Your Data Journey Explained
Date last updated: May 2020
The following are a series of ‘real-world’ examples that help to explain how your personal data is collected, used and shared by Equifax - and what the potential impact of that use is on you.
These examples relate to:
- Credit, account management and debt tracing
- Identity verification and fraud services
- Marketing services
For more details of how and why your personal data is used by Equifax or to find our contact details, please see the Equifax Information Notice (EIN) available at: https://www.equifax.co.uk/ein.html
1. Your Credit Data Journey
- When you apply for credit, you will need to complete an application and give some information about yourself and your financial circumstances, such as your income, job and assets (e.g. whether you own a home).
- The lender will, through their privacy notice, explain how your personal data is being used by them and Equifax.
- To assess your application, the lender will usually collect information about you from three main sources:
- You (what you put in your application form, such as details of your job and income)
- The lender’s own database (any information the lender may already have about you, for example, if you are an existing customer)
- Your credit report from Equifax or other credit reference agencies (CRAs)
- Lenders will also check your identity to help confirm that you are who you say you are. This may involve the lender checking the information you provide against your credit report held by Equifax or other CRAs.
- If your identity check is successful, Lenders will likely want to understand your credit history. This is how well you have managed your credit accounts in the past and what credit accounts you have now (loans, mortgages, etc). This is a key factor in assessing your credit risk because it shows what kind of borrower you are and how much money you already owe. As well as your credit history, lenders may look at publicly available information about you which can also help to determine your creditworthiness (for example, CCJs, Electoral Roll, and Bankruptcy information).
- Equifax will provide the required information to your lender to help them make the lending decision. Equifax does not make this decision. In fact, each lender has its own criteria for assessing risk. This means that your application may be accepted by one lender but not another, despite both reviewing the same information.
- Your lender will then communicate the outcome of the lending decision to you. If your application is unsuccessful, your lender will let you know if Equifax data was used as part of the decision. You have the right to request a copy of your data directly from Equifax to understand all of the data that we hold about you that could have been used by the lender to make the decision.
Ongoing Account Management
- If your application is successful, your lender will provide details of your credit facility to Equifax. The Lender will, on a monthly basis, update Equifax with the status of your account activity and your credit report will also be updated accordingly by Equifax.
- Equifax will, at the request of the lenders, continually review your credit information to understand whether your financial circumstances have changed. This helps to inform lenders in deciding if they need to make any adjustments to your credit limit (for example).
- If you are struggling to pay your monthly payments, the lender may approach Equifax to advise on the approach to recover any monies owed.
- If your lender is unable to contact you at the address they have on file (either in relation to money you owe or money that the lender owes you), they may request Equifax to provide them with potential alternative contact details.
- Equifax may hold different contact details for you if (for example) you have registered to vote at a new address or you have provided an alternative address when applying for other loans or credit facilities, which resulted in a search being made with Equifax by that lender.
2. Your ID Verification Data Journey
- An organisation you are dealing with (e.g. when you are applying your credit, seeking to rent a property or applying for a job) may wish to check that you are who you say you are, which helps to prevent fraud.
- To check your identity, the organisation will usually collect the following information about you:
- Date of Birth
- Additionally they may also collect:
- Bank account numbers and sort codes
- Email Address
- Telephone number
- Through a two-step process the company will check that your ID exists and that your ID belongs to you. The organisation may then send this information to Equifax or other CRAs. We will compare this data with the data we already hold to check that:
- the data exists; and
- the data matches records we hold about you.
- If there are inconsistencies or gaps with the information checked (for example you may have recently changed your name), the organisation may wish to ask you additional questions in order to verify any inconsistencies.
3. Your Marketing Data Journey
- When a property is listed for sale or rent, that information is made publicly available and is, in some cases, received by Equifax. Equifax provides this information to its clients who may use it to send relevant marketing communications to the property. For example, details of how the outgoing resident may want to migrate their broadband services, or offers to new residents on new broadband services.
- If you move into a new property, you will likely register to vote in public elections. This means that your name and your new address will be added to the Electoral Register. There are two versions of the Electoral Register; the ‘full version’ and the ‘open register’ (‘edited register’ in Northern Ireland). When you register to vote, your details will be automatically added to the open register unless you ‘opt-out’, in which case your details will be only added to the full register. The difference is that the open register is available for anyone to purchase.
- Equifax purchases a copy of the open register as and when it is updated (which is monthly) and makes the relevant information available to its clients (typically on a monthly basis also).
- We permit our clients to use the open register data (for example, your name and new address) for their own direct marketing activities (where lawful to do so). This means that you may receive postal marketing from companies with whom you have no prior relationship.
- Wherever you live in the UK (whether it is a new area or one in which you have lived for some time), you may occasionally receive marketing based on a profile generated by Equifax about that area.
- Equifax obtains data about you (including from lenders and publicly available sources like the open register). Equifax will aggregate this data and remove any information that identifies you (meaning that a third party can no longer identify you from the data) and combine it with anonymised data we hold to build a ‘picture’ of a geographical area (for example a town or city). This might indicate the general spending habits of residents in an area and/or if they are more or less likely to purchase new products more quickly than average.
- We make this ‘picture’ (or profile) available to clients who can use it to send generic marketing to all of the households in the relevant area. If you live in this area, you may occasionally receive such marketing (for example, you may receive a leaflet addressed to “Dear Occupier” (or similar), providing you with various offers).
- We do not permit clients to combine the profile with any personal data they already hold about individual residents in the relevant area, for the purpose of sending individually targeted marketing. This means that you should not receive any marketing (on reliance of the Equifax area profile) which identifies you as an individual or otherwise targets you as an individual.
- Should you ever want to stop receiving marketing communications, you can contact the sender at any time and ask them to remove you from their marketing lists. The sender must comply with this request. You can also contact Equifax using the contact details included in the Equifax Information Notice (please find the link above). Finally, you also have a number of other rights, which are explained in SECTION 9 of the Equifax Information Notice.