By registering on this site, you consent to the collection, use and transfer of your information under the terms of this policy.
Our Privacy Promise
- To keep your data safe and private
- Not to sell your data
- To give you ways to manage and review your marketing choices at any time.
WHAT PERSONAL INFORMATION WE COLLECT
The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or where we’re required to collect the information to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.
This will likely include the collection of:
- your personal details (e.g. name, date of birth)
- address details
- contact details (e.g. phone number, email)
- special personal information* (e.g. health information)
- financial information (e.g. details of your income and expenditure)
- employment information
- information about your creditors
- information on how you use our website(s) and products and services
Special personal information*
Data protection law defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you and obtain a better understanding of your financial situation. For example, a period of ill health could have caused you to fall behind with your regular payments to your creditors.
Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.
Information about other people:
If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person, your personal information and any information about the service provided to you will be shared with the other person.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may obtain personal information from you in a number of ways:
- When you make an application or enquiry to us either by email, phone, via our website, by a third party or by any other means
- By adding reviews or interacting with us using social media such as Twitter or Facebook etc • When we may need to obtain up to date information about you to meet our legal or regulatory obligations
- Information received from a third party, for example a creditor providing information about an account you hold with them, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company
- When you participate in market research
- Where you have given permission for your information to be provided to us
HOW WE USE YOUR PERSONAL INFORMATION
We can only use your personal information where it falls into one or more of the following categories:
- It is necessary to enter into or fulfil a contract we have with you
- You have provided your consent
- We have a legal or regulatory obligation to do so
- It is necessary to carry out a task that is in the public interest
- It is necessary to protect your vital interests or
- It is in our legitimate interest to do so and it is not against your rights
Where you make an application or enquiry for one of our products or services, we’ll use your information to provide you with appropriate information to recommend a suitable debt solution. If you cannot provide this information, we may not be able to progress with your application or enquiry.
We may also use this information to contact you about and process your application, for example, sending you an email, text message or letter to welcome you to our services.
We will process the personal data we collect about you for the purposes set out below at Purposes for Processing your Personal Data.
After you have made you initial application/enquiry, if you also decide to go ahead with any of the products or services that we offer, the sections below explain how we will also process your data when we provide that particular product(s) or service(s).
Where we give you advice we will process your personal information to administer the service we provide. This may include contacting you where we may need further information or sending you updates on the progress of the service we provide to you.
The information below specifically explains how and why your personal data will be used so that the service can be provided to you. When providing you with debt advice we collect and use your personal information under the lawful basis of our legitimate interest and is necessary to enable us to provide you with the best advice possible.
WHAT PERSONAL DATA WILL WE NEED TO COLLECT:
To be able to provide you with advice regarding insolvency solutions we need to collect certain categories of personal data. This will include:
- Contact details – Your full name, address, contact number, e-mail address etc. This is so we can contact you about and process your enquiry
- Personal and financial details – Your date of birth, gender, any previous names that you were known by, your living arrangements, employment details, details of any dependants, details of any assets you hold and your payment information. We need this so that we can decide whether an IVA is appropriate for you and so that we can draft and send a proposal to your creditors. Once you enter into an IVA, we need this information to ensure that we can collect payments and take any changes in circumstances into consideration when administering the IVA.
- The people you owe money to and your property and assets – creditor details (including the names of your creditors, reference numbers and balances). This is so we fully understand your financial situation and give you personalised advice that’s tailored to you
- Your Income and expenditure – – Details of your financial position including all sources of income and your household expenditure. This is so we can accurately work out what you can afford to pay towards your debts and make sure the solution we recommend is the right one for you
- Call Recordings, Chat Logs and E-mails: When you contact us by telephone, your call may be recorded for training and monitoring purposes. We also keep any e-mail correspondence and online chat logs to help us to manage your IVA.
- Special personal information – only with your permission and where this is relevant to your financial situation and how a debt solution needs to work for you, or where we have a legal right to do so. With your permission, we may use information from your credit file to confirm certain information, including about your lenders, balances, account numbers, your account, address and insolvency history and details of any county court judgments (CCJ). We will also use this information to confirm your identity and to comply with anti-money laundering legislation.
WHO WILL THE DATA BE SHARED WITH?
We may share your information with our Debt Solution Providers/partners these include Phoenix Insolvency Practitioners Limited, Fortis Insolvency limited, Money Plus and GW Financial Solutions. We will only share your information with them if they’ve agreed to keep it confidential.
In addition, you information may be shared with:
- Your Creditors and their Representatives: Your personal data will be shared with your creditors, their agents, debt collectors, bailiffs and solicitors dealing with the debts. This is key to allow us to provide the service we have agreed to provide you and also ensures that we comply with our regulatory obligations.
- Our regulators, The Financial Conduct Authority (FCA), the Information Commissioner’s Office (ICO) or any other regulatory body or authority may request certain information as part of supervising us. We have a legal or regulatory obligation to provide this.
- If you have provided your authority, if we have a legitimate interest to do so or where we may be legally entitled to, we will share information with credit reference agencies (CRAs) to obtain information about your financial history or your credit commitments. For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – TransUnion (formerly Callcredit); Equifax; and Experian.
- Solicitors: We may from time to time need to instruct solicitors to assist with the administration of your IVA or to assist us with legal, regulatory and contractual obligations.
- IT Providers: We use third-party software companies to help manage your data. These include, The insolvency Link, a case management system, Secured Trading, a payment processor, Telephony companies, so we can communicate with you, external printing company who print correspondence that we send to you.
These companies help us to provide our service to you. We have contracts in place with all providers to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.
HOW LONG WILL YOUR DATA BE STORED FOR?
If you continue to be our customer and we give you advice, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your data to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.
If you do not go ahead with any product or service offered by us, your personal information will normally be deleted after 2 years (except for any recorded telephone calls) unless we have another reason to keep your personal information, for example, if you have given your consent to receive marketing or promotional messages from us.
After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.
OTHER PURPOSES FOR PROCESSING YOUR PERSONAL DATA
Websites and marketing
To help us understand you better and provide you with information about other products which may be suitable and relevant, we will use your personal information to create a profile of you and your circumstances. This allows us to provide more relevant, accurate and tailored services to you. For example, we may assess your income and expenditure to determine whether you would be eligible for a debt solution through us. We believe we have a legitimate interest to do this and that it is not against your rights.
However, if you don’t want us to profile your personal information this way, to then better enable us to tailor any marketing communications to you, you can contact us to let us know that you wish for your personal data not to be used in this way.
Reviews and Market Research
Where we have a copy of your personal information we may contact you to ask you to provide a review about the services you’ve received or where we are carrying out market research which may help us design future products and services or to help improve our current services. Although this information would really help us, you wouldn’t be required to provide us with this information unless you were happy to. We consider that this is in our legitimate interests to contact you in this way for market research purposes.
Legal or Regulatory Obligation
We are required to process your personal information where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering or our regulatory obligations.
Responding to complaints or enquiries
If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.
As part of our legitimate interest to develop our business and our products we will use your personal information to assess our performance as a business and for statistical analysis. We will use your personal information to assess our performance as a business and for statistical analysis. We will use as little personal data as we can to achieve this.
WHO DO WE SHARE YOUR INFORMATION WITH?
We may also share your personal information with the following organisations:
- IT Service Providers who provide IT platforms or other IT services • Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account
- Payment Service companies that process transactions for us (e.g. Direct Debits and card transactions)
- Communication providers (e.g. telephone line providers, and email and text service providers.
- This Party administrators who provide ongoing support with the administration of your plan • Third parties who may have introduced you to our services
We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.
Fraud Prevention and Law Enforcement Agencies
The personal information we have collected from you may be shared with law enforcement agencies and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information is used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us.
We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms you should be aware that:
- The social media web pages are publicly available and you must not provide any personal or sensitive information on our pages that are accessible to the public, such as your account information. We may ask you for your account information via a private message to identify you and to service any request you make; and
Sharing your information outside of the EEA
We will only share your personal information outside the European Economic Area (EEA), where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the EEA.
If we do share your information outside of the EEA we will make sure that it is protected in the same way as if it was being used in the EEA to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as the EEA (this may include defined model clauses), or only share the data to a business partner in a non-EEA country where the privacy laws provide the same protection as within the EEA or where they are part of a Privacy Shield.
More information on this can be found on the European Commission Justice Website.
We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:
- Company security policies and standards
- Staff security awareness Role-based and biometric access controls to prevent unauthorised access to the information
- Encryption and anonymisation technology
- Anti-malware technologies
- Security monitoring
- Security testing
- Secure archiving and deletion
- Compliance with industry regulation and legislation
HOW WE MAY CONTACT YOU ABOUT THE PRODUCTS AND SERVICES WE PROVIDE TO YOU
To help us keep you up to date about the products and services that we provide to you, and to ensure that you’re kept fully informed, we may contact you by letter, telephone, email, text message, push notifications, social media or may send you messages by any online customer platforms or other electronic means.
If you start an application for a product or service through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason.
If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing a service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.
It is important that you keep us up to date when you change your contact details to ensure that we use your up to date contact information.
We record any telephone calls you make to us or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes.
We may keep a copy of the telephone calls for up to 6 years from the date the telephone call was made.
Access to your personal information
You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as set out below. We won’t charge you to provide you with this information.
Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it were you have given your agreement.
Right to have your personal information corrected
If the personal information we hold about you is incorrect you have the right to request that we correct this.
Right to stop or limit the processing of the data we carry out
You may request that your personal information is deleted or that we stop processing the information if we’re no longer entitled to process it. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations. We will however discuss this with you if you request for your information to be deleted.
In some cases you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically by you or the other company. If you want to request this you’ll need to contact us.
If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer.
When using this website, some information may be collected automatically using ‘cookies’. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used. Cookies can be temporary or permanent.
Temporary cookies form part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.
What are cookies?
Cookies are small text files that are placed in your computer or mobile device when you visit a website. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used.
There are two types of cookies, in regard to its lifespan:
- Temporary Cookies: these cookies form part of the security process and expire when you close your web browser
- Permanent Cookies: these cookies stay in your device for a longer period of time or until you manually delete them
In regard to the Entity that sets the cookies, there are two types of cookies:
- First-party Cookies: these are cookies set by the website that you are visiting, either by us or by a third-party at our request
- Third-party Cookies: these are cookies set by a third-party rather than the provider of the website that you are visiting
Why are cookies used?
They help visitors. Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off – this won’t stop a website from working, but it might mean it won’t work as well as it could, or that you have to do the same thing more than once.
They help website owners. Cookies tell website owners things like, what search engine a visitor used to find the website, how often they’ve visited it, how long they’ve spent on it, and so on. Except for essential cookies, all cookies will expire after 10 years.
You have the ability to accept or decline cookies by modifying the settings on your browser. Please remember though that disabling certain cookies may affect the functionality of our website.
Further information on the use of and managing cookies can be found at https://allaboutcookies.org