Collection and use of data
This privacy notice lets you know what happens to any personal data that you give to Us, or any that We may collect from or about you. It applies to all cases/examples where We collect your personal data.
The MDS Ltd and our Data Protection Officer
We’re The MDS Ltd, 6 Chenab Court 176a London road SM4 5AR, London UK. We are a data controller of your personal data. We have a dedicated data protection officer (“DPO”). You can contact the DPO by writing to the above address, marking it for the attention of the DPO, or by using the contact details in your policy terms and condition or going to the Contact Us section of our website.
What kinds of personal information about you do we process?
Personal information that we’ll process in connection with all our products and services, if relevant, includes:
• Personal and contact details, such as title, full name, contact details and contact details history;
• Your date of birth, gender and/or age;
• Your nationality, if needed for the product or service;
• Details of beneficiaries, such as joint policy holders, named drivers, beneficiaries of our products
• Family members (if relevant to the product or service);
• Records of your contact with us such as via the phone number of our breakdown service and,
if you get in touch with us online using our online services or via our smartphone app, details
such as your mobile phone location data, IP address and MAC address;
• Products and services you hold with us, as well as have been interested in and have held and
the associated payment methods used;
• The usage of our products and services, any call outs and claims, and whether those claims
were paid out or not (and details related to this);
• Marketing to you and analysing data, including history of those communications, whether
you open them or click on links, and information about products or services we think you may
be interested in, and analysing data to help target offers to you that we think are of interest or
relevance to you;
• Vehicle information, such as make and model, faults, repairs and repair costs. Offers may
include our car, insurance, financial services, connected car, travel and any of our other
products and services;
• Driving school assessment, including feedback and analysis of your instructor;
• Information we obtained from third parties, including information about insurance risk,
pricing, claims history, instances of suspect fraud and usage history;
• Personal information which we obtain from Credit Reference Agencies and Fraud
Prevention Agencies and shared credit history, financial situation and financial history;
• Fraud, debt and theft information, including details of money you owe, suspected instances
fraud or theft, and details of any devices used for fraud;
• Criminal records information, including alleged offences, for example if you apply for
• Information about your health or if you are a vulnerable customer;
• Information about your property, such as location, value, number of rooms, property type and
building work you’ve had done;
• Financial details about you, such as your salary and details of other income, details of your
savings, details of your expenditure, and payment method(s);
• Details about all your existing borrowings and loans, if relevant;
• Information about your employment status, if relevant;
• Information about your property occupier status, such as whether you are a tenant, live with
parents or are an owner occupier of the property where you live at the time of your application;
• Your residency and/or citizenship status, if relevant, such as your nationality, your length of
residency in the UK and/or whether you have the permanent right to reside in UK;
• Your marital status, family, lifestyle or social circumstances, if relevant to the product (for
example, the number of dependents you have or if you are a widow or widower);
• Information we buy or rent from third parties, including demographic information, vehicle
details, details of outstanding finance, vehicle claims history, marketing lists, publicly available
information, and information to help improve the relevance of our products and services;
• Insights about you and our customers gained from analysis or profiling of customers;
• Where relevant, information about any guarantor which you provide in any application;
• Third party transactions; such as where a person other than the account holder uses the
service, information about that person and the transaction; and
• Tax information, if relevant (for example, for savings accounts)
2.What do we use your personal data for?
We use your personal data, including any of the personal data listed in section 1 above, for the
• Assessing an application for a product or service you hold with us, including considering
whether or not to offer you the product or service, the price, the risk of doing so, availability of
payment method and the terms;
• Managing products and services relating to the product or service, or application for one;
• Updating your records, tracing your whereabouts, and recovering debt;
• Managing any aspect of the product or service;
• To make automated decisions on whether to offer you a product or service, or the price,
payment method, risk or terms of it;
• To perform and/or test the performance of our products, services and internal processes;
• To improve the operation of our business and that of our business partners;
• To follow guidance and best practice under the change to rules of governmental and
• For management and auditing of our business operations including accounting;
• To carry out checks at Credit Reference and Fraud Prevention Agencies pre-application, at
application, and periodically after that;
• To monitor and to keep records of our communications with you and our staff (see below);
• To administer our good governance requirements and those of other members of our Group,
such as internal reporting and compliance obligations or administration required for Annual
General Meeting (“AGM”) processes;
• For market research and analysis and developing statistics;
• Assessing and profiling aspects of your vehicle (including assessing and predicting faults or
issues), driving style (including recommending improvements and assessing risk associated
with your driving style), location and routes taken (if relevant to your product or service);
• To provide personalised content and services to you, such as tailoring our products and
services, our digital customer experience and offerings, and deciding which offers or
promotions to show you on our digital channels;
• To develop new products and services and to review and improve current products
• To comply with legal and regulatory obligations, requirements and guidance;
• To provide insight and analysis of our customers both for ourselves and for the benefit of
business partners either as part of providing products or services, helping us improve products
or services, or assess or improve the operating of our businesses;
• To share information, as needed, with business partners (e.g. financial services institutions,
insurers), account beneficiaries, service providers or as part of providing and administering our
products and services or operating our business;
• To facilitate the sale of one or more parts of our business;
3.What are the legal grounds for our processing of your personal information (including when we
share it with others)?
We rely on the following legal bases to use your personal data:
1) Where it is needed to provide you with our products or services, such as:
a) Assessing an application for a product or service you hold with us, including consider
whether or not to offer you the product, the price, the payment methods available and
the conditions to attach;
b) Managing products and services you hold with us, or an application for one;
c) Updating your records, tracing your whereabouts to contact you about your account and
doing this for recovering debt (where appropriate);
d) Sharing your personal information with business partners and services providers when
you apply for a product to help manage your product;
e) All stages and activities relevant to managing the product or service including enquiry,
application, administration and management of accounts, illustrations, requests for
transfers of equity, setting up/changing/removing guarantors; and
f) For some of our profiling and other automated decision making to decide whether to offer
you a product and/or service, particular payment method and the price or terms of this.
2) Where it is in our legitimate interests to do so, such as:
a) Managing your products and services relating to that, updating your records, tracing
your whereabouts to contact you about your account and doing this for recovering debt
b) To perform, test the performance of, our products, services and internal processes;
c) To follow guidance and recommended best practice of government and regulatory bodies;
d) For management and audit of our business operations including accounting;
e) To carry out searches at Credit Reference Agencies pre-application, at the application
stage, and after that. Where you have been introduced to us by a broker or other
intermediary they may do these searches on our behalf;
f) To carry out monitoring and to keep records of our communications with you and our staff
g) To administer our good governance requirements and those of other members of our
Group, such as internal reporting and compliance obligations or administration required
for AGM processes;
h) For market research and analysis and developing statistics;
i) For direct marketing communications and related profiling to help us to offer you relevant
products and services, including deciding whether or not to offer you certain products and
service. We’ll send marketing to you by SMS, email, phone, post and social media and
digital channels (e.g. using Facebook Custom Audiences and Google Custom Match);
j) Subject to the appropriate controls, to provide insight and analysis of our customers to
business partners either as part of providing products or services, helping us improve
products or services, or to assess or to improve the operating of our businesses;
k) For some of our profiling and other automated decision making; and
l) When we share your personal information with these other people or organisations other
than for providing products and services to you, as necessary for running our business or
comply with legal or regulatory obligations.
3) To comply with our legal obligations
4) With your consent or explicit consent:
a) For some direct marketing communications;
b) For some of our profiling and other automated decision making; and
c) For some of our processing of special categories of personal data such as about your
health, if you are a vulnerable customer or some criminal records information.
5) For a public interest, such as:
a) Processing of your special categories of personal data such as about your health, criminal
records information (including alleged offences), or if you are a vulnerable customer.
4.How and when can you withdraw your consent?
Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the contact details in your policy documents or going to the Contact Us section of our website.
5.Is your personal information transferred outside the UK or the EEA?
We’re based in the UK, but sometimes your personal information may be transferred outside the
European Economic Area. If we do so, we’ll make sure that suitable safeguards are in place, for
example by using approved contractual agreements, unless certain exceptions apply.
6.How do we share your information with credit reference agencies?
To process your application, we’ll perform credit and identity checks on you with one or more credit
reference agencies (CRAs). Where you take insurance, financial or credit from us we may also make
periodic searches at CRAs to manage your account with us. To do this, we’ll 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’ll 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);
• Assess payment methods available to you;
• Trace and recover debts; and
• Make sure any offers provided to you are appropriate to your circumstances.
We’ll continue to exchange information about you with CRAs while you have a relationship with us.
We’ll also notify the CRAs about your settled accounts. If you borrow and don’t repay in full and on
time, CRAs will record the outstanding debt. This information may be given to other organisations
by CRAs. The identities of the CRAs, their role 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 on our website.
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’re making a joint application, or tell us that you have a spouse or financial associate, we’ll 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.
7.How do we share your information with Fraud Prevention Agencies?
This is explained in a separate leaflet available on our website or by using the contact details in your
8.What should you do if your personal information changes?
You should tell us so that we can update our records. The contact details for this purpose are in your
policy documents. We’ll then update your records if we can.
9.Do you have to provide your personal information to us?
We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.
10.For how long is your personal information retained by us?
• For as long as we have reasonable business needs, such as managing our relationship with you
and managing our operations;
• For as long as we provide goods and/or services to you and then for as long as someone could
bring a claim against us; and/or
• Retention periods in line with legal and regulatory requirements or guidance.
11.What are your rights under data protection laws?
Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all
circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.
• The right to be informed about your processing of your personal information;
• The right to have your personal information corrected if it is inaccurate and to have incomplete
personal information completed;
• The right to object to processing of your personal information;
• The right to restrict processing of your personal information;
• The right to have your personal information erased (the “right to be forgotten”);
• The right to request access to your personal information and to obtain information about how we
• The right to move, copy or transfer your personal information (“data portability”); and
• Rights in relation to automated decision making which has a legal effect or otherwise
significantly affects you.
You have the right to complain to the Information Commissioner’s Office which enforces data
protection laws - You can contact our DPO for more details on all the above.
12.Your right to object
You have the right to object to certain purposes for processing, in particular to data processed
for direct marketing purposes and to data processed for certain reasons based on our legitimate
interests. You can contact us using the contact details in your policy documents to exercise
13.What are your marketing preferences and what do they mean?
We may use your home address, phone numbers, email address and social media or digital channels
(e.g. Facebook, Google and message facilities in other platforms) to contact you according to your
marketing preferences. You can stop our marketing at any time by contacting us using the details
below or by following the instructions in the communication.
Changes to this Privacy Notice
We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you revisit our website –
If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can use the contact details in your policy book or you can go to the Contact Us section of our website. Alternatively, you can write to MDS LTD, 6 Chenab Court, 176a London Road SM4 5AR, London UK, marking it for the attention of the DPO.