Debtors

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Debtor Summary We keep to a minimum the information we hold about you We use your data to search for and take control of goods, execute writs, warrants of control, liability orders, forfeiture notices, other debts and to carry out evictions or repossessions. We delete your personal data when it is no longer needed for these reasons We will only share data where disclosure is required or permitted by law or when we use third party service providers to supply and support our services. We do not trade your personal data. You have privacy rights We do not process your data outside of the European Economic Area (EEA) From time to time we may be processing your data on behalf of another controller We are happy to answer questions – contact us We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. Information we hold about you We only process personal data that is necessary, relevant, adequate and lawful. We may hold the following information about you (but not limited to) to assist us in carrying out of one of our services, in the collection of any debt or supplying our services to you for a client: Your full names including previous Home and trade addresses Personal and work email addresses Telephone numbers (landline, mobile) Date of birth Gender Description of our interactions Social Media (handle, signature, username) National Insurance Number Occupations Employee / Employment status Financial Information (Income / benefit claims / expenditure) Marital Status Housing Status Sensitive Data - Special category data (Health, Vulnerability) Vehicle Registration Number (VRN) Information about your business activities Information and documents about your matter or enquiries, including communications with you Billing and payment information Video imagery – Body Worn Video (BWV) cameras maybe worn by Enforcement Agents’. This may collect personal and special category data. Using your data References to the basis of processing are a reference to the article of the General Data Protection Regulation under which we undertake the processing in question. We use personal data that is given to us by you or anybody else such as your creditor, the court, local authority, landlord, land owners, enforcement agency, key worker, debt advice charities and others. Live Chat enquiries are handled by Court Enforcement Solutions via a WIX application on the website. Court Enforcement Specialists will process your data: As necessary to comply with a legal obligation – Article 6(c) eg – When you exercise your rights under data protection law and make requests For compliance with legal and regulatory requirements and related disclosures For establishment and defence of legal rights For activities relating to the prevention, detection and investigation of crime To verify your identity, fraud prevention and money laundering checks To monitor emails, calls, other communications to you and activities about your case As necessary to perform a contract on behalf of your creditor and you for the relevant service – Article 6(b) eg – To manage the performance of the contract To manage mediation activities To update records To trace your whereabouts to contact you regarding your contract and recovery of a debt As necessary for our own legitimate interests or of those persons and organisations – Article 6(f) eg – To protect you and us To prevent malicious or fictitious allegations, aggression and assault eg Body Worn Video For good governance, accounting, managing and auditing our business operations To search credit reference agencies To monitor emails, calls, other communications and activities on your case Body Worn Video (BWV) data is not reviewed unless necessary to assist in identifying a data subject requesting information, to answer a complaint or it is to be provided as evidence to law enforcement following an allegation of crime. In some instances Court Enforcement Specialists will be acting as a controller of the BWV data being processed and on other occasions defined as a processor as processing on behalf of another controller (eg Enforcement Agency). Please refer to our Subject Access Request information for more detail. Based on your (explicit) consent – Article 6(a) and 9(2)(a) eg – When you request us to disclose your personal data to other people or organisations such as a debt advice charity, key worker, family member or other handling your case When we process special category data of personal data about you at your request to help us assess and make legal and duty bound decisions about your case (eg racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation) When we assess if you are vulnerable, or have the capacity to handle your own finances. You are free at anytime to change your mind and withdraw your consent, but there maybe exceptions if being processed under a legal obligation ie If you are vulnerable and we know you are vulnerable and you withdraw your consent, we have a legal obligation to make decisions based on the information provided. We use such data to make informed decisions on all of the information available to us, our instruction from our clients’ and any legal obligation. Other uses include; We use your information to handle and resolve complaints. We use your data to verify who we are speaking to. To comply with any contractual or legal obligations, including sharing data with law enforcement Click on privacy rights for more detailed information Our collection methods are: Via the courts, a creditor, landlord, landowner, enforcement agency Through engagement in person Enquiries via our office, website or agents’ By communications, including email, telephone, post or social media Through engagement of service or your advice providers Via third parties and/or publicly available resources Data Security We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractor and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. If we are processing your personal data on behalf of another, please refer to the applicable Data Controllers privacy notice for more information. If you have particular security requirements, please contact us to discuss how we can support you. Your data and the EEA We do not transfer or process data outside the European Economic Area (EEA) or where the nature of the processing requires it (for example, where we are emailing a party to your matter who is based outside the EEA, or because you have chosen to use an email or other communications service which routes data outside the EEA). Your privacy rights You have lots of privacy rights in respect of our processing of your personal data. Click on privacy rights for more detailed information You also have the right to lodge a complaint about our processing with a supervisory authority — you probably want the UK's Information Commissioner's Office Telephone: 0303 123 1113 Online: https://ico.org.uk/concerns Third parties We will share data where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We use third party service providers such as certificated enforcement agents, vehicle removal companies, security, tracing services and other organisations to help us provide services to you. These would include: Court services Protestor removal Traveler removal Forfeiture of lease Residential possessions Commercial rent arrears recovery Methods to take payment Telephony Banking Accounting Broadband Email providers Data Controllers Driving and Vehicle Licensing Agency (DVLA) Companies House Where personal data is passed to any other organisation, if we stop using their services, any of your data held by them will either be deleted or rendered anonymous. We may also pass your data to third party external organisations where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. These requests are assessed on a case by case basis and we may need to seek your consent before doing so. All of our third party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third party service providers to process your personal data for specified purposes and in accordance with our instructions. Deletion and retention periods Data about debtors: duration of your relationship with us, then seven years Data about specific matters: duration of the matter, then seven years Enquiry data: duration of enquiry, then 7 days As compulsory in the Data Controller – Data Processor contracts When assessing what retention period is appropriate for your personal data, we take into consideration: The requirements of our business and the services provided; The contractual requirements of data sharing agreements with our clients’ Any statutory or legal obligations; The purposes for which we originally collected the personal data; The lawful grounds on which we based our processing; The types of personal data we have collected; The amount and categories of your personal data; and Whether the purpose of the processing could reasonably be fulfilled by other means. Subject Access Requests We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB. If we do hold your personal data we will respond in writing without undue delay and within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will: Confirm that your data is being processed; Verify the lawfulness and the purpose of the processing; Confirm the categories of personal data being processed; Confirm the type of recipient to whom the personal data have been or will be disclosed, and Let you have a copy of the data in an intelligible form. Please note that you may need to provide identification in order to prove who you are to access your data. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.

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