Client Data Security

As a part of our “Client Protection Principle” we are committed to maintain privacy of client data. Client documents/information are kept with security at every stage of loan processing, disbursement and during the tenure of the loan. Due accountability has been fixed with every employee who are responsible for collection of client data, documents, photographs etc. Following are the process of dealing with client.

Document security during sourcing and disbursement of loan.
During day 3 of the CGT we collect following proof of identities from each client.

  1. 5 photographs of the client and 1 photograph his/her spouse(of the 5 client photograph one each to be affixed in Loan agreement cum promissory note, Loan card, KYC form, Loan Proposal, Enrollment form)
  2. Voters’ Identity card. (mandatory)
  3. Ration Card, driving license, Passport (either one of these)
  4. In absence of Voters identity card and Ration card we collect domicile certificate certified by local elected representative for client and his/her spouse.

In no circumstances the concern CSO is authorized to collect additional proof of identity from the client. During the CGT process we educate the client on rational behind collecting the required documents.

During the “5 days-CGT” the concern CSO handling the center handles the client documents (the KYC form, CGT form, loan proposal form and the proof of identity as provided by the client) in his custody. Upon completion of CGT the CSO hands over the documents to the branch manager (BM). BM is responsible for the safe custody of all the client documents during the Pre-GRT and GRT.

Pre disbursement Client data transfer from branch to RO

Upon completion of CGT and GRT the completed set of document (KYC with photograph, Loan proposal with photograph, GRT form) goes to RO for data entry followed by Credit Bureau investigation. The same is usually transferred through the Branch Messenger or courier. The messenger/courier delivery person handover to the loan dossier to the Admin Officer of RO. Admin Officer acknowledges the receipt of all such documents.

The admin officer in turn handovers the document to respective Data Entry Operator (DEO) assigned to handle and manage the data/files and reports of the branch. Typically one DEO is responsible for the data entry and document management of 3 branches (1 territory). The DEO in acknowledged the receipt of documents from the Admin Officer.

One still safes (almirahs)/filing rack is assigned for every branch in region office. The key of the record room is in control of the MIS officer while the almirah key remains with the DEO. Only authorized person with permission from the Regional Manager can have access to client document.

After necessary data entry and check from authorized Credit Bureau the branch confirms about the approval status of the loan to the branch. In case the loan is rejected the documents are stored in rejected file rack. In case clients demand return of their photograph and identity proof, with the permission from Regional Manager we refund the same to the clients.

Post disbursement document transfer from branch to RO

After the disbursement documents pertaining to the disbursal of loan consisting of loan agreement, sheet of disbursement, promissory note (with photograph) migrates from branch to RO. The documents come through the messenger or through courier. The Admin Officer acknowledges the receipt of all such documents while he handovers all such documents to responsible DEO of the branch. The DEO prepares the complete dossier center wise. The loan proposal of members of one center (consisting of 15 to 25 clients) remains one file while the files of all loan clients of a branch remains in one filing rack/safe with control key remains with the DEO responsible for the branch.

Authorized persons to access client data

Following persons are authorized to access client data upon approval from Regional manager, Zonal Manager, Vice president or COO.

  1. Internal auditors of the company.
  2. Company appointed external/statutory auditor.
  3. Representative from Credit bureau.
  4. Representative from Regulator (RBI)
  5. Management representative of the company.
  6. Bankers who have funded the loan or lending relationship with company.
  7. Investors and board of directors of the company.
  8. Representative from MFIN or Sa-Dhan identified by senior management of the company.

The Regional Manager (RM) of the company is responsible for safe keeping of documents in the region and gives limited accessibility to the above mentioned representatives with necessary approval and instruction.

Documents of closed loan, non active loans, and rejected loans are kept separately and after expiry of stipulated time are destroyed completely.

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