Robert Owen Community Banking Limited

Privacy Policy

1. Who We Are

Robert Owen Community Banking Fund Ltd (“ROCBF”, “we”, “our”, or “us”) is a not-for-profit community development finance institution providing lending and related financial support services.

Authorised and regulated by the Financial Conduct Authority (FCA), Firm Reference Number 726281.

Companies House Registration Number: 5832750

We are committed to protecting the privacy and security of personal information and handling personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable data protection legislation.

Contact Details

Robert Owen Community Banking Fund Ltd
3rd Floor, Royal Welsh Warehouse, 17 Old Kerry Road, Newtown, Powys SY16 1BH
Telephone: 01686 626234
Email: jackiem@rocbf.co.uk
Website: www.rocbf.co.uk

Data Protection Contact

If you have any questions regarding this Privacy Policy or how ROCBF processes personal information, please contact:

Head of Operations
Robert Owen Community Banking Fund Ltd
Email: jackiem@rocbf.co.uk
Telephone: 01686 626234

ROCBF is registered with the Information Commissioner’s Office (ICO).

2. What Information We Collect

We may collect and process personal information including:

  • Name, address, date of birth, and contact details
  • Proof of identity and proof of address documentation
  • Financial information including income, expenditure, assets, liabilities, bank statements, and credit history
  • Information relating to loan applications and lending decisions
  • Payment and bank account details
  • Employment and business information
  • Correspondence and communications with us
  • Information obtained through Open Banking services where consent has been provided
  • Technical information relating to the use of our website and online systems

In some circumstances, we may also process special category data where this is necessary to support customers experiencing vulnerability or financial difficulty.

3. How We Collect Information

We collect information directly from:

  • Applicants
  • Borrowers
  • Guarantors
  • Directors
  • Other individuals connected to loan applications

We may also collect information from:

  • Credit reference agencies
  • Fraud prevention agencies
  • Open Banking providers
  • Local authorities and public sector partners
  • Professional advisers
  • Publicly available sources
  • Third-party introducers or referral partners

4. How We Use Personal Information

We use personal information to:

  • Assess loan applications and affordability
  • Verify identity and prevent fraud and financial crime
  • Administer loans and ongoing customer relationships
  • Collect payments and manage arrears
  • Meet legal and regulatory obligations
  • Carry out internal reporting, audit, and governance activities
  • Improve products and services
  • Communicate with customers and applicants
  • Monitor outcomes and impact relating to funding programmes

5. Lawful Bases for Processing

We process personal information under one or more of the following lawful bases:

  • Performance of a contract
  • Compliance with legal obligations
  • Legitimate interests pursued by ROCBF
  • Consent, where required
  • Substantial public interest, where applicable

Our legitimate interests include:

  • Responsible lending
  • Fraud prevention
  • Risk management
  • Governance
  • Effective administration of services

6. Credit Reference and Fraud Prevention Agencies

We may share information with credit reference agencies and fraud prevention agencies in order to:

  • Assess creditworthiness and affordability
  • Verify identity
  • Prevent fraud, money laundering, and financial crime
  • Trace and recover debts

These agencies may retain records of searches carried out.

7. Open Banking

Where applicants choose to use Open Banking services as part of a loan application, we may receive financial information from authorised Open Banking providers.

Open Banking access is only provided with the customer’s consent and is used to help assess affordability and financial circumstances.

8. Sharing Information with Third Parties

We may share personal information with trusted third parties where necessary for the operation of our services and lending activities.

These may include:

  • Loan management and CRM system providers, including Soar Technology Ltd
  • Direct debit and payment processing providers
  • Identity verification providers
  • Open Banking providers
  • Credit reference and fraud prevention agencies
  • IT support, cloud storage, and software providers
  • Professional advisers including auditors, accountants, solicitors, and insurers
  • Regulators, government bodies, and funders including the British Business Bank and Welsh Government where required
  • Debt recovery or tracing agencies where necessary
  • Partner organisations involved in the delivery of specific programmes

We require third-party service providers processing personal data on our behalf to protect personal information appropriately and only process it in accordance with our instructions.

9. Automated Decision Making

ROCBF does not normally make lending decisions based solely on automated processing.

Applications are reviewed by members of staff and lending decisions involve human assessment and oversight.

10. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

Retention periods may vary depending on the type of information and the nature of the relationship with ROCBF.

11. Data Security

We take appropriate technical and organisational measures to protect personal information against:

  • Unauthorised access
  • Loss
  • Misuse
  • Alteration
  • Disclosure

These measures include:

  • Access controls and password protection
  • Secure systems and software providers
  • Staff training and confidentiality obligations
  • Secure document storage and disposal procedures
  • Monitoring and controls designed to reduce fraud and cyber-security risks

12. International Transfers

We normally store and process personal information within the United Kingdom or European Economic Area (EEA).

Where personal information is transferred outside the UK or EEA, we will ensure that appropriate safeguards are in place in accordance with applicable data protection laws.

13. Your Rights

Individuals have rights under data protection legislation including the right to:

  • Access personal information
  • Request correction of inaccurate information
  • Request deletion of information in certain circumstances
  • Restrict or object to processing in certain circumstances
  • Withdraw consent where processing relies on consent
  • Request transfer of data to another provider where applicable
  • Complain to the Information Commissioner’s Office (ICO)

Requests relating to personal information should be made using the contact details provided above.

14. Complaints

If you have concerns about how ROCBF handles personal information, please contact us in the first instance.

You also have the right to complain to the Information Commissioner’s Office:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Website: https://www.ico.org.uk

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in:

  • Legal requirements
  • Technology
  • Our services
  • The organisations we work with

The latest version will always be available on our website.

Last updated: May 2026