- Who we are and who is responsible for your personal data
- Our services and products
- What information we collect about you
- How we use your information
- How we safeguard your information and how long we keep it for
- Where we transfer your information to
- Who we share your information with
- Confidential Information
- Your rights under data protection legislation
- How to contact us
1. Who we are and who is responsible for your personal data
1.1 British Business Bank plc (“British Business Bank” or “we” or “us”) is registered in England and Wales with company number 08616013. British Business Bank with its registered office at Steel City House, West Street, Sheffield, S1 2GQ and other companies in the British Business Bank group of companies collect and use certain personal data.
1.2 The British Business Bank is a development bank wholly owned by HM Government which is not authorised or regulated by the Prudential Regulation Authority (PRA) or the Financial Conduct Authority (FCA). British Business Bank plc and its subsidiary entities are not banking institutions and do not operate as such. A complete legal structure chart for British Business Bank plc and its subsidiaries can be found at www.british-business-bank.co.uk.
“British Business Bank”, “we or “us” means British Business Bank plc and other companies in the British Business Bank group (including without limitation, British Business Finance Ltd (registration number 09091928), British Business Investments Ltd (registration number 09091930) and British Business Financial Services Ltd (registration number 09174621).
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, British Business Bank (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of British Business Bank or any other person in respect of an individual.
2. Our services and products
2.1 We offer the following services (by way of non-exhaustive list):
- A six-step tool to find finance options that can work for your business;
- Access to our partners;
- Access to case studies and other material that is useful for small businesses seeking finance; and
- Access to guides, checklists and infographics to help you get your business ready for investment.
3. What information we collect about you
3.1 Many of the services offered by British Business Bank require us to obtain Personal Data about you in order to perform our services, evaluate the Website and offer our products.
3.2 We may collect and process the following Personal Data about you:
- Information that you provide to us:
- information that you submit online via our Website (including information on ethnicity and disability if you choose to provide it);
- any correspondence you send to us;
- information that you provide by completing forms on the Website; and
- any surveys that that you complete and which we use for research or evaluation purposes, if you choose to respond to them.
- Information that we collect or generate about you (by way of non-exhaustive list):
- details of your visits to our Website and the resources that you access (which may include, amongst other things; traffic data and communication data); and
- a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you.
- Information we obtain about you from other sources:
- Anonymised data
In addition to the categories of Personal Data described above, British Business Bank will also process further anonymised information and data that is not processed by reference to a specific individual.
4. How we use your information
4.1 We will keep information about you that is necessary for us to provide you with a service or product you have requested.
4.2 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
- to ensure that our Website’s content is presented as effectively as possible for you;
- for ongoing review and improvement of the information provided on the Website to ensure it is user friendly and to prevent any potential disruptions or cyber-attacks;
- to allow you to use and access the functionality provided by the British Business Bank services;
- for our internal purposes, such as research and analysis, reporting, quality control, website performance, system administration and to evaluate use of our Website, so that we can provide you with enhanced services;
- to notify you about changes to our services and products;
- to communicate with you in order to provide you with information about British Business Bank and our services and mandate;
- to keep you updated about events in your area that could help you with your business (in accordance with section 6 (Marketing) below);
- to invite you to attend focus groups to further improve our Website;
- for the administration and maintenance of databases storing Personal Data;
- to conduct analysis required to detect malicious data and understand how this may affect your IT system;
- to provide you with information or services that you request from us, or which we feel may interest you (in accordance with section 6 (Marketing) below);
- to create reports to assist with future marketing;
- for complaint handling purposes;
- to enable you to participate in interactive features of our Website, when you choose to do so;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
- to help us improve our services and products;
- to understand your needs and interests;
- to understand feedback on our services and products and to help provide more information on the use of those products and services quickly and easily;
- for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
- for analytical and administrative purposes (including to keep a record of the types of finance that SME are seeking;
- to evaluate the effectiveness of the Website;
- for the management and administration of our business;
- to ensure that content from our site is presented in the most effective manner for you and your computer; and
- to allow you to participate in interactive features of volunteering, when you choose to do so.We will collect behavioural data about the you and how you interact with the site, including location data. This data may be used to personalise and improve your experience of the website. In some instances, this data will be used to inform targeted marketing and advertising campaigns (see section 6. (Marketing below)).
We may also use your Personal Data in case studies that we produce which will then be used for advertising and marketing purposes. We will obtain your consent to do this in advance.
4.3 We will only use information you provide relating to ethnicity and disabilities for monitoring and equal opportunities purposes.
4.4 We make sure that our use of Personal Data complies with law and the law allows us and requires us to use Personal Data for a variety of reasons, for instance where:
- we need to do so in order to perform contractual obligations with customers;
- we have obtained your consent;
- we have legal and regulatory obligations that we have to discharge;
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- the use of your Personal Data as described is necessary for our legitimate business interests, such as:
- allowing us to effectively and efficiently manage and administer the operation of our business;
- maintaining compliance with internal policies and procedures;
- monitoring the use of our copyrighted materials;
- allowing us to effectively evaluate the effectiveness of the Website;
- enabling quick and easy access to information on our services and products;
- offering optimal, up-to-date security solutions for mobile devices and IT systems; and
- obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.
5. How we safeguard your information and how long we keep it for
5.1 We will keep Personal Data secure by taking appropriate technical and staff measures to protect it against the unauthorised or unlawful processing and against accidental loss, destruction or damage.
5.2 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
5.3 As a condition of employment, British Business Bank employees are required to follow all applicable laws and regulations, including in relation to data protection laws. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a British Business Bank employee is prohibited and may result in disciplinary measures.
5.4 When you contact a British Business Bank employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
6.1 We may use your information to provide you with marketing information that you request or that we feel may interest you by post, email and/or telephone (including SMS) as follows:
- If you are an existing customer or have taken steps to become a customer by using the Website or contacting us, we may contact you by post, email and/or telephone (including SMS) with information about products and services which are similar to those we previously provided to you, unless, at the time we collect your contact information, you have indicated that you do not want to receive marketing information; or
- If you are a new customer, we may contact you by post, email and/or telephone (including SMS) if you have consented to receiving such information.
6.2 We will not pass your information to third parties for their marketing purposes, but if you have indicated that you wish to receive promotional material relating to events or promotional offers, that we have negotiated on your behalf, with our preferred partners then we may contact you by post, e-mail and/or telephone (including SMS) with such promotional material and offers.
6.3 We operate an integrated communications programme, which means we use your Personal Data to communicate with you through several different channels; including direct mail and email. Our aim is to keep you up-to-date with all the latest news from the British Business Bank, however if you feel you no longer wish to receive direct mail or email communications from us, you are able to ‘opt out’ of them individually at any time.
6.4 If you do not want us to use your information for marketing purposes, please indicate your preference via the relevant boxes on any forms you submit when you are providing your contact information. You may also ask us at any time not to use your information for marketing purposes by contacting us via the methods listed in the ‘How to contact us’ section below.
7. Where we transfer your information to
7.1 We will not routinely transfer your information to, or store it, outside the European Economic Area (“EEA”).
7.2 If we do transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. This may be done in one of the following ways:
- the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
- where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
- in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
7.3 You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us through the methods listed in the ‘How to contact us’ section below.
7.4 By providing your information to us you agree and consent to us transferring to, and storing your information at, a destination outside the EEA.
8. Who we share your information with
8.1 We may share your Personal Data within the British Business Bank group of companies for the purposes described above.
8.2 We will also share your information with our trusted Partners so that they can consider your eligibility for support/as well as Government departments and other associated partner organisations to Government and public-sector bodies for research purposes. A Partner may be a company within the British Business Bank itself or an organisation that is contracted by the British Business Bank. For a full list of Partners please refer to our www.british-business-bank.co.uk/finance-hub/.
8.3 We may also share your Personal Data outside of the British Business Bank group with the following third parties:
- to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
- if we sell or buy any business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
- if we or substantially all of our company assets are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third-party buyer.
9. Confidential information
9.1 Please note that under the Freedom of Information Act 2000, we are only permitted to protect information that is actually confidential in law and where, if we were to disclose it, we could be sued for breach of confidence.
9.2 Information you give us which you may consider confidential, or may mark as confidential, may in fact not be confidential in law. However in respect of any information we receive from you that is truly confidential, we will take steps to ensure it remains confidential.
9.3 Unauthorised disclosure or misuse of Personal Data by staff will lead to disciplinary action.
10. Your rights under data protection legislation
10.1 You have a number of legal rights in relation to the Personal Data that we hold about you. These rights include:
- the right to see a copy of the information we hold about you (with the exception of the assessment of any application for finance or other products);
- where you have actively provided your consent for us to process your Personal Data, the right to withdraw your consent at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason (other than consent) for doing so;
- the right to be removed from our mailing lists, and those of our partner organisations (please see further details in section 6 (Marketing) above).
- in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is feasible. Please note that this right only applies to Personal Data which you have provided to us;
- the right to correct any errors in information we hold about you, and to change or correct any details you have already given us (by contacting us through the methods listed in the ‘How to contact us’ section below);
- the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
- the right to request that we restrict our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your Personal Data but we are legally entitled to refuse that request; and
- the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.
10.2 You can exercise your rights by contacting us using the details set out in the “How to contact us” section below.
11. Changes to this Policy
11.2 Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Website, whichever is earlier. Your continued use of our Website after the expiry of this period means that you agree to be bound by the modified policy.
12. How to contact us
12.1 If you have any questions or comments regarding how we handle your Personal Data, please contact us at:
- Email Address: firstname.lastname@example.org
- Postal Address: British Business Bank, Steel City House, West Street, Sheffield, S1 2GQ.