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Introduction
The EU General Data Protection Regulation (“GDPR”) came into force on 25 May 2018.
The new Regulation aims to standardise data protection laws and processing across the EU, giving people greater rights to access and control their personal information.
Our Commitment
Extra Direct (UK) Limited (trading as Extra Direct, Bank Accounts Direct, Bank Accounts Compared, Guaranteed Personal Accounts and Guaranteed Business Accounts and other specific related websites) registered office is at Perception House, 50b Duke Street, Chelmsford, Essex CM1 1JA are committed to ensuring protection of all personal information that we hold, and to provide and to protect all such data. We recognise our obligations in updating and expanding this program to meet the requirements of GDPR.
We are dedicated to safeguarding the personal information under our control and in maintaining a system that meets our obligations under the new regulations. Our practice is summarised below.
How We Prepared for GDPR
Extra Direct (UK) Limited already have a consistent level of data protection and security across our organisation, but we have introduced new measures to ensure compliancy.
Information Audit — We carried out an audit of information previously held and ensured that it was compliant with the new regulations.
Policies and Procedures — we have revised data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:
Data Protection - our main policy and procedure document for data protection has been revised to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy and the rights of individuals.
Data Retention and Erasure - we have updated our retention policy and schedule to ensure that we meet the "data minimisation" and "storage limitation" principles and that personal information is stored, archived and destroyed in accordance with our obligations. We have procedures in place to meet the new "Right to Erasure" obligation.
Data Breaches - our procedures ensure that we have safeguards in place to identify, assess, investigate and report any personal data breach as early as possible. Our procedures have been explained all employees.
International Data Transfers and Third-Party Disclosures - where Extra Direct (UK) Limited stores or transfers personal information outside the EU, we have robust procedures in place to secure the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as binding rules, or standard data protection clauses for those countries without.
Subject Access Request (SAR) - we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge
Privacy Notice/Policy - we have revised our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
Obtaining Consent - we have revised our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information
Direct Marketing - we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.
Data Protection Impact Assessments (DPIA) - where we process personal information that is considered high risk, we have developed stringent procedures for carrying out impact assessments that comply fully with the GDPR's Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).
Processor Agreements - where we use any third-party to process personal information on our behalf (ie Payroll, Recruitment, Hosting, etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they meet and understand their/our GDPR obligations.
Data Subject Rights
We provide easy-to-access information via our office of an individual’s right to access any personal information that Extra Direct (UK) Limited processes about them and to request information about:
what personal data we hold about them
the purposes of the processing
the categories of personal data concerned
the recipients to whom the personal data has/will be disclosed
how long we intend to store your personal data for
if we did not collect the data directly from them, information about the source
the right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
the right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
the right to lodge a complaint or seek judicial remedy and who to contact in such instances.
Information Security and Technical and Organisational Measures
Extra Direct (UK) Limited takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction.
GDPR Roles and Employees
Extra Direct (UK) Limited have designated Robert Billam as our Appointed Person and have appointed a data privacy team to develop and implement our roadmap for complying with the new data protection Regulation. The team are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR compliance, identifying any gap areas and implementing the new policies, procedures and measures.
Extra Direct (UK) Limited understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans.
If you have any questions about our GDPR compliance policies, please contact our Appointed Person admin@extradirect.com
Last reviewed 14July 2021
Privacy Statement
This Privacy Statement will be effective May 25, 2018.
General Information about us
1.1 Extra Direct (UK) Limited (trading as Extra Direct, Bank Accounts Direct, Bank Accounts Compared, Guaranteed Personal Accounts and Guaranteed Business Accounts and other specific related websites) registered office is at Perception House, 50b Duke Street, Chelmsford, Essex CM1 1JA
1.2 We comply with the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 as well as the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (together “Data Protection and Privacy legislation”). We and our banking/account partners are committed to safeguarding the privacy and security of the information we collect.
Important information about this privacy statement
2.1 This Privacy Statement sets out the basis, on which any personal data you provide to us, or we collect from you through our website(s), our Applications and Services, or our operating partners will be processed by us.
2.2 Definitions are as per Definitions in our Terms and Conditions.
2.3 If you do not agree with this Privacy Statement, you should not use any of our websites, do not complete an application and close your browser window immediately.
Collection of your personal data
3.1 We collect your personal data in order to:
allow us to provide you with our intermediary services;
monitor, analyse and improve our services;
prevent money-laundering, fraud & illegal activities;
allow us to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
comply with legal obligations such as Anti Money Laundering legislation
How we protect and manage your personal data
4.1 We will take appropriate measures to ensure confidentiality of all information, both paper and electronic required for the operation of our business. We will take appropriate steps to protect data stored or transmitted against accidental or unlawful destruction, accidental loss or alteration, and unauthorised or unlawful storage, processing, access or disclosure.
4.2 We will ensure that your personal data will only be accessed by authorised personnel for legally authorised purposes.
4.3 We will only use personal data in our possession for its intended, specific and authorised purpose.
4.4 Your personal data will be retained and maintained in accordance with applicable Data Protection and Privacy laws and regulations. Upon request by you, we will amend the personal data we hold if factually incorrect or incomplete, and provide you with a copy of any personal data held by us.
4.5 All our employees are trained in applicable Data Protection and Privacy legislation and will act with due care and diligence when handling personal data.
Third parties and your data
5.1 We may disclose your personal information to third parties in the following circumstances:
Your personal data may be transferred to contracted third parties, e.g. banks and other personal & business account providers for the purposes of providing an account to you. Contracted third parties are obliged to ensure that your personal data is securely managed at all times and will only use this data in line with our specific instructions.
We and our contracted third parties may share your personal information with authorities both within the UK and abroad to prevent money laundering, terrorism and fraud in order to meet legal obligations.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation.
In order to enforce or apply our Terms and Conditions or other agreements;
To protect the rights, property, or safety of us, our customers, or others.
In the event that we sell or buy (partially or wholly) any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
If you give explicit permission to do so.
Information we collect from you
6.1 Our customers are both individuals and businesses. The information we receive and collect from prospective customers is strictly related to our customers and the services we provide. The information we collect may include financial and other information. The above information and any contact or enquiry you make will be stored by us in line with our data retention policy.
6.2 When you visit our website(s) or use any of our banking intermediary services we collect your IP address and other information such as the domain and host from which you access the internet, the browser and browser version, the operating system, and type of device. We do so in order to administer our services and optimise our websites and Applications for you and to diagnose problems with our website(s) or Applications. We also use the information to assist in the fight against fraud or malevolent applications and to ensure a better user experience.
6.3 “Cookies” are small pieces of information that are stored by your browser on your device. Like most websites and applications we use cookies to keep track of your activity and enhance your experience. We also use cookies to assist us in the fight against fraud or malice. If you wish to disable these cookies, the “help” section of the toolbar on most browsers will tell you how. However, if you set your browser to disable cookies, you may not be able to access certain areas or features of our Applications or website(s).
Your personal data rights
7.1 You have a right to the following (unless it conflicts with another legal obligation):
Seek access to information which we hold about you;
To ask us to correct information about you which is inaccurate, incomplete or out of date;
To erase your personal data unless certain conditions apply including that processing is necessary for compliance with a legal obligation;
To restrict the processing of your personal data or to object to such processing;
To data portability whereby your personal data can be transmitted directly from one controller to another where technically feasible.
7.2 Any such request should be made to us in writing to: Data Protection Officer, Extra Direct (UK) Limited, Perception House, 50b Duke Street, Chelmsford, CM1 1JA or by email to admin@extradirect.com. Your request will be dealt with as soon as possible and in any event within 30 days.
Retention of your personal data
8.1 We must comply with a number of statutory and regulatory requirements in relation to the retention of data. Your personal data must be retained for a period of no less than six years following your application or six years from the date of the last correspondence, whichever is the later.
8.2 We do not sell or rent your personal data to any third parties for marketing purposes outside of the dedicated banking/Account partners specifically registered to ultimately provide the service you have requested.
Changes to this Privacy Statement
9.1 We continue to review our controls and processes to ensure that they are effective in meeting our commitments to our customers. We reserve the right to change this Privacy Statement without notice at any time and from time to time, including as needed to comply with the laws and regulations of the jurisdictions within which we operate.
Contacting Us
If there are any questions regarding this privacy policy you may contact us using the information below.
Guaranteed Business Accounts
Perception House
50b Duke Street
Chelmsford
Essex
CM1 1JA
info@guaranteed-business-accounts.co.uk
Telephone: 020 3286 3929
Last reviewed 14July 2021