Complaints Policy
Introduction
National Hunter is a not-for-profit membership organisation that helps prevent fraud by facilitating the secure sharing of data contained in applications for financial products. It is governed by a Board of Directors elected by the membership, with day-to-day operations managed by a Managing Director.
Although National Hunter is not regulated by a specific body, its individual member organisations are regulated by the Financial Conduct Authority (FCA).
This Complaints Policy outlines how we handle concerns related to the processing of personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018). As a data processor, National Hunter processes personal data only on behalf of its member organisations (the data controllers), who determine the purpose and legal basis for processing.
Our Role as a Data Processor
As a data processor:
• We process personal data strictly under the instructions of our member organisations (data controllers).
• We do not determine the purposes or lawful basis for the processing of personal data.
• We are not authorised to amend or delete personal data unless instructed by the relevant data controller.
• We are unable to act on requests concerning personal data held by the data controller. This would include requests for removal/erasure or objection to a fraud-related decision or status applied by your lender.
• There are very specific and limited cases involving clear factual errors where we would be able to make any changes to the data.
Raising a Concern About Your Personal Data
If you believe your personal data has been mishandled or contains inaccuracies, your first point of contact should be the data controller. That is the organisation that originally collected or submitted your data for anti-fraud purposes.
The data controller is responsible for:
• Responding to data subject rights requests (e.g., access, rectification, erasure).
• Making decisions about how your data is used.
• Investigating complaints regarding the handling of your personal information.
If you are unsure who the relevant data controller is, we can assist you in identifying the appropriate organisation.
What We Can Do
While we are unable to independently modify or remove data, we may assist in the following circumstances:
• Correcting factual errors: If there is a verifiable mistake in the data we process (e.g., an incorrect date of birth due to a data entry error), we may correct it once confirmed.
• Referring you to the correct data controller: If you do not know which organisation to contact, we can help redirect your enquiry to the appropriate party.
Please note that we cannot act on requests involving decisions, assessments, or opinions made by data controllers or their partners.
How to Register a Complaint
Complaints may be submitted by individuals whose data is processed by National Hunter, or by authorised representatives acting on their behalf.
Complaints may be submitted via email or post. Please ensure all correspondence includes sufficient detail to identify the concern.
Email: info@nhunter.co.uk
Postal Address: One St Peter's Square, Manchester, M2 3DE
We aim to acknowledge receipt of your complaint within 5 working days and provide a response within 20 working days. Postal complaints may take longer to acknowledge and process. If additional time is required, we will keep you informed of progress.
We maintain a log of all complaints and their outcomes as part of our commitment to transparency and accountability. In addition, they are retained in line with our internal retention policy. This Complaints Policy is reviewed periodically to ensure it remains up to date and effective.
How to Contact Us
If you believe there is a factual error in the data we process and would like to raise a concern, please contact us with the following information:
• A description of the data in question
• The nature of the suspected error
• Any reference number or identifier, if available
Email: info@nhunter.co.uk
Postal Address: One St Peter's Square, Manchester, M2 3DE
If you require this policy in an alternative format (e.g., large print or accessible digital format), please contact us.
Further Steps
If you are dissatisfied with the response received from the relevant data controller, you have the right to escalate your concern to the UK's data protection authority:
Information Commissioner's Office (ICO)
Website: https://ico.org.uk
Telephone: 0303 123 1113