As a result of Data Protection legislation and associated regulation, you are entitled to receive West One’s assurances that personal data is collected, processed and stored for specific purposes and that this is done so securely and confidentially. West One, as a Data Controller, has responsibilities under Data Protection laws to inform you of the data we collect, why we collect it, how we process it and with whom it will be shared. This is set out in our Privacy Notice, a copy of which you may already have been given.
Should you require any further details or wish to enquire on the details we hold on you or your employees please contact the firm’s Data Protection Representative via the following:
Email: compliance@westoneloans.co.uk
Post: Data Protection Representative, West One, 3rd Floor, The Edward Hyde Building, 38 Clarendon Road, Watford, WD17 1JW
Tel: 0333 123 4 556
West One consists of West One Secured Loans Ltd, West One Loan Ltd, West One Development Finance Ltd.
West One Secured Loans and West One Loan, are regulated and authorised by the Financial Conduct Authority for the provision of mortgage finance secured on a customer’s home. Certain loan types, for example loans on some Buy to Let properties and those loans for business purposes are not regulated.
West One Development Finance is not regulated by the FCA as the lending it undertakes solely relates to commercial borrowers who are not subject to regulation.
Details on West One Loan Ltd and West One Secured Loans Ltd status as regulated entities can be obtained from the FCA’s company register: https://register.fca.org.uk/
Each of the above companies is a subsidiary of the parent company Enra Specialist Finance Ltd. Enra Specialist Finance Ltd provides back-office functions to each of its subsidiary firms which means that each of these firms will share customer personal data with this firm in order to manage their obligations under contract.
All of the above entities are registered with the Information Commissioners Office (ICO) as Data Controllers. Each firms’ entry can be searched at: https://ico.org.uk/esdwebpages/search
WOSL is a provider of first and second charge mortgages secured on properties owned by the borrower. Where the loan is secured on the borrower’s home this is subject to FCA oversight and authorisation. Loans are generally over a term of up to 30 years in duration.
The firm also offers loans which are not subject to FCA regulations and are secured on But to Let or Semi-Commercial property and the loan is for a business purpose the borrower undertakes or is intending to carry on.
WOSL’s registration number with the FCA is: 776026
Its registration number with the ICO is: ZA216645
WOL is a bridging lender who provides short term loans which are regulated and unregulated. Bridging loans are generally for 12 months or less in duration. These loans can be provided on a first, second or subsequent charge on the property.
WOL’s registration number with the FCA is: 510024
Its registration number with the ICO is: Z2651210
WODF is a provider of short term development finance to experienced property developers. Development finance lending is provided for the construction and development of large scale property projects and funds against the potential development value of a site.
WODF’s registration number with the ICO is: ZA362893
We will only collect such data that is needed to manage the relationship that we have entered into whereby we will underwrite mortgage applications that you submit to us on behalf of your customer. The information required to this includes:
Under Data Protection laws we must have a legal basis for the collection of your data. This means that there must be a specific reason for us to request your data. West One collects data for the maintenance of a contract for a loan and for the preparation of entry into this contract. The information is used for entering into and management of a contract for the availing of the products which we provide to customers with whom you engage.
West One will also ask for your consent to use your personal data for marketing purposes in order that we can promote our firm's and our sister firms' products and services where we believe these would be of benefit to you and/or your clients. You will have the ability to withdraw your consent at any stage whereby you will not receive any further correspondence that does not directly relate to a loan application you have made.
Data will be gathered from your firm directly and will also be collected from external sources to enable us to manage the relationship in place between the entities under Introducer or Service contract.
Using that data, we will obtain further data from those external companies who maintain data on your credit history (i.e. CRAs) and Fraud Prevention Agencies as well as the Land Registry.
Your data will be shared with other, external data processors to assist us in providing you with finance. These include:
In some circumstances, your data will be shared with our external funders to enable them to determine whether they will be able to provide finance on the loan application you have made. This includes Financial Institutions with whom we have funding agreements in place and also in the provision of certain bridging loans, the firm’s Professional Investor base which consists of private individuals and incorporated entities who have been assessed to act as Professional Investors and who invest under formal investment structures. Financial Institutions consist of retail, investment and merchant banks and certain private equity funders.
Each of the above firms are wholly owned subsidiaries of Enra Specialist Finance Ltd. As a result, a number of the functions which are common to each firm is undertaken centrally by Enra. This will entail sharing your data with Enra for the purpose of maintaining and administering your loan contract as well as processing your data for internal statistical purposes only. Enra is also subject to the Data Protection Act and ICO regulations and oversight.
Where the firm is regulated, we have an obligation to report certain personal data to the FCA, a statutory body set up under legislation. We have further requirements, where requested by other statutory bodies, such as the National Crime Agency, police forces, the Serious Fraud Office, etc. to provide specified personal data on their lawful request for information. This is done on a confidential basis and, through legislation, you will not be entitled to be informed of when this transfer of data has occurred. Details of what data we have submitted to these entities are also exempt from disclosure under a Subject Access Request.
Data Protection legislation provides you with express rights which include:
You may object to West One holding or processing your personal data and/or request that we remove this data from our storage. Please be advised, however, that should you request that this takes place before a loan completes then we will be unable to provide you with funds. Where your loan does complete we have an obligation to retain your information in order to assure the performance of the loan contract so will be unable to remove your data during the term of any loan taken out with West One. Please contact the firm’s Data Protection Representative for further details or to exercise your rights.
Where you or we become aware of an error in the data that West One processes or holds, you have a right to have that data corrected. You can inform our Data Protection Representative of any errors that need to be corrected.
You also have the right to request either the details of the data we hold on you or to request a copy of this. We are obliged to provide this to you within 30 days of receipt of your request. Please contact the firm’s Data Protection Representative to request this.
You have the right to request that data which we hold is passed to another Data Controller for their use on your behalf via a “machine readable” format. This can be requested from the Data Protection Representative of West One.
You have the right to withdraw your consent for West One to use your personal data for marketing purposes. Withdrawing consent means that West One will no longer contact you with information on products and services the firm offers which may be of benefit to you.
You have a right to complain, via our Data Protection Representative, in regards to how and why we process, or any errors we have made in the processing of, your data. Your complaint can also be made to the Information Commissioners Office:
Post: ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
West One will only retain your data for as long as is necessary. In all cases this will be for the term of the loan plus 7 years, where you drawdown on your application. Where the loan does not complete we will retain your data for 7 years from the date of final decision on whether you or we wish to proceed with the loan. We are obliged to retain your data for this period in order to meet our regulatory and legislative obligations.
All Data that West One collects is controlled and stores within the UK. We do not transfer data to any entity outside of the UK or the EEA. Where this does occur, we will inform you of the situation and seek your consent prior to the initiation of the transfer.
A ‘cookie’ is a piece of data that a website transfers to the internet browser on your computer’s hard disk, which lets the website “remember” who you are. It will usually contain a unique, randomly generated, number. Major commercial and business websites generally employ cookies. They cannot be used by themselves to identify you, and we will not attempt to use them for this purpose. You can delete cookies manually – if you wish to do so, please consult your browser help manual. (There are also websites that help you do this.) “Session cookies” stay in your browser only until you close it. “Persistent cookies” stay in your browser for longer – how long depends on the “lifetime” of the relevant cookie.
We use session cookies to allow you to carry information across pages and avoid you having to re-type it. We may use persistent cookies so we can recognise your number (but not identify you further) when you return to our website, and, potentially, to enable us to note your interests, and arrange or edit content to match your interests, or those of borrowers generally, in a better way. Third parties may also serve cookies through this website. They may be used to put together statistics to help understand how people use the site, or to check whether, and how often, particular content is being viewed.
Some pages may contain these electronic markers to allow us to count up the people who have visited these pages. They collect limited information, including the time when the page was viewed, and the cookie number. We may also carry web beacons placed by third party advertisers in order to track a campaign’s effectiveness, but, again, these will not collect information that would allow you to be identified personally.