Data protection policy

Introduction

Acorn.finance needs to gather and use certain information about individuals.

This can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards — and to comply with the law.

Why this policy exists

This data protection policy ensures Acorn.finance; complies with data protection law and follows good practice protects the rights of all individuals’ data is open about how it stores and processes individuals’ data in line with individuals’ rights protects itself from the risks of a data breach.

Data protection law

The General Data Protection Regulations describe how organisations — including Acorn.finance— must collect, handle and store personal information. These rules apply regardless of whether data is stored electronically or otherwise.

To comply with the law, personal information must be;

Processed lawfully, fairly and in a transparent manner in relation to individuals
Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes
Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed
Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

Record Keeping:

A range of information is detailed in our internal records of processing activities. Such areas include;

The name and details of the organisation
The organisation’s representative and data protection officer
Purposes of processing the data
Description of the categories of individuals and the categories of personal data
Categories of the recipients of personal data
Details of transfers of data to third parties or abroad, including details of safety mechanisms
Retention schedules
Technical and organisational security measures

Acorn.finance ensures that records of these activities are kept and are updated accordingly. Individuals’ data is kept on file for 6 years after our work with you is complete, in line with the Financial Conduct Authorities record keeping rules. After which point, personal data is retracted to the point it is unidentifiable and used for statistical purposes only.

Lawful Basis for Processing Data

Under GDPR, it is a requirement that Acorn Finance has a valid lawful basis to process personal data, this should be documented. Most lawful bases require that processing is ‘necessary’.

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever Acorn Finance process personal data: Processing is lawful under GDPR as:

Consent:
- The individual has given clear consent for us to process their personal data for a specific purpose.
Contract:
- The processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
- Acorn Finance has chosen this basis for processing data as it is requested from the individuals that we capture data before entering into a contract (e.g. provide a quote for finance).

Special categories of data may be captured by Acorn Finance, for example, information about an individual’s:

Financial backrgound
Credit background

Responsibilities

Acorn Finance acts as a Data Controller and Data Processor. All staff are responsible for ensuring that the highest data standards and best practices are met on a continual basis.

Although a Data Protection Officer (DPO) has not been appointed as Acorn Finance does not fall within the scope, the business owner is accountable and responsible for compliance with GDPR and will take on the tasks appointed to them as if they were a DPO.

Data Protection Impact Assessments (DPIA)

Acorn Finance has a general obligation to implement technical and organisational measures to demonstrate that data protection is integrated into our processing activities. A Data Protection Impact Assessment is conducted each time Acorn Finance consider implementing using new technologies

The DPIA will pertain at least; a description of the processing operations and the purposes, including, where applicable, the legitimate interests pursued by the controller; an assessment of the necessity and proportionality of the processing in relation to the purpose; an assessment of the risks to individuals; the measures in place to address risk, including security and to demonstrate that you comply.

Individuals Rights

Individuals now have more rights under GDPR.

The Right to be Informed
The Right of Access
The Right to Rectification
The Right to Erasure
The Right to Restrict Processing
The Right to Data Portability
The Right to Object
Rights in relation to automated decision making and profiling

Acorn.finance provides every customer with a Privacy Notice at the point data is captured.

The information supplied in this notice demonstrates how Acorn Finance is transparent over our data processing. The notice is; concise, transparent, intelligible and easily accessible, written in clear and plain language and free of charge.

We include details of (but not limited to); the Data Controller, the lawful reason for processing data, if any third parties have legitimate interests, categories of personal data, categories of recipients such as banks and credit unions, the data retention periods, the individuals’ rights; including the right to withdraw, where the individual can complain about how the data is processed with a supervisory authority, source of data when it comes from a third party and where personal data is part of a contractual requirement or obligation.

Rectification

Individuals are entitled to have personal data rectified if it is inaccurate or incomplete. If Acorn Finance has disclosed the personal data in question to third parties, then we will inform them of the rectification where possible.

Acorn Finance will respond to this request within one month or extended by two months where the request for rectification is complex.

Erasure

Individuals have a right to have personal data erased and to prevent processing in specific circumstances;

where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed. when the individual withdraws consent. when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing. the personal data was unlawfully processed (i.e. otherwise in breach of the GDPR).

the personal data must be erased to comply with a legal obligation. the personal data is processed in relation to the offer of information society services to a child. under the GDPR, this right is not limited to processing that causes unwarranted and substantial damage or distress. However, if the processing does cause damage or distress, this is likely to make the case for erasure stronger. Acorn Finance may refuse to comply with a request for erasure where the personal data is processed for the following reasons;

to exercise the right of freedom of expression and information; to comply with a legal obligation for the performance of a public interest task or exercise of official authority. for public health purposes in the public interest; archiving purposes in the public interest, scientific research historical research or statistical purposes; or the exercise or defence of legal claims.

If Acorn Finance has disclosed the personal data in question to third parties, a notification will be sent, informing them about the erasure of the personal data, unless it is impossible or involves disproportionate effort to do so.

Restrict processing

Acorn Finance will restrict the processing of personal data in the following circumstances;

where an individual contest the accuracy of the personal data, you should restrict the processing until you have verified the accuracy of the personal data. where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and you are considering whether your organisation’s legitimate grounds override those of the individual.

when processing is unlawful, and the individual opposes erasure and requests restriction instead. if you no longer need the personal data but the individual requires the data to establish, exercise or defend a legal claim. if any data has been disclosed to third parties, Acorn Finance will notify them about the restriction on the processing of the personal data, unless it is impossible or involves disproportionate effort to do so.

Portability For personal data an individual has provided to a controller; where the processing is based on the individual’s consent or for the performance of a contract; and when processing is carried out by automated means, Acorn Finance must provide the personal data in a structured, commonly used and machine-readable form. Open formats include CSV files. Machine readable means that the information is structured so that software can extract specific elements of the data. This enables other organisations to use the data.

Acorn Finance must provide this service free of charge.

If the individual requests it, we may be required to transmit the data directly to another organisation if this is technically feasible. Acorn Finance will respond without undue delay, and within one month or extended by two months where the request is complex or receive many requests.

Objecting

If an individual has objected to processing data or direct marketing, Acorn Finance will cease to process the data. Individuals must have an objection on “grounds relating to his or her particular situation”. Acorn Finance will stop processing the personal data unless;

compelling legitimate grounds for the processing, which override the interests, rights and freedoms of the individual; or the processing is for the establishment, exercise or defence of legal claims. This is brought to the attention of the data subject at the first point of communication and in our privacy notice. This is separated out from any other information.

Direct marketing purposes

As soon as an objection is received, Acorn Finance will stop processing personal data for direct marketing purposes. This will be actioned at any stage and is free of charge. Our communications allow an opt-out at any point.

Automated decision making including profiling

Acorn Finance understands that any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse, or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour falls under this right. Where this is conducted, the rules and guidance of the ICO will be adhered to and followed. To date, Acorn Finance does not conduct automated decision making including profiling.

Subject Access Requests (SAR)

Individuals who are the subject of personal data held by Acorn Finance are entitled to;

confirmation that their data is being processed; access to their personal data; and other supplementary information – this largely corresponds to the information that should be provided in a privacy notice Individuals contacting the company requesting this information, this is called a Subject Access Request.

Acorn Finance will provide a copy of the information free of charge. However, a ‘reasonable fee’ may be charged when a request is manifestly unfounded or excessive, particularly if it is repetitive.

A reasonable fee may also be charged to comply with requests for further copies of the same information. The fee is based on the administrative cost of providing the information only.

Once the identity of the person making the request has been verified, the information will be provided within 1 month, this will be extended to 2 months if the request is complex. Notification will be made to the individual if this is the case.

Complaints regarding data processing or protection

It is made clear that data subjects who wish to complain about how their personal data has been processed can raise this with Acorn Finance complaints procedure. If the data subject is still not happy, then the complaint can be referred to the Information Commissioner’s Office.

Data Security and Storage

When data is stored on paper, it will be kept in a secure place where unauthorised people cannot see or have access to it. These guidelines also apply to data that is usually stored electronically but has been printed out for some reason;

When not required, the paper or files will be kept in a locked drawer or filing cabinet.
Employees always make sure paper and printouts are not left where unauthorised people could see them, like on a printer
Data printouts will be shredded and disposed of securely when no longer required.
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts
Data is protected by strong passwords or encryption products
If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used
Data will only be stored on designated drives and servers and should only be uploaded to an approved cloud computing services
Servers containing personal data are sited in a secure location, away from general office space
Data is backed up frequently. Those backups should be tested regularly, in line with the company’s standard backup procedures
Data should never be saved directly to laptops or other mobile devices like tablets or smartphones
All servers and computers containing data should be protected by approved security software and a firewall.

The point that personal data is accessed is when it can be at greatest risk of loss, corruption, theft, unlawful access, Acorn Finance will;

When working with personal data, employees will ensure the screens of their computers are always locked when left unattended
Personal data is not shared informally. It will never be sent by email, as this form of communication is not secure.
Data must be encrypted before being transferred electronically.
Personal data should never be transferred outside of the European Economic Area unless contractual arrangements are in place highlighting adequate safeguards and protection to the rights of individuals.
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

How we will use the information about you

Here at Acorn Finance we take your privacy seriously and will use your personal information in several ways which will help us;

We may share your information with, and obtain information about you from, credit reference agencies or fraud prevention agencies.

If you apply to us for insurance we will pass your details to the insurer.

The information you provided may be put onto a register of claims and shared with other insurers to prevent fraudulent claims.

We will not disclose your information to any company outside of Acorn Finance, our lending sources or other service providers as required to fulfil your requests to us, except to help prevent fraud or if required by law to do so.

For further information on how your information is used, how we maintain the security of your information and your rights to access/alter and change the information we hold on you, please contact [email protected]

Who we are

Paul Thompson trading as Acorn.finance – or Appointed Representatives (Your broker) of them. Our website address is: https://acorn.finance.

Comments

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An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

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Cookies

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If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

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Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.

Complaints

Customer Complaints: Ensuring Fair and Transparent Resolution

At Acorn.finance, we strive to deliver exceptional service and support to our clients. However, if something hasn’t met your expectations, we want to hear from you so we can address the issue promptly and work toward a resolution. We handle complaints fairly, transparently, and efficiently, ensuring compliance with regulatory requirements to protect your rights.

Our Commitment to Resolving Complaints

We take all complaints seriously, whether they involve regulated mortgages, non-regulated business finance, or property finance. Below is an overview of the complaints process, including guidance on which organizations may be able to assist in resolving your complaint, such as the Financial Ombudsman Service (FOS), the National Association of Commercial Finance Brokers (NACFB), and the Financial Conduct Authority (FCA).

Steps to Raise a Complaint

Step 1: Contact Us Directly

Your first step should be to reach out to our team. Please provide as much information as possible, including:

You can contact us by:

Once we receive your complaint, we will acknowledge it within five business days and provide an estimated timeframe for our response.

Step 2: Initial Response and Investigation

We aim to resolve all complaints fairly and promptly. For regulated mortgages, we are required to provide you with a final response within eight weeks. For non-regulated business finance and property finance complaints, we will still endeavor to resolve your issue as swiftly as possible.

Our final response will include:

Routes for Escalating a Complaint

If you are dissatisfied with our final response or feel that your complaint has not been adequately addressed, you may have options for further escalation. Below, we outline the relevant bodies depending on the nature of your complaint.

1. Financial Ombudsman Service (FOS)

The Financial Ombudsman Service offers free, independent resolution for complaints about financial services. They typically handle complaints related to regulated mortgages and other consumer finance products.

When to Contact the FOS:

If your complaint involves a regulated mortgage or financial product provided to an individual or small business.

If you have not received a final response from us within eight weeks or are unhappy with our final response.

How to Contact the FOS:

2. National Association of Commercial Finance Brokers (NACFB)

The NACFB represents commercial finance brokers and promotes high standards of practice. As members, we adhere to their code of conduct. The NACFB can assist with complaints related to non-regulated business finance or property finance.

When to Contact the NACFB:

If your complaint is related to non-regulated commercial finance or business lending.

If you believe our conduct may have breached the NACFB’s code of practice.

How to Contact the NACFB:

The NACFB will review your complaint, investigate it where appropriate, and liaise with us to help reach a fair resolution.

3. Financial Conduct Authority (FCA)

The FCA regulates financial services firms to protect consumers and maintain the integrity of the market. While the FCA does not investigate individual complaints, they may be able to take action if your complaint indicates serious misconduct.

When to Contact the FCA:

If your complaint involves regulated financial products and you believe there may be a regulatory issue.

If you think we have not complied with FCA regulations or you have experienced poor practices in a regulated area.

How to Contact the FCA:

The FCA uses information from complaints to monitor firm behavior and may take action to prevent broader issues in the industry.

Key Differences in Complaint Routes

Type of Finance Complaint Route Relevant Body

Regulated Mortgages Initial complaint to Acorn.finance, then to FOS if unresolved Financial Ombudsman Service (FOS)

Non-Regulated Business Finance Initial complaint to Acorn.finance, then to NACFB if unresolved National Association of Commercial Finance Brokers (NACFB)

Regulated Financial Products Initial complaint to Acorn.finance, with FCA involvement if necessary Financial Conduct Authority (FCA)

Property Finance (Non-Regulated) Initial complaint to Acorn.finance, then to NACFB if unresolved National Association of Commercial Finance Brokers (NACFB)

Frequently Asked Questions (FAQs)

What happens if I don’t receive a response within eight weeks?

For regulated mortgage complaints, you can refer the complaint to the FOS if you have not received a final response within eight weeks.

Can I escalate my complaint directly to the FOS or NACFB without contacting Acorn.finance?

No, you should first give us the opportunity to address your concerns directly. If you remain dissatisfied, you can then escalate your complaint.

Will contacting the NACFB affect my credit rating or relationship with lenders?

No, your complaint to the NACFB will remain confidential and will not impact your credit rating or lender relationships.

We are committed to upholding high standards of service and will work diligently to resolve any complaints you may have. If you need further guidance or wish to begin the complaints process, please get in touch with us directly.

For more information on our services, visit Acorn.finance.