance to all of the CRAs. We report to these third parties at least once a month, including details of the payments you make, payments that you do not make on time and details on any default against this agreement. Our records will remain on your credit file for 6 years after they are closed, whether settled by you or defaulted by us.
The personal data that we will share with CRAs include your:
- Your full name and initials;
- Your postal and correspondence address(es);
- Your date of birth;
- Your marital status;
- Your contact telephone numbers (daytime and evening);
- Your e-mail address;
- Your National Insurance number;
- Your history of name changes;
- Your postal address history;
- Your Bank Name, Bank Account Number and Sort Code;
- Details of your payment history for loans taken with us.
The CRAs can also share your information with other organisations.
CRAs will provide us with the following information relating to you:
- Your name and aliases;
- Your date of birth;
- Your address and contact details (including address links where it appears you have moved house);
- Your financial details including details of your debts;
- Your court judgments that have been issued against you;
- Your bankruptcies, Individual Voluntary Arrangement (IVAs), debt relief orders and similar events relating to you;
- Fraud prevention indicators;
- "Gone away indicators" (which indicate whether you have left an address, deceased or partially settled your account);
- Search footprints where enquiries have been made about you;
- Your credit scores and ratings;
- Your financial associations to which you are linked;
- Flags and triggers, for example where you may be flagged as subject to fraud, and indicators of the certainty of the information they provide;
- Your insolvency and repayment history;
- Your phone number data
- Politically exposed persons (PEPs) and sanctions data.
We and those other companies will use these records and other information to make credit decisions about you. The CRA records will also be used to make credit decisions about your current spouse, partner or other individual that has been financially linked or associated with you (for example if you have a joint account with them). We will: search, link and/or record information at CRAs about you both; link any individual identified as your financial associate, in our own records; take both your and their information into account in future applications by either or both of you (as relevant), and continue this linking until one of you notifies us that you are no longer linked; links between all such persons will remain on your and their files at the CRAs until such time as you or the other relevant person successfully files for a disassociation with the CRAs. If your circumstances change such that you are no longer a financial unit with another person, you should contact the CRAs directly using the contact details in the “How to find out more about Credit Reference Agencies” section below.
More information about CRAs and how they use personal data is available at the following links:
- For Experian: www.experian.co.uk/crain
- For Equifax: www.equifax.co.uk/crain
- For TransUnion: www.transunion.co.uk/crain
You can contact the CRAs currently operating in the UK; the information they hold will not be the same so it is worth contacting them all.
- TransUnion International UK Limited One Park Lane, LEEDS, LS3 1EP Tel: 0330 024 7574 or email: firstname.lastname@example.org
- Equifax Ltd, Customer Service Centre, PO Box 10036, LEICESTER LE3 4FS Tel: 0333 321 4043 or 0800 014 2955 or email UKDPO@equifax.com
- Experian, PO BOX 9000, NOTTINGHAM, NG80 7WP Tel: 0344 481 0800 or 0800 013 8888
- CreditSafe, Creditsafe Business Solutions Limited, Bryn House, Caerphilly Business Park, Van Road, Caerphilly or visit www.creditsafe.com/gb/
In addition, as a normal part of our business we will share your details with:
- our market research provider to enable them to conduct customer satisfaction surveys on our behalf to monitor and improve the quality of our product and service offerings;
- where you have requested that your loan is provided on a Prepaid Debit Card, our supplier of Prepaid Debit Cards for the purposes of providing your loan on the Prepaid Debit Card, administering the Prepaid Debit Card and associated transactions and providing support services in connection with it. They remain the data controller for all Personal Information related to the transactions on the prepaid debit card therefore they will issue their own Privacy Notice relating to how they manage this information. This Privacy Notice and their contact information can be found by using the following link https://contis.com/downloads/Contis-Privacy-Policy-General-v1.0.pdf;
- our third party payments provider to enable us to process debit card transactions when you make payments against your loan by debit card;
- our professional legal, accountancy and other advisors and auditors based in the United Kingdom in order to obtain legal, accountancy and other professional advice;
- our IT service providers based in the United Kingdom and India that provide network and storage infrastructure and/or software programs and support to us in connection with the operation of our business;
- Where you have requested that your loan is paid directly to your Bank Account using Faster Payments, our supplier of Faster Payments for the purposes of providing your loan directly into your Bank Account
- debt collection agencies, if your loan account with us falls into arrears, to enable them to make contact with you (whether in person, by post, email or telephone) and recover the sums owed.
- we use live chat software on our website, this is provided by a 3rd party UK based software company.
Where we have received your personal details from a broker or another provider of loan products, we will notify such broker or loan provider whether you are eligible for a loan application with us and whether you have obtained a loan from us.
We will disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with any laws, regulations or good governance obligations, or in order to enforce or to protect its rights, property or safety, or that of our customers or other persons with whom we have a business relationship. These third parties will include (without limitation) the police, Action Fraud, the National Crime Agency, HMRC, HM Treasury and the Department of Work & Pensions.
In the event that we sell any part(s) of our business and/or assets, we will also disclose your personal data to actual or potential purchasers of parts of its business or assets, and their respective advisers and insurers for the potential purchaser’s legitimate interests of:
- enabling potential purchasers to complete due diligence on, and value, the business and/or assets;
- transferring the personal data in connection with any relevant sale and the transfer of our contractual rights and/or obligations; and
- the use of such personal data by a purchaser for the operation of its business.
We will share your personal data with our:
- IT system developers in India to enable them to support our IT infrastructure. India is not designated by the European Commission as providing an adequate level of protection for personal data. In order to safeguard your personal data in respect of these transfers, we have implemented a data transfer agreement with our supplier which incorporates the European Commission standard contractual clauses for the transfer of personal data to processors established in third countries, under Article 46(2) of the General Data Protection Regulation. You can obtain a copy of this data transfer agreement by contacting us (as set out in the “Our Contact Details” section below);
- Customer communication platform. Data is stored within the EU, but our vendor uses a ‘follow the sun’ support model. Transfer may take place if a representative located in an international location accesses data for support purposes. The international location could be Australia, USA, Belarus or South Africa. The named countries are not designated by the European Commission as providing an adequate level of protection for personal data. In order to safeguard your personal data in respect of these transfers, we have checked that the supplier of the service has data transfer agreement in place which incorporates the European Commission standard contractual clauses for the transfer of personal data to processors established in third countries, under Article 46(2) of the General Data Protection Regulation.
If you take out a loan with us, we will retain your personal data for the period during which your loan remains outstanding and thereafter until the expiry of a period of ten years.
If you apply for a loan and your application was unsuccessful, your personal data will be held by us for up to 50 days.
If you complete a customer satisfaction survey, your personal data in relation to that survey will be held by us for a period of up to 6 months from the date that you submitted the survey response.
If you raise a complaint or there is a dispute between us, your personal data will be held by us for a period of up to seven years following the resolution of the complaint or dispute.
If you raise a general enquiry with us (which does not involve a complaint or dispute), your personal data in relation to that enquiry will be held by us for a period of up to one month.
We will retain your personal data for longer than the periods specified above if required by law, to defend or exercise legal rights (such as defending legal claims) or to comply with regulatory obligations.
It is important to us that you are in control of your own information. As a result, we offer the following controls:
The Right Of Access. You may request access to or copies of the personal information that we hold about (known as a “Data Subject Access Request”) you as set out in the “How can I find out what personal information Morses Club holds about me?” section below. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Rectification. You have the right to have inaccurate information about you corrected. For more information, see the “How can I change the personal information Morses Club holds about me?” section below.
The Right To Erasure. You may request that your personal information be deleted where it is no longer necessary for the purposes for which it is being processed and provided there is no other lawful basis for which we may continue to process such personal information. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Data Portability. Where you have provided us with your personal information that we process using automated means, you may be entitled to a copy of that personal information in a structured, commonly used and machine readable format. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Object. In some circumstances, you may, on grounds relating to your particular situation, have grounds to object to our processing of your personal information. We will consider any objections to its processing on the particular circumstances relating to each case. If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
The Right To Restrict Processing. You may also request that we restrict the processing of your personal information to that to which you have consented or for the establishment, exercise or defence of legal claims or the protection of the rights of another person:
- whilst we verify your data as set out in “The Right To Rectification” above;
- pending verification of our legitimate grounds for processing your personal information; or
- if the processing is unlawful or no longer necessary but you wish for us to retain your personal information for the purposes of establishing, exercising or defending legal claims.
If you would like to exercise this right, please contact us (as set out in the “Our Contact Details” section below).
Furthermore, you can also exercise your right via the Information Commissioner, who is the supervisory authority and an independent regulator. Details Below:
Telephone: 0303 123 1113
Information Commissioner's Office
Cheshire SK9 5AF
Your right to access, as detailed above, or to obtain copies of your personal information may extend to (but is not limited to) some or all of the following items below.
- Copy of your Loan Agreement
- Your loan application details
- Your payment history with us
- Statement of Account
- Customer Notes
- Any charges applied to your account
- Telephone calls recorded for quality and training purposes. (Not all calls are recorded)
We will endeavor to return your details from 1 month of receiving the request.
A Data Subject Access Request is free. However, where a request is manifestly unfounded or excessive, we may require a reasonable administrative fee or refuse to act on the request. This will be based on the true administrative cost and will be discussed with the requester on application.
You can make a Data Subject Access Request or exercise your other rights by contacting us (as set out in the “Our Contact Details” section below).
Please tell us if your personal information, including contact details or address, change at any time so that we can update our records. If some of the information we hold about you is inaccurate (for instance because you have changed your marital status or name, or moved house, or changed your telephone number or email address) or incomplete, please contact us (as set out in the “Our Contact Details” section below). We will take steps to seek to correct or update any information if we are satisfied that the information, we hold is inaccurate or incomplete. In certain circumstances, you may also request that we restrict our processing.
If you are opted-in to receive direct marketing communications, for instance when you submit your name and contact details through our website, or when you apply for a loan, we will use your contact information to communicate with you in relation to products and services which you have confirmed you would like to hear about from us. Depending on the specific permissions you gave, we may contact you by post, SMS, telephone or email.
To change your marketing preferences, you can contact us using our contact details set out in our Contact Us page. We will process your request within a reasonable period of time.
Any marketing communication by email or SMS which are from us will also include details of how you may unsubscribe.
We are serious about guarding the security of your personal information and the details of any transactions or applications made. We use the triage of Confidentiality, Integrity and Availability (CIA) as the keystones to our technical and organisational controls. This helps us protect against unauthorised or unlawful processing, accidental loss or destruction of, or damage to, your personal information.
If you require a printed copy of this Privacy Notice or a copy in another format such as audio or Braille, then please contact us using the contact page.
You can contact us by post at Morses Club, Building 1, The Phoenix Centre, 1 Colliers Way, Nottingham, NG8 6AT, by e-mail at DPO@Morsesclub.com by telephone on 0330 045 0719 or using our contact form on our Contact Us page.
Last updated: 08/12/2020