Privacy notice

Who we are

runs AssignedOnce, the estate lending registry, and is the data controller for the information described here.

Contact

What the registry is for

Someone waiting on an inheritance can raise money now by assigning it to a lender. The lender advances the cash and takes the right to be paid out of the estate when it settles.

The whole entitlement goes across, so it can only be assigned once. After that the borrower has nothing left to assign.

The registry exists because some people assign the same inheritance twice. The second lender pays out against a right the borrower no longer holds, and only finds out when the estate settles and there is nothing to collect. Member firms check the registry before they lend, and record the assignments they take, so a second attempt shows up.

Firms record where they have got to: looking at a case, terms agreed, or money advanced. Only the last of those means the inheritance has gone. Up to that point two firms may both be considering the same person, which is ordinary competition, and we say so rather than implying otherwise.

We also hold a second, smaller kind of record: loans made to an estate itself, repaid by the executor. Nobody's inheritance is assigned in those, so they name no individual and we hold nothing about a person for them.

We do not make lending decisions. We report what member firms have recorded. Whether to lend, and on what terms, is the lender's call. We cannot stop a loan or require one, we do not score anybody, and we are not a credit reference agency.

If you have borrowed against an inheritance

This section is about you, even though you have probably never dealt with us. Your lender has to tell you they use the registry. This explains our side of it.

What we hold

Not your name, and not your date of birth. When your lender records an assignment, those two details are turned into a single one-way value using a secret key, and the originals are thrown away immediately. That value is all we keep. It cannot be turned back into your details, and it is no use to anyone who does not hold our key.

Along with it, and linked to you, we hold:

• Which member firm took the assignment, and when
• Which estate it relates to
• What stage it has reached (being considered, agreed, money advanced, or settled), and the date money was advanced if it was
• A record of firms checking that estate, and what we told them

If a firm records that it is considering lending to you and then never does, that record is deleted automatically after a few months. We do not keep a permanent note that somebody once looked at your case.

We also hold details of the person who died: their name, date of death, and sometimes date of birth and last known postcode. Data protection law does not cover people who have died. We mention it because it is how estates are matched.

Why we are allowed to hold it

Our lawful basis is legitimate interests, under Article 6(1)(f) of the UK GDPR. The interest is preventing fraud, and specifically one kind of it: assigning an inheritance that has already been assigned to someone else. Fraud prevention is recognised in law as a legitimate interest.

Stopping that matters to more people than the lender:

• Lenders, who hand over money against a right the borrower no longer holds. The lender's security is the entitlement itself, so if it has already been assigned there is nothing behind the loan. They can still pursue the borrower personally, through the credit agreement and ultimately bankruptcy, which is why this can end badly for the borrower too.
• Executors, who are left holding two claims on one share and cannot safely pay either until it is sorted out
• Anyone whose name and date of birth are used by somebody else to borrow

We have written down how we weighed those interests against the privacy of the people we hold data about. Ask and we will send it to you.

Who sees it

If a check matches an assignment already on file, both firms are told a match exists and each is given the other's business contact details, so they can sort it out between themselves. We do not give them your name or date of birth. They are not ours to give: we do not have them.

The same happens if a firm advances money on a case another firm was still looking at. The second firm is told, so it stops work on something that can no longer go ahead. It is told the estate and the firm, and nothing about you beyond the fact that a match exists.

A firm only ever sees records connected to its own. There is no way for a member to browse the registry or look someone up, and no way for anyone to get a list of who has borrowed.

How long we keep it

Records of assignments and checks are kept for 6 years after the loan is settled. That is roughly how long a lender might need to show why it lent. After that they are deleted automatically. Details of the person who died and their estate are kept, because they identify nobody living and they are what lets us recognise the same estate coming back.

Your rights

You can ask us to do any of the following, free. Write to . We answer within a month.

No decision here is made by a computer on its own. A flag is information passed to a person at a lending firm. We decide nothing about you.

If you are unhappy with how we have handled your information you can complain to the Information Commissioner's Office at ico.org.uk. We would rather you came to us first so we can put it right.

If you work at a member firm

We hold your name, work email address, and a record of your sign-ins and of the checks and records you make. The lawful basis is legitimate interests: a shared fraud registry has to be able to show who did what, and your firm answers for its own staff. Your firm's administrator controls your account.

We keep your account while it is in use, and for a while after, so the audit trail still makes sense. We never store passwords, only a value that a password cannot be recovered from.

Where the information is held

We do not sell information to anyone. We do not use it for marketing or profiling, or for anything other than what is set out here.