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:
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. 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 (for example, linked Individual Voluntary Arrangements), your personal information and any information about the service provided to you will be shared with the other person.
How do we collect your personal information?
We collect your information in a number of ways.
We can only use your personal information where it falls into one or more of the following categories:
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 about any solutions we may be able to offer to you. 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 your 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 are providing you with a debt solution, such as a Debt Arrangement Scheme (DAS), Individual Voluntary Arrangement (IVA); Trust Deed, or claims management services or any other financial services solution, we will process your personal information to administer the services we provide. This may include contacting you where we may need further information or sending you updates on the progress of the services we provide to you.
Where we provide ongoing services, we will normally require you to agree to the terms and conditions of the debt solution or service. These will set out how we will provide the services to you and where we will be required, under the terms and conditions, to process your personal information. For example, we would need to share information with your creditors to enable us to set up and administer an Individual Voluntary Arrangement, Trust Deed or Debt Arrangement Scheme.
We will share your personal information with suitable debt solution providers such as Insolvency Practitioners on our panel and debt advice organisations.
We may share your personal information with regulatory bodies such as the FCA and HMRC when required to do so by law.
We may engage the services of professional advisers such as compliance consultants, lawyers and accountants who may be given access to your personal information in order to provide their services to us. We will ensure that your personal information is protected by obtaining a written undertaking of confidentiality from the professional service providers.
If you do not go ahead with any product or service with us, your personal information will normally be deleted after 12 months unless we have another reason to keep your personal information, for example, if you have given your consent to receive marketing information from us. We will delete your information sooner if you ask us to.
If you sign your proposal and a meeting of creditors is convened, which is later withdrawn, or for whatever reason does not go ahead, your data will be stored for 6 years from the date that we cease to provide you with our services.
If you become our customer by entering a debt solution, we will keep your data to ensure that we provide you with our services and comply with our legal and regulatory obligations. Your data will be stored for 6 years from the date that we cease to provide you with our services. We cannot delete this data if you ask us to because we are required to keep it by law. After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.
Websites, marketing and promotions
To help us understand you better and provide you with information about other products and promotions 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 or enrol you into a promotion the company or group is running whilst you are a client. 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 as little personal data as we can to achieve this. We may also share this analysis or personal data with third parties who provide us with services including conducting research for us and/or where we have a contractual obligation to do so.
Right to access
You have the right to request copies of the personal information we hold about you at any time.
Right to rectification
You have the right to request that we correct any inaccurate personal information we hold about you.
Right to erasure
You have the right to request that we delete your personal information from our records.
Please note that we will not be able to delete your personal information whilst we are still providing our services to you. We will be able to delete your personal information once you cancel the service or once the service is completed.
Right to restrict processing
You have the right to request that we restrict how we use your personal information.
Right to object
You have the right to object to the collection and use of your personal information at any time.
Right to data portability
You have the right to obtain a copy of your personal information in a legible and compatible format such as Excel or Word.
Why do we collect and use your personal information?
We collect and use your personal information in order to review your financial circumstances and advise you on suitable debt solutions and, where appropriate, refer you to a suitable debt solution provider.
We may use your personal information to send marketing communications to you about similar products and services that may be of interest to you. We will send our marketing communications to you by email.
It is to be noted that you can object to your personal information being used by us to send you marketing information.
Each marketing email will also include an unsubscribe link to enable you to opt-out of receiving future marketing communications.
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:
We will store your personal information for up to six years after you cease to be our client. This is to enable us to refer to our records in the unlikely event that you want to lodge a complaint against us within six years.
If you do not exercise your right to object to marketing or unsubscribe to our marketing emails, we will store your personal information for marketing purposes until you exercise your right to object or unsubscribe.
You can lodge a complaint with us directly by contacting us on the details above.
You also have the right to lodge a complaint directly with the Information Commissioner’s Office (ICO). The ICO are the regulator who makes sure that we use your personal information in a lawful way