Privacy Notice

When you register your interest for a Start Up Loan using our online form, you need to provide information about your business to determine your initial eligibility under the Start Up Loan Scheme criteria. We may also share this information with our Business Support Partners so that they can assess your eligibility for support. The eligibility questions include:

• whether you have the right to work in the UK;
• details of where your business is located;
• details of when your business started trading; and
• whether you would use your Start Up Loan to pay any debts.

If your business is eligible, you can register your interest by completing the online form and providing us with your name, date of birth, National Insurance Number, personal email address, mobile number; information as to whether you require adjustments to be made to documentation we will send to you (braille, large print, audio, alternative language, sign language, no adjustments, other) or whether there is anything about your circumstances that might make it more difficult to complete the application (this may, for example, include details of any health condition you want to let us know about); gender; marital status; nationality as shown on your passport (to determine if you need to provide right to work / visa information); ethnic background (to help us understand the individuals that we work with and ensure there are equal opportunities); employment status; gross annual income (including benefits); and whether you have any unspent current or pending convictions (for fraud prevention purposes and to assess the viability of the proposed business activities).

We use the abovementioned information to create an online account, so you can start the loan application process. Data subjects: Prospective Applicants

• Art. 6(1)(e) public task in the delivery of a government scheme
• Art. 9(2)(g) substantial public interests to prevent fraud
• Schedule 1, paragraphs 14 and 15 of the Data Protection Act 2018
• Art. 9(2)(g) substantial public interests to monitor equal opportunities

As part of the registration process, you can elect to receive direct marketing communications from us via e-mail, including useful business tips, industry news, guidance and information about Start Up Loans that could assist with your start up journey. You can unsubscribe or withdraw your consent to marketing at any time, see section 11 for contact details.

Data subjects: Prospective Applicants, Applicants, Borrowers

• Art.6(1)(a) consent

Following registration, when you apply for a Start Up Loan, we ask for the following information:

• three years of resident address history;
• information on the nature of your residence (e.g., whether you own your home and are sole owner or otherwise);
• whether you, or an immediate family member have ever been a member of the British Armed Forces; and
• whether, in the last three years, you have received any other de minimis State aid and/or subsidy (Minimal Financial Assistance), including details on the amount of State aid and/or subsidy you have received in the last three years.

In addition, as part of your application, you will have to undergo a personal credit check (and to confirm your name, date of birth and address details and to supply your personal current account number and sort code) to ensure that you are able to afford the repayments if your application is successful, and we may share this information with our Business Support Partners.

As part of the application process, we will also require you to provide details about your business (including what it does/will do and details of any business partners who have already received or are currently applying for a Start Up Loan, a business plan and a personal survival budget).

Verification documents will also need to be provided (such as your personal ID and bank statements).

We match the information you provide with third party data sources to assess your eligibility to the SUL Scheme, and will share the information you have provided with credit reference and fraud prevention agencies to conduct credit assessment and fraud prevention checks using Experian and CIFAS services.

The Experian credit check is an enhanced check to assess your credit status and the check leaves a footprint on your credit history that may affect your future credit rating. We share the results of the credit checks we undertake with our Finance Providers to make sure you can afford a Start Up Loan. The CIFAS service is used for the purposes of fraud prevention. For further information about CIFAS and Experian in general please see their privacy notices at: Website Privacy Notice | Cifas and Experian Privacy Policy

Once the checks are completed, your application will either (a) progress to the next stage and your details will be shared with one of our Business Support Partners to support you in your loan application or (b) be declined. This decline may be a result of an automated decision.

Data subjects: Prospective Applicants, Applicants, Borrowers

• Art. 6(1)(e) public task in the delivery of a government scheme
• Art. 6(1)(b) taking steps to enter a contract (for any automated decision making)
• Art.9(2)(g) in the public interest (equalities)
• Art. 9(2)(g) substantial public interests to prevent fraud

A key part of the Scheme is post-loan support where Borrowers can obtain assistance such as business mentoring for the first 12 months of the loan period.

When a loan is drawn, the Borrower’s name and contact details are shared with the Post-Loan Support Provider, so they can contact the Borrower to confirm what services are available and how to access them, for example business mentoring.

Post-loan support is not mandatory, so you can opt-out at any time.

The Post-Loan Support Provider will provide us with information about the interactions they have with Borrowers to help us understand the take-up and effectiveness of post-loan support. The Post Loan Support Provider will provide us with information about the interactions they have with Borrowers to help us understand the take-up and effectiveness of post loan support.

Data subjects: Borrowers

• Art. 6(1)(e) public task in the delivery of a government scheme

If you contact us by telephone, email, social media, post, or webchat, we will keep a record of your contact and our response.

The information collected will depend on why you contacted us, but will usually include your name, contact details, and the details of the contact.

If you have a complaint regarding service, information or communications provided by the Scheme, then this complaint should be submitted directly to Start Up Loans Customer Services Team.

Please see our Complaints Policy for full information.

If the matter involves your Business Support Partner or Finance Provider, we may have to share the details of your contact with them to enable us to investigate fully or to refer the matter to them for investigation.

Data subjects: Prospective Applicants, Applicants, Borrowers

• Art. 6(1)(e) public task in the delivery of a government scheme
• Art. 9(2)(a) consent where special category data is provided

We need your name and contact details and details of the matter being raised, to be able to investigate and reply to you.

Data subjects: Requestors

• Art. 6(1)(c) legal obligation

We send customer surveys to obtain feedback about our services to help us improve what we do.

These surveys are sent by SMS or email and usually following a telephone interaction and at various stages through your application.

Data subjects: Prospective Applicants, Applicants, Borrowers

• Art. 6(1)(e) public task in the delivery of a government scheme
• Art. 9(2)(a) consent where special category data is provided

We use case studies to promote the Scheme and show how the loans have been used. If you apply to be a case study, we need your name and contact details (and may need your photograph) and the information about your business and business experience.

We aim to use our case studies and if selected we will publish the information or use it in promotional literature or events. We might also share the case study information with third parties such as DBT or the media, but we will only do so if you have provided consent.

Data subjects: Borrowers

• Art. 6(1)(a) consent

We have commissioned Propello, a third party, to manage the promotion of the business offers, discounts and promotions that are available to Borrowers once they have drawn down and received a loan. The promotions are intended to help support businesses to grow and develop. This service will be available for 12 months from receipt of a Start Up Loan as part of the post-loan support services from Start Up Loans.

If you consent, your information will be shared with Propello who will add your details to their Reward platform and you will be sent details to verify your account. You will have the option to subscribe to receive daily, weekly, or monthly marketing emails or to unsubscribe at any time.

For details about how Propello process Personal Data, see their privacy notice at Customer Loyalty Platform | Propello (propellocloud.com).

We have also commissioned Newable as the Post-Loan Support Provider to provide you with 12 months of free business support when you take out a Start Up Loan. At application stage, you will be given the option to opt-out of our membership offer by Newable. Throughout the initial 12 months of the loan, you have the option to change your mind and opt back in. If you opt-in, your information will be shared with Newable to aid the provision of its services.

For details about how Newable processes Personal Data, see their privacy notice at Privacy Policy - Newable Group - Newable.

Data subject: Borrowers

• Art. 6(1)(a) consent

We contract with specialist services to provide Start Up Loan Scheme documents in a different language or format, for example large print or Braille. If you request copies of such documents, we share your name and address with the contracted provider, so they can provide the materials directly to you.

Prospective Applicants, Applicants, Borrowers

• Art. 6(1)(e) public task in the delivery of a government scheme
• Art. 9(2)(g) in the public interest (equalities)

SUL has a loan affiliate arrangement where organisations can recommend the Start Up Loan Scheme to individuals as a viable product.

The individual applies for the loan themselves and if they are successful, we reward the loan affiliate. In some cases, we may also provide the affiliate with the name of the borrower so they can update their customer records.

Data subjects: Prospective Applicants, Applicants, Borrowers

• Art. 6(1)(f) legitimate interests to share personal data with the affiliate

We record telephone calls to our customer services team and business advisors. The recordings are used to assist in quality monitoring and investigate complaints, which may require the recordings to be shared with the relevant Business Support Partner.

Data subjects: Prospective Applicants, Applicants, Borrowers

• Art. 6(1)(f) legitimate interests

When you express an interest in the Start Up Loan programme with one of our Business Support Partners using their online form, your name and email address will also be sent to us.

We collect this information, so that if you do register for a Start Up Loan, we can match you to the Business Support Partner you first contacted. If you don’t progress your interest with the Start Up Loan Programme, we will delete your information after 90 days.

Data Subjects: Prospective Applicants

• Art. 6(1)(e) public task in the delivery of a government scheme