Who We Are
Asset Finance Solutions (UK) Ltd acts as Data Controller for oversight; ARs and lenders may act as independent controllers; joint controller roles are governed by The Data Use and Access Act 2025 (DUAA). Asset Finance Solutions (UK) Ltd (AFS) is an independent commercial finance broker. We are committed to protecting your personal data and ensuring transparency in how we use it.
Joint controller roles are governed by The Data Use and Access Act 2025 (DUAA), which sets out mandatory joint-controller responsibilities, record-keeping, and liability sharing.
Data Controller: Asset Finance Solutions (UK) Ltd
Address: Greenbank Court, Challenge Way, Greenbank Business Park, Blackburn BB1 5QB
AFS Compliance Ltd acts as the principal firm under the Financial Conduct Authority (FCA) Appointed Representative (AR) regime. We are responsible for overseeing compliance through a network of Appointed Representatives (ARs) who operate under our regulatory permissions.
We provide access to our bespoke compliance platform, BIPS, which is used to process finance applications, enforce compliance workflows, and manage deal flow securely. BIPS logs user activity, automates regulatory checks, and ensures consistent adherence to legal and financial standards.
As Principal, we are the data controller for activities related to regulatory oversight, AML, monitoring, and platform performance. In some cases, we act as a joint controller or processor in coordination with ARs and lenders.
Email: gdpr@afsuk.com
Our Data Protection Officer (DPO) can be contacted at the above email for any questions about this notice or your rights.
What Personal Data We Collect
We may collect and process the following categories of personal data:
| Type | Category |
| Identity & Contact Data | Name, date of birth, address, phone numbers, email address, ID documentation (passport, driving license) |
| Financial & Credit Data | Income, expenditure, credit history, employment details, Bank details, financial commitments, and credit reports |
| Transactional Data | Details about the finance products or services you’ve engaged with |
| Usage Data | IP address, browser type, interaction with our website or services |
| Special Category Data | Health information (e.g., if disclosed as part of accessibility or vulnerability declarations) Only collected with explicit consent |
BIPS, our compliance platform, automatically logs deal-related activity, time-stamps key compliance events, and tracks access to sensitive data. These logs are used for regulatory supervision and internal auditing.
How We Collect Your Data
We collect data:
- Directly from you – via forms, phone, email, or our website
- From third parties – including credit reference agencies, introducers, franchisees, and fraud prevention bodies
- Via automated technology – such as cookies and web analytics tools
Why We Process Your Data (Purposes & Lawful Bases)
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Consent: the individual has given clear consent for you 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
- Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations)
- Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law
- Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
| Purpose | Legal Basis | Explanation |
| To assess and arrange finance products | Contractual necessity (Art. 6(1)(b)) | To take steps at your request prior to entering a finance agreement |
| To carry out credit and fraud checks | Legitimate Interests (Art. 6(1)(f))Contractual necessity (Art. 6(1)(b)) | These checks are required by financial crime laws and to assess your suitability for finance.To take steps at your request prior to entering a finance agreement. |
| To communicate with you about your application or finance options | Contractual necessity (Art. 6(1)(b)) & Legitimate Interests (Art. 6(1)(f)) | To ensure clear service delivery and client care |
| To refer your application to lenders or franchisee brokers | Legitimate Interests (Art. 6(1)(f)) & Contractual necessity (Art. 6(1)(b)) | To fulfil your finance enquiry effectively |
| To meet legal and regulatory obligations | Legal obligation (Art. 6(1)(c)) | To comply with UK financial and data protection laws |
| To monitor service quality and handle complaints | Legitimate interests (Art. 6(1)(f)) | To improve service and resolve disputes |
| Marketing communications | Consent (Art. 6(1)(a)) | We will only send marketing communications with your explicit opt-in |
| Processing special category data (e.g., health) | Explicit Consent (Art. 9(2)(a)) | Only processed if freely given by you for specific support needs |
| To monitor compliance via the BIPS platform | Legal obligation (Art. 6(1)(c)) & Legitimate interests (Art. 6(1)(f)) | To ensure ARs meet FCA regulatory standards and prevent misuse of the platform or financial crime exposure |
Credit Checks:
By continuing your application for credit, you are processed under Legitimate Interests and/or Legal Obligation, and in line with DUAA this does not rely on consent. Credit checks may impact your credit file.
Where we rely on Legitimate Interests, we have completed a Legitimate Interests Assessment (LIA). A summary of these assessments is available upon request.
To facilitate the performance of the contract with you, AFS may need to conduct credit checks, either on our behalf or directly through a lender. By continuing your application for credit, you processed under Legitimate Interests and/or Legal Obligation in line with the DUAA that credit checks may be carried out, which could impact on your credit file.
Legitimate interests:
Where we rely on Legitimate Interests, we have completed a Legitimate Interests Assessment (LIA) to ensure that processing is proportionate and does not override your rights.
Who We Share Your Data With
All sharing with lenders, ARs and product providers is governed by the DUAA, which sets out controller responsibilities and safeguards.
Under DUAA joint controller provisions, we and relevant lenders/ARs must ensure you are told which party to contact for exercising your data rights, who is primarily responsible for complaints, and how liability is apportioned.
Typically, AFS is responsible for oversight and compliance queries (gdpr@afsuk.com), while your lender is responsible for decisions on your creditworthiness.
We may share your data with the following third parties, where appropriate:
- Lenders and Financial Product Providers (a full list is available by contacting gdpr@afsuk.com or by clicking here).
- AFS Compliance Ltd (our regulatory compliance body)
- Franchisee firms within our broker network
- Credit Reference Agencies (e.g. Experian, Equifax, TransUnion)
- Fraud prevention agencies (e.g. CIFAS)
- Regulators, such as the Financial Conduct Authority (FCA) or Information Commissioner’s Office (ICO)
- IT service providers, hosting and document management systems
All data-sharing partners are subject to appropriate data protection contracts and safeguards.
Automated Decision-Making
Some lenders may use automated decision-making (e.g., credit scoring) to assess your eligibility. You will be informed directly if this occurs and can request human intervention or express your point of view.
Profiling
Profiling activities are carried out under Legitimate Interests in compliance with the DUAA. You have the right to object and request human review.
We may use limited profiling to help match you with finance providers that best suit your circumstances or business needs. This involves evaluating financial information and preferences to support product suitability decisions.
We do not make decisions solely based on automated profiling that produce legal or similarly significant effects. If profiling is used, you have the right to object and request human involvement in any decision-making process.
International Transfers
Your data is primarily stored in the UK. If it must be transferred outside the UK/EEA, we ensure:
-
- Appropriate standard contractual clauses (SCCs) are in place
- DUAA Transfer Codes or equivalent DUAA-compliant safeguards are in place (replacing reliance solely on EU SCCs)
- Or the transfer is to a country with adequate data protection laws
How We Protect Your Data
We take the protection of your personal data seriously. We use a combination of technical and organisational measures to safeguard it. These include:
- Encryption and secure cloud storage
- Role-based access controls
- Firewalls, antivirus protection, and intrusion detection
- Two-factor authentication where appropriate
- Regular training for staff and Appointed Representatives (ARs)
- Logging and audit trails through our BIPS platform
These safeguards are designed to protect your data against loss, misuse, unauthorised access, disclosure, alteration, or destruction.
Data Retention
Retention periods reviewed for DUAA compliance, particularly in relation to credit check data.
We retain personal data for up to 6 years after your case is closed, in line with FCA requirements and to support legal claims or audits. Specific retention periods may vary depending on the data type:
- Finance application data: 6 years after case closure
- AML/KYC documentation: 6 years from end of relationship
- Call/email records and case correspondence: 3–6 years
- Marketing preferences: Until you withdraw consent
In some cases, we may retain data longer if legally required (e.g., under HMRC rules).
Your Rights
You have the following rights under the UK GDPR:
- Right to access – get a copy of your personal data
- Right to rectification – correct inaccurate or incomplete data
- Right to erasure – request deletion in certain cases
- Right to restrict processing – in limited situations
- Right to data portability – receive your data in a structured format
- Right to object – to processing based on legitimate interests or direct marketing
- Right to withdraw consent – at any time for processing based on consent
To exercise any of these rights, contact: gdpr@afsuk.com
If you’re unsatisfied with our response, you can complain to the Information Commissioner’s Office (ICO):
www.ico.org.uk | Tel: 0303 123 1113
For questions related to your specific finance application, please contact your broker directly. For questions about how your data is processed on the BIPS platform or about AFS Compliance’s role, contact gdpr@afsuk.com.
Cookies and Online Tracking
We use cookies and similar tracking tools to:
- Enhance website functionality
- Measure traffic and performance
- Improve your user experience
We use cookies and tracking tools in compliance with the UK Privacy and Electronic Communications Regulations (PECR) and UK GDPR. Where required, we request your consent before placing non-essential cookies.
You can manage cookie preferences through our Cookie Policy or browser settings.
Children’s Data
We do not knowingly provide services directly to children (under 18s). Our services are intended for business and commercial finance applicants. If we become aware that we hold personal data relating to a child without proper legal basis, we will delete it in accordance with DUAA and UK GDPR.