Privacy | Close Brothers Commercial Finance

Close Brothers Commercial Finance is a business name of Close Brothers Limited and its subsidiaries, Close Leasing Limited, Close Brothers DAC and Close Invoice Finance Limited.

Close Brothers Limited (being a UK registered private limited company and its Irish registered branch of the same name having registration number 907899), trading as (and having as registered business names) Close Brothers Commercial Finance, Close Brothers Asset Finance, Close Brothers Motor Finance and Braemar Finance, is authorised by the Prudential Regulation Authority in the United Kingdom and is regulated by the Financial Conduct Authority and the Prudential Regulation Authority in the United Kingdom. UK registered address: 10 Crown Place, London, EC2A 4FT, registered at Companies House, Number 00195626.

Close Leasing Limited (being a UK registered private limited company and its Irish registered branch of the same name having registration number 910558), trading as (and having as registered business names) Close Brothers Commercial Finance, Close Brothers Asset Finance and Close Brothers Aviation and Marine. UK registered address: Jackson House, Sibson Road, Sale, United Kingdom, M33 7RR, registered at Companies House, Number 06377532.

Close Brothers DAC (being an Irish registered designated activity company having registration number 706530) trading as Close Brothers Commercial Finance, Close Brothers Asset Finance, Close Brothers Motor Finance and Braemar Finance and is regulated by the Central Bank of Ireland. Registered address: Swift Square, Building 1 Santry Demesne, Northwood, Dublin 9, D09 A0E4, Ireland.

Close Brothers Invoice Finance and Close Brothers Commercial Finance are registered business names of Close Invoice Finance Limited, a UK registered private limited company (and its Irish registered branch of the same name having registration number 908024). UK registered address: 10 Crown Place, London, EC2A 4FT, registered at Companies House, Number 00935949.

Introduction / Who we are

"We", "our" and "us" means Close Brothers Limited and its subsidiaries (including Close Leasing Limited, Close Brothers DAC and Close Invoice Finance Limited). “Close Brothers Group” means Close Brothers Limited and its subsidiaries (including affiliates and their respective parent and subsidiary companies). For the purposes of data protection law, we are the data controller in respect of your personal data.

This Privacy notice explains how, why and when we will use your personal data along with the rights you have over that personal data. It also explains how others within the Close Brothers Group will use your personal data, see section 5 for further information. It is therefore important that you take the time to read this Privacy notice.

Personal data that we collect about you

We collect and use various personal data about you and your representatives, this usually comes directly from you and/or your Broker and will include:

Personal details, such as your name, date of birth and nationality
Contact details, such as postal address, email address, telephone numbers
Identity information such as passports and driving licences, along with sanctions and anti-money laundering checks
Financial information including employment, proof of income and expenditure, assets and liabilities, credit and borrowing history
Voice recordings, and where you attend a Close Brothers premises or Event visual images and/or CCTV images
Any other information which is necessary to fulfil the application, such as vehicle or asset details and your personal circumstances including qualifications.

We will also collect and use special categories of personal data and data related to criminal convictions or offences for limited purposes, these include:

Information concerning health

Where you provide personal data about a third party, including family members, joint account holders, guarantors etc you must ensure that they understand the information contained within this Privacy Notice and how we will use their personal data.

How we obtain your personal data

The personal data we collect and use about you is obtained from various sources, and includes the following:

personal data you give to us or through your relationship with us and the way you manage your products and services including the use of our websites
Personal data received from Intermediaries such as dealers, brokers and introducers
personal data from other sources, including:

Other Close Brother group companies
Credit reference agencies, fraud prevention agencies, law enforcement or government agencies
Third parties who provide data services to help us improve the personal data we hold about you
Criminal records checks
Joint account holders
Third parties appointed to act on your behalf
Other banks or financial institutions
Publicly available sources, such as the press, the electoral register Companies Registration Office and Companies House (UK).
Social media where you have interacted with our social media pages
Businesses you own or are associated with, including directors, partners, trustees etc.

Personal data generated or inferred from your relationship and/or engagement with Close Brothers Group companies

What we use your personal data for and the legal basis

To ensure we are meeting our responsibilities when processing your personal data, we must have a suitable legal basis to do so.

In most cases we will rely on the one of the following:

It is necessary for the performance of our contract with you, for example to allow us to provide you with the product or service
It is required by law or regulation, for example to meet our obligations in respect of anti-money laundering activities
We have a legitimate interest which does not outweigh yours, or your rights or freedoms, and where necessary will be supported by a balancing test, for example security activities, or product and service improvements. In the UK, we may use recognised legitimate interests as our legal basis for processing. This will only be in accordance with Annex 1 of the UK General Data Protection Regulation.
We may need your consent to process your personal information, such as using your image for promotional activities
In exceptional circumstances, it may be necessary to process your personal data to protect your life (vital interests).

By way of a more detailed explanation, the following list outlines the purpose for which we will or may process your personal data, and in each case, the legal basis or bases which we will rely on in order to do so:

Purpose	Legal basis
To provide and manage our products and services to you including our communications with you	Performance of a contract Legal obligations Legitimate interests
Assess affordability and suitability of our products and services	Legal obligation Legitimate interests
Complaints management including analysis and complaint related regulatory reporting	Performance of a contract Legal obligations Legitimate interests
Where you may be considered a vulnerable customer, we will process your personal data to support accessibility and providing reasonable adjustments	Legal obligations Where special categories of personal data are also processed, we rely on substantial public interests, and either protection of an individual’s economic wellbeing or to prevent and detect unlawful acts, fraud and financial crime
To verify your identity, the identity of joint account holders or third parties acting on your behalf. ROI Legal Obligations: We are under a legal obligation to verify your identity as part of the account opening process for new customers pursuant to Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021.	Legal obligation Legitimate interests
To monitor, analyse and improve services, and for training and quality purposes. This includes the monitoring and recording of communications including phone calls as well as quality assurance activities.	Legal obligations Legitimate interests
To develop and improve products and services, including identification of new business opportunities. This also includes personal data of applications which have been declined.	Legitimate interests
To undertake activities relating to the prevention of money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. This may require us to process information about criminal convictions and offences including sharing of data with law enforcement and regulatory bodies ROI aligned to our legal obligations under the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 to 2021.	Legal obligations
Data sharing with credit references agencies (see Section 6 below for full details)	Legal obligations Legitimate Interests
Data sharing with Regulators and trade organisations	Legal obligations Legitimate Interests
To trace debtors including recovery of debt and/or assets	Performance of a contract Legal obligations Legitimate interests
Data sharing with third party providers of products or services, such as but not limited to insurance products	Consent
Data sharing with police, law enforcement, tax authorities or other government and fraud prevention agencies, including reporting suspicious activity and complying with production and court orders	Legal obligations Legitimate interests
To monitor your use of our information and communication systems to ensure they remain secure. To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution;	Legitimate interests
Compliance with all applicable laws and regulations	Legal obligation Legitimate interests
Protection of our legal rights and interests, including in connection with any actual or prospective litigation, internal or regulatory investigation.	Legitimate interests
Provision of marketing information related to Close Brothers groups products and services. This may include provision of marketing online, however, we will not provide your personal data with third parties for their own marketing purposes. Provision of direct marketing activity promotions or events that we publicise through our social media channels.	Legitimate interests Consent
Data sharing in relation to a prospective buyer of any Close Brother group companies or assets	Legitimate interests

Who we will share your personal data with

We will not share your personal data with any third party outside of the Close Brothers Group except in the following circumstances:

Close Brothers Group companies for the purposes as set out in Section 4 above.
Where we have your permission, including your advisors who you have authorised to act on your behalf
Where you have provided your consent, to third party affiliates who may wish to offer you their products and services which may be of interest to you
If applicable, your broker who introduced you to Close Brothers
Registers of financed assets (for the purposes of preventing fraud)
With third parties providing services to us, such as customer service and/or complaints services, companies that print our correspondence, data storage providers and technical support.
Other banks and third parties in relation to (actual or suspected) fraud or financial crime activities, such as fraud prevention agencies
Credit reference agencies, Companies Registration Office and the Central Credit Register
Government and tax authorities
Debt collection, tracing and repossession agents
To our professional advisers including insurers, law firms and auditors
To any potential or actual guarantor, or funder
If we sell any of our business or assets, or we are acquired by a third party, the personal data held by us will be shared under strict duties of confidentiality
Where permitted by law for our legitimate interests and is not incompatible with the purposes in Section 4.

These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this Privacy Notice unless they notify you otherwise.

Credit Reference and Fraud Prevention Agencies

We carry out credit and identity checks on you with credit reference agencies (“CRAs”) and fraud prevention agencies. We do this by suppling your personal data to the agencies and they will give us information about you including both public (including the electoral register) and shared credit information, financial situation, history, and fraud prevention information.

The Central Credit Register

In ROI, The Credit Reporting Act 2013 mandates that the Central Bank of Ireland establishes, maintains and operates a national mandatory database of credit information to be known as the Central Credit Register (“CCR”).

The CCR provides a reliable and secure source of credit information, with an accurate picture of each borrower's total loans and guarantees reported. This matching of loans and guarantees from different lenders creates a Single Borrower View, which facilitates enhanced creditworthiness assessments and responsible lending. You can find further information about how the CCR may process your personal data at www.centralcreditregister.ie or you can contact us to obtain a paper copy of this information;

We will use this information to:

Assess your credit and affordability position for the product applied for
check the accuracy of the data you’ve given to us
prevent criminal activity, fraud and money laundering
trace and recover debts if you owe us money
assess how you’ve managed credit in the past, for example, about any borrowing, including the amount you borrow and your payment history, including any payment arrangements.

We will continue to share information about you with CRAs and/or CCR while you have a relationship with us. We’ll also inform the CRAs and/or CCR about your account status and repayment history. CRAs and/or CCR will provide us with regular information to enable us to carry out the activities in the above list. If you borrow and don’t repay in full and on time, CRAs and/or CCR will record the outstanding debt. CRAs and/or CCR may give this information to other organisations.

When CRAs and/or CCR receive a search request from us they’ll place a search footprint on your credit file that may be seen by other lenders.

The Credit Reference Agency Information Notice (“CRAIN”) describes how the three main credit reference agencies in the UK use and share personal data. The CRAIN is available on the credit reference agencies’ websites:

www.transunion.co.uk/crain
www.equifax.co.uk/crain
www.experian.co.uk/crain

The information held by CRAs and/or CCR may be linked to people who are associated with you, such as your partner or other members of your household. These linked records are called associated records. Any enquiry we make to the CRA and/or CCR may be answered from both your own record and any associated records.

Another person’s record will be associated with yours when:

you are making a joint application
you tell us about a financial association with another person (for example, that they are your business partner); or
the CRA and/or CRA already have existing associated records.

An associated record will be taken into account for all future applications made by either or both of you. The association continues until one of you makes a successful application for the credit reference agencies to file a ‘disassociation’, which allows your information to no longer be linked. You can check for any associations by getting your credit record direct from the CRAs and/or CCR.

We and fraud prevention agencies may also share your personal data with law enforcement agencies to detect, investigate and prevent crime. If fraud is detected, you could be refused certain services or finance. Fraud prevention agencies can hold your personal data for different periods of time. If you are considered to pose a risk of fraud or money laundering, your personal data can be held for up to six years.

Transferring your personal data overseas

When we transfer your personal data outside the European Economic Area (“EEA”), we will ensure that it is protected in a manner that is consistent with how your personal data is protected by us in the EEA. This will include processing by other companies in the Close Brothers Group with processing for service provision taking place within the United Kingdom.

We do this by using one of the following safeguards:

The country that we send the data to has been approved as offering an adequate level of protection by the European Commission. We rely on Adequacy Decisions in the first instance where available; or
We have entered into a contract with the recipient organisation on terms approved by the European Commission, known as Standard Contractual Clauses, obliging them to protect your personal data to the same level.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of the Standard Contractual Clauses, where applicable) by contacting us in accordance with the “ How to contact us” section below.

How long will we keep your personal data

The length of time we hold your personal data for will vary dependent upon the purpose the data was collected or generated. Once our relationship has ended, we will usually retain your personal data for seven years.

There may be circumstances where we need to retain your personal data after this time, for example:

To meet legal or regulatory obligations
Evidence of business activities
To help detect or prevent fraud and financial crime
Defend or take legal action
Comply with court orders or investigations from law enforcement agencies or regulators

Where retained we will take steps to ensure that the personal data is accessed only by personnel that have a need to do so for the purposes described in this Privacy Notice.

Marketing

Where we have appropriate marketing permissions, we will provide you with details about our products and services including those of the Close Brothers Group.

We may also use information gathered from third party organisations which provide personal data for marketing purposes to help us improve our marketing offerings to you.

We will not share your personal data with any third party organisations for their own marketing purposes, unless you have provided your consent for us to share your personal data for this purpose.

You can contact us at any time to ask us to stop using your personal data in this way. We will still send you important information such as changes to your terms and conditions, or if we need to tell you something to comply with our regulatory or legal obligations.

Your rights

You have a number of rights in relation to the personal data that we hold about you.

These rights include:

Right of Access: This means we will provide you with a copy of the personal data we hold about you. This is an entitlement to a copy of the information only, you are not entitled to documents although these may be provided on occasion.
Right of Rectification: This means if we hold any incorrect information about you, we will correct it.
Right of Erasure: This means you can request we delete the personal data we hold about you. Please note, we may not be able to comply with this request in full where, for example, we have a legal or regulatory obligation to retain your personal data.
Right to Restrict processing: This means we will pause processing your personal data in certain circumstances, such as where you believe it is inaccurate and we are investigating these claims.
Right to Portability: We will provide your or a third party an electronic copy of the personal data you have given us in a commonly used electronic format
Right to Object: This means you can object to us processing or holding your personal data. We may refuse a request where we can reasonably demonstrate legitimate grounds for continuing use. We will not refuse an objection request which relates to marketing activity.
Withdraw consent: Where consent is our lawful basis of processing your personal data, you can withdraw your consent at any time.
Right to object to any automated decision making (including profiling) which we conduct based on your personal data, which significantly affects you. Please note that there may be circumstances where you object to us conducting automated decision making but we are legally entitled to refuse that request
Complaint: In the UK under the UK Data Protection Act 2018 - You have the right to complain to us about how your personal data is being processed. You can also complain directly to the relevant data protection supervisory authority.

You can exercise your rights by contacting us or the relevant data protection supervisory authority using the details set out in the “How to contact us” section below.

Automated Processing

During our relationship with you, we may process your personal data by automated means which includes profiling, so we can make decisions about you, predict risks or outcomes. Examples of this type of processing are:

Credit and affordability checks for products and services
Anti-money laundering and sanctions checks
Screening of politically exposed persons
Identification of customers who may need additional assistance, such as vulnerable customers in line with regulators requirements
To provide tailored marketable populations

You have the right to object to an automated decision we have made and request that a person reviews it.

We may also process your personal data using artificial intelligence technology (“AI”), which includes generative artificial intelligence, machine learning or large language models provided by third party organisations.

AI may be used for many purposes, including personal productivity, risk management, improve the quality and efficiency of our services and analysis activities. When using these technologies, your personal data may be used to train our AI models, including those of our third party service providers.

Cookies

We use cookies and similar technologies on our website and in our emails for many reasons. An example of some uses:

Storage of preferences
Analysis of online traffic to improve online experience
Serve non tailored marketing materials
In emails, tracking if you opened an email and if you visited our website

For full details on what cookies are, what they do, and which cookies are used by us, please see our Cookie Policy.

How to contact us

If you have any questions about our Privacy Notice or want to exercise your rights, you can:

Write to our Data Protection Officer; DPO, Close Brothers. 10 Crown Place, London, EC2A 4FT,

Our Data Protection Representative at:

Close Brothers Commercial Finance; Swift Square, Building 1 Santry Demesne, Northwood, Dublin 9, D09 A0E4, Ireland; or
Close Brothers Commercial Finance, Centrepoint, Second Floor, 24 Ormeau Avenue, Belfast BT2 8HS.

By telephone:

Republic of Ireland (01) 960 9567 or
Northern Ireland 028 9099 8571; or

By email:

You can also complain directly to the relevant data protection supervisory authority:

In ROI, please contact the Data Protection Commission
In the UK, please contact the Information Commissioner’s Office.

Changes to our privacy notice

We keep our privacy notice under regular review and any changes will be posted on this page. Where a change has a significant effect on how we use your personal data you will also be notified by email or any other communication method we deem appropriate.

Please check back frequently to see any updates or changes to our privacy notice.