Honda Financial Service Privacy Notice
Last updated - 31/07/2020
Honda Finance Europe Plc t/a Honda Financial Services (“We”) is committed to protecting and respecting your privacy. This privacy notice tells you how Honda Financial Services (‘we’, ‘us’) processes your data during the process of applying for finance and throughout your finance agreement.
This privacy notice also describes your personal data protection rights. More information about your rights and how to exercise them is set out in the ‘Your Choices and Rights’ section.
For the purpose of the Data Protection Act 2018 (“the Act”) incorporating the General Data Protection Regulations (GDPR), the Data Controller is Honda Financial Services, a subsidiary of Honda Motor Europe, located at: Cain Road, Bracknell, RG12 1HL. Honda Finance Europe’s Data Protection Registration Number is Z7591683.
We process the following types of personal data both during the application process and throughout the administration of your agreement.
- Contact information: such as your name, address, length of time at address (to validate application details) phone, email, and other similar information.
- Other types of personal information: such as your marital and employment status, length of time with employer (to validate application details), time at address and nature of tenure (homeowner, tenant etc.).
- Financial information: such as your bank account name and number, sort code, years with bank and number of credit cards held (to validate application details) as well as financial history in order to assess your creditworthiness and affordability of any lending to you.
- Details of the vehicle being financed: including the make, model, VIN and registration number, description and any additional information such as extras and accessories.
- Any other information required to process your application: from time to time, in order to validate your identity and affordability of any credit to you, we may request additional copies of documentation such as passport, National Identity Card and other official documents as described on the Home Office Identity Verification list.
- We may also require additional evidence to validate signatures in some exceptional circumstances.
- From time to time during the administration of your account for us to provide an appropriate service tailored to your circumstances we may collect sensitive personal data, such as health and other special category data, where disclosed to us.
Why we collect, use and store this personal data
We collect, use and store your personal data for the reasons set out below:
- To process your application for finance, which includes a process of automated decision making in some cases.
- To apply payments to your agreement and to perform the contract between us and you, our customer.
- To manage the quality of our service including where responding to complaints.
- To analyse the performance of our products to ensure we continue to offer a competitive and customer-focussed service.
- Where necessary, to comply with a legal obligation including the detection and prevention of financial crime and identity fraud.
- Where necessary to protect Honda’s legitimate interests and legal rights, and where our interests are not overridden by your data protection rights.
- To pursue outstanding payments and recover assets.
- To carry out analysis of our products and customers’ preferences through production of management information.
- To undertake profiling of consumer behaviour and customer outcomes using data, which is anonymised for this purpose. You have the right to object to this. Please see Your Choices and Rights for more information.
- We may also use your data for the purposes of undertaking market research through an appointed third party.
- We also collect, use and share aggregated data such as statistical and demographic data for analysis and oversight purposes. This may be derived from your personal data however is not considered personal data in law where it does not directly or indirectly identify you. For example, we may analyse product preferences for different customer groups. Where we combine or connect this data with Personally Identifiable Information, we treat the combined data as personal data.
Where you have consented to this, we may also use your data, or permit Honda affiliated third parties including our dealer network to use your data, to provide you with information about additional products and services which may be of interest to you and we or they may contact you about these by post, email or telephone in accordance with your preferences.
Where additional information is required to assess the affordability of our products at underwriting stage, with your consent we may view your data through Open Banking. For more information, please read our supplemental Open Banking Privacy Notice. We do not share your Open Banking data with any third parties.
- Protecting our legitimate business interests and legal rights. This includes, but is not limited to, use in connection with compliance, regulatory, auditing, legal claims (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance requirements.
- We may also share your data with third parties if we choose to sell, transfer or merge parts of our business or its assets. If a change happens to our business, then the new owner of the data may use your personal data in the same way as set out in their own privacy notice.
The information we collect is appropriate for the purposes described and not excessive. your personal data is held on secure servers to minimise the risk of the data being lost or stolen.
Your choices and rights
Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time.
You may also withdraw your consent to contact you for marketing purposes or for us to give your details to others for this purpose.
You have the right to request that we erase any data we hold about you where we do not have a legitimate basis for holding it.
You have the right to ask for a copy of the personal data we hold about you by way of a Subject Access Request.
You have the right to object to us processing your personal data.
You have the right to request that your personal data is erased or restricted.
You have the right to request a copy of your personal data in a commonly used electronic format.
In certain circumstances, you may contest a decision made about you based on automated processing.
In order to exercise any of these rights please notify us in writing to the Customer Services Department at Honda Financial Services, Cain Road, Bracknell, RG12 1HL or by telephoning the same department on 0345 128 8908 or by email at email@example.com.
If you are not happy with the way we are using your personal data, we would ask that you contact our data protection representative via firstname.lastname@example.org who will look into your query and seek to resolve it for you.
You also have a right to lodge a complaint with the Information Commissioner’s Office at ico.org.uk.
How we share your personal data
(a) Transfers within the Honda Group of Companies
We share your personal data with members of the Honda Group as set out below:
- Honda Motor Europe Ltd (HME): HME is the European subsidiary of Honda Motor Group and is responsible for the distribution of vehicles and other Honda products throughout the UK dealer network.
- Honda Motor Co., Ltd. (HM): HM, our parent company, receives information on sales and volumes. HM is a company incorporated in Japan.
For the purposes mentioned above, your personal data will be processed in, or accessed from, Japan. When transfer your data to HM in Japan, we make use of standard contractual data protection clauses, which have been approved by the European Commission.
(b) Transfers to Honda authorised dealers
We may from time to time share your personal data with Honda authorised dealers in the UK for the purposes of managing your finance agreement, as explained in the section 'How we collect, use, share and store this personal data'. This may include at the time you may be discussing part exchange options, for example, data like your settlement figure, current monthly payment, equity position and the car you are driving. At no time will sensitive data be shared with a Honda dealer without your consent.
If your finance agreement was brokered by a dealer no longer operating, we may transfer your data to an alternative dealer within the same group, or to an alternative Honda dealership where the original brokering dealership is no longer operating.
We rely on legitimate interests to do this but if you wish to object to this please contact us to let us know.
Honda’s network of dealerships is independently owned and operated businesses. If you have any concerns about how a Honda dealer processes your personal data, please contact them in the first instance. Please check your preferred dealer privacy notice for details of how they may process your personal data.
A full list of Honda dealers may be accessed below:
- Cars - www.honda.co.uk/cars/dealer-list.html
- Motorcycles - www.honda.co.uk/motorcycles/dealer-list.html
- ATVs - www.honda.co.uk/atv/dealer-list.html
You can also search for your nearest Honda dealer using the following web links:
- Cars - www.honda.co.uk/cars/dealer-search.html
- Motorcycles - www.honda.co.uk/motorcycles/dealer-search.html
- ATVs - www.honda.co.uk/atv/dealer-search.html
(c) Transfers to companies providing services under contract
During the life of your agreement, your personal data may be shared with one or
many of the categories of company below providing services under contract.
- IT and Telecoms companies
- Fulfilment and print companies
- Consultancy Services and legal firms
- Contract Hire provider
- Credit Reference Agencies
- From time to time during the administration of accounts in arrears or in order to recover and remarket assets related to agreements in arrears, or otherwise in breach, data may be transferred to a third party to perform services to deliver the contract.
All companies providing services under contract may be reviewed from time to time, in which case your data will be transferred to the new supplier of that service.
Sharing your information with Credit Reference Agencies
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”).
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
- assess your creditworthiness and whether you can afford to take the product;
- verify the accuracy of the data you have provided to us;
- prevent criminal activity, fraud and money laundering;
- manage your account(s);
- race and recover debts; and
- ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt.
This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at www.experian.co.uk/crain.
The Credit Reference Agency Information Notice (CRAIN) is also accessible from each of the three CRAs – clicking on any of the following links will also take you to the same CRAIN document: Callcredit www.callcredit.co.uk/crain; Equifax www.equifax.co.uk/crain.
Sharing your information with Fraud Prevention Agencies
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud, money laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies and your data protection rights, can be obtained by writing to us at the Customer Services Department, Honda Finance Europe Plc, Cain Road, Bracknell, Berks RG12 1HL or telephoning us on the number listed below.
Please call us on 0345 128 8908 or email email@example.com if you want details of those credit reference and fraud prevention agencies from which we obtain, and to which we pass, information about you. You have a legal right to these details.
For the purposes of training, quality assurance and assisting our customers in the events of complaints or claims, we record our telephone calls.
Transfers outside the EEA
Further to the above purposes, we may transfer your personal data to organisations outside of the EEA. When doing do, we may use standard contractual data protection clauses, which have been approved by the European Commission. For further information, including to obtain a copy of the documents used to protect your information, please contact us as described in the Contact Us section below.
We will retain your personal data only for as long as we need it for Honda Financial Services’ legitimate interest in accordance with applicable law, to perform a service at your request or the contract which you hold with us, or to meet a legal requirement.
At the end of the retention period, we will take steps to delete your personal data or hold it in a form that no longer identifies you.
Contact us: correcting, updating and accessing your personal information
It is important that the data we hold about you is accurate. Please notify us of any changes during our relationship with you
If your personal information changes (such as your address, contact details and/or bank details), or if we have inaccurate information, we will endeavour to correct, update or remove your personal information in our database.
To notify us of an inaccuracy or to contact us about any of your data protection rights, you can write to us at the Customer Services Department at Honda Financial Services, Cain Road, Bracknell, Berks, RG12 1HL, telephone the same department on 0345 128 8908, or email us at firstname.lastname@example.org.