We get information about you from a number of sources. For example, information that:
We are the data controller and we will hold and use the following information about you:
as well as any other information we reasonably need to operate your account, make decisions about you or fulfil our regulatory obligations. We may keep details of any phone number that you call us from and use it to contact you. When we are managing your account we may be given sensitive information, such as information about your health or medical information which we may hold and process to provide you with the services that you require.
We will keep your information confidential and only share it with others for the purposes explained below and elsewhere in this policy. We have trusted relationships with carefully selected third parties who carry out services on our behalf. All these third parties have a contract with us and have agreed to keep your personal information confidential and secure and only to use it for the purposes that we allow.
We may share information about you to the following people and organisations to:
Operate your account and provide services
Manage your account
Prevent Crime and Terrorism and Regulatory Purposes
Credit Reference Agencies
We may sell your debt to a third party, but if we do, we will require them to keep your personal information secure.
We will use your information to:
Your data may also be used for other purposes for which you give your permission or where we are permitted to do so by law or it is in the public interest to disclose the information or is otherwise permitted under the terms of the Data Protection Act 1998.
We know how important it is to keep your personal information secure. We protect that information using strong encryption when data is both being transferred and when at rest. Access to data is strictly controlled. We use firewalls and other security measures to protect our servers and networks from external attack. Our security systems meet or exceed industry standards.
We may transfer your personal information so that we can run your account and provide other services from:
We may process payments through other financial institutions such as banks and the worldwide payments system operated by the SWIFT organisation. These external organisations may process and store your personal information abroad and may have to disclose it to overseas authorities to help them to fight against crime and terrorism. If these authorities are outside the EEA, your personal information may not be protected to the same standards as in the EEA.
When you apply to us for credit, we may use an automated system known as credit scoring to help us decide whether to lend to you. It is a way of assessing how much you are able to afford to borrow and how you are likely to manage your account. Most lenders use credit scoring to help make fair and informed decisions about lending.
Credit scoring takes account of information from three sources – (i) the information you give us on your application, (ii) information provided by credit reference agencies and fraud prevention agencies, including information about how you manage similar accounts; and (iii) information that may already be held about you by the NewDay Group. Credit scoring methods are regularly reviewed to ensure they remain fair, effective and unbiased.
Using credit scoring helps us to lend responsibly.
As well as searching credit reference agencies, we may ask you to provide physical forms of identity when you apply for a credit card.
If you apply to us but we are unable to offer you a credit card you can contact us within 21 days to ask to have the decision reconsidered.
We will keep your data for statistical analysis, fraud prevention and credit scoring purposes. We may also contact you by post, email, sms or phone about our products and services if you have given us permission to do so.
If you begin an application with us but this application is not completed, we may retain your personal data for no more than six months (180 days) so that we can contact you about your application and to help you to complete it, if this is what you want to do. An incomplete application is defined as personal data that has been provided by you to NewDay Group, but without permission for NewDay Group to perform a Credit Reference Agency search and to make a credit decision about you.
Under the Data Protection Act 1998 you have a right to access certain personal records that we hold about you. This is called a data subject access request and you can make a request by writing to aqua Customer Services, PO BOX 173, Sheffield, S98 1JW. A fee is payable.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove any data that you think is no longer up to date.
You have a right under the Consumer Credit Act 1974 to request credit reference agencies to provide you with information that they hold about you. A fee is payable.
As part of the application process we ask whether we may contact you about our products and services. If you ticked yes, but no longer wish to receive such communications, please let us know by contacting aqua customer services on 0333 220 2691.
We want to make sure that we provide excellent customer service and we use various means of communication to do this including phone, post, email and sms.
We may contact you about services related to your credit card that we, or other companies outside the NewDay Group, may be able to provide you and which we think may be of interest to you or may benefit you financially. We promise not to contact you about everything – only if we think that it could be appropriate and relevant to you.
We will not send you marketing communications if you ask us not to and we will not provide information about you to companies outside the NewDay Group to use for their own marketing purposes.
If you do not want to receive marketing from us, please contact us on 0333 220 2691.
We may monitor or record phone calls with you in case we need to check that we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve the quality of our service, to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.
As part of our commitment to understand our customers better, we may research comments and opinions made public on social networking sites, such as Twitter and Facebook.
Please read this section very carefully
What we do
1) When you apply to us to open an account, we will: -
a) Check our own records for information on: -
i) Any account you and, if you have one, your financial associate may have or have had with us.
A financial associate is someone with whom you have a personal relationship that creates a joint financial unit in a similar way to a married couple. You will have been living at the same address at the time. It is not intended to include temporary arrangements such as students or rented flat sharers or business relationships.
Credit reference agencies may link together the records of people that are part of a financial unit. They may do this when people are known to be linked, such as being married or have jointly applied for credit or have joint accounts. They may also link people together if they, themselves, state that they are financially linked.
b) Search at credit reference agencies for information on: -
i. Your personal accounts;
ii. if have ever previously made joint applications or have joint accounts that are financially linked, we will check your financial associates’ personal accounts as well;
iii) very occasionally if there is insufficient information to enable us to assist you, we may also use information about other members of your family; and
iv) if you are a director or partner in a small business we may also check on your business accounts.
c) Search at fraud prevention agencies for information on you and any addresses at which you have lived and on your business (if you have one)
2) What we do with the information you supply to us as part of the application: -
a) Information that is supplied to us will be sent to the credit reference agencies.
b) If you are making a joint application or tell us that you have a spouse or financial associate, we will: -
i) Search, link and/or record information at credit reference agencies about you both.
ii) Link any individual identified as your financial associate, in our own records.
iii) Take both your and their information into account in future applications by either or both of you.
iv) Continue this linking until the account closes and one of you notifies us that you are no longer linked.
So you must be sure that you have their agreement to disclose information about them.
c) If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
d) Your data may also be used by us to offer you other products, but only if you have given your permission. That will be on any application that you have completed.
3) With the information that we obtain we will: -
a) Assess this application for credit;
b) Check details on applications for credit and credit related or other facilities;
c) Verify your identity and the identity of your spouse, partner or other directors/partners (if any); and/or
d) Undertake checks for the prevention and detection of crime, fraud and/or money laundering.
We may use scoring methods to assess this application and to verify your identity.
Any or all of these processes may be automated.
4) What we do when you have an account: -
a) Where you borrow or may borrow from us, we will give details of your personal and/or business account (if you have one), including names and parties to the account and how you manage it/them to credit reference agencies.
b) If you borrow and do not repay in full and on time, we will tell credit reference agencies.
c) We may make periodic searches of our own group records and at credit reference agencies to manage your account with us, including whether to make credit available, increase the amount of credit available or to continue or extend existing credit. We may also check at fraud prevention agencies to prevent or detect fraud.
5) When credit reference agencies receive a search from us they will:
a) Place a search “footprint” on your credit file whether or not this application proceeds. If the search was for a credit application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you apply for credit in the future.
b) Link together the records of you and anyone that you have advised is your financial associate including previous and subsequent names of parties to the account. Links between financial associates will remain on your and their files until such time as you or your partner successfully files for a disassociation with the credit reference agencies.
Financial associates may “break the link” between them if their circumstances change such that they are no longer a financial unit. They should apply for their credit file from a credit reference agency and file for a “disassociation”.
6) They will supply to us: -
a) Credit information such as previous applications and the conduct of the accounts in your name and of your associate(s) (if there is a link between you) and/or your business accounts (if you have one).
b) Public information such as County Court Judgments (CCJs) and bankruptcies.
c) Electoral Register information.
d) Fraud prevention information.
7) When information is supplied by us, to them, on your account(s): -
a) Credit reference agencies will record the details that are supplied on your personal and/or business account (if you have one) including any previous and subsequent names that have been used by the accountholders and how you/they manage it/them.
b) If you borrow and do not repay in full and on time, credit reference agencies will record the outstanding debt.
c) Records shared with credit reference agencies remain on file for 6 years after they are closed, whether settled by you or defaulted.
8) How your data will NOT be used by credit reference agencies: -
a) It will not be used to create a blacklist.
b) It will not be used by the credit reference agency to make a decision.
9) How your data WILL be used by credit reference agencies:
a) The information which we and other organisations provide to the credit reference agencies about you, your financial associates and your business (if you have one) may be supplied by credit reference agencies to other organisations and used by them to:
i) Prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities;
ii) Check the operation of credit and credit-related accounts;
iii) Verify your identity if you or your financial associate applies for other facilities;
iv) Make decisions on credit and credit related services about you, your partner, other members of your household or your business;
v) Manage your personal, your partner’s and/or business (if you have one) credit or credit related account or other facilities;
vi) Trace your whereabouts and recover debts that you owe; and
vii) Undertake statistical analysis and system testing.
10) How your data may be used by fraud prevention agencies:
i) The information which we provide to the fraud prevention agencies about you, your financial associates and your business (if you have one) may be supplied by fraud prevention agencies to other organisations and used by them and us to prevent crime, fraud and money laundering by, for example:
a) checking details provided on applications for credit and credit related or other facilities;
b) Managing credit and credit related accounts or facilities;
c) Cross Checking details provided on proposals and claims for all types of insurance;
d) Checking details on applications for jobs or when checked as part of employment;
e) Verify your identity if you or your financial associate applies for other facilities including all types of insurance proposals and claims;
f) Trace your whereabouts and recover debts that you owe;
g) Conduct other checks to prevent or detect fraud;
h) We and other organisations may access and use from other countries the information recorded by fraud prevention agencies; and/or
i) Undertake statistical analysis and system testing. 11) Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998. 12) Your data may also be used to offer you other products, but only where permitted by you.
11) Your data may also be used for other purposes for which you give your specific permission or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
12) Your data may also be used to offer you other products, but only where permitted by you.
You can contact the Credit Reference Agencies currently operating in the UK; the information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.
Please contact aqua customer services on 0333 220 2691 if you want to receive details of the relevant fraud prevention agencies.
What is a credit reference agency?
Credit reference agencies (CRAs) collect and maintain information on consumers’ and businesses’ credit behaviour, on behalf of organisations in the UK.
What is a fraud prevention agency?
Fraud Prevention Agencies (FPAs) collect, maintain and share, information on known and suspected fraudulent activity. Some CRAs also act as FPAs.
Why do you use them when I have applied to your organisation?
Although you have applied to us (NewDay Ltd) and we will check our own records, we will also contact CRAs to get information on your credit behaviour with other organisations. This will help us make the best possible assessment of your overall situation before we make a decision.
Where do they get the information?
- The Electoral Register from Local Authorities
- County Court Judgments from Registry Trust
- Bankruptcy (and other similar orders) from the Insolvency Service
How will I know if my information is to be sent to a Credit Reference Agency or a Fraud Prevention Agency?
Why is my data used in this way?
We and other organisations want to make the best possible decisions we can, in order to make sure that you, or your business, will be able to repay us. Some organisations may also use the information to check your identity. In this way we can ensure that we all make responsible decisions. At the same time we also want to make decisions quickly and easily and, by using up to date information, provided electronically, we are able to make the most reliable and fair decisions possible.
Who controls what such agencies are allowed to do with my data?
All organisations that collect and process personal data are regulated by the Data Protection Act 1998, overseen by the Information Commissioner’s Office. All credit reference agencies are in regular dialogue with the Commissioner. Use of the Electoral Register is controlled under the Representation of the People Act 2000.
Can just anyone look at my data held at credit reference agencies?
No, access to your information is very strictly controlled and only those that are entitled to do so may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement.