HOW WE USE YOUR DATA
We will use your personal data fairly and lawfully and in accordance with the Data Protection Act 1998 (“the Act”). For the purposes of the Act, we The C and L Group of Companies Ltd T/A C and L Collections
PERSONAL DATA WE MAY COLLECT AND USE
Where We Get Your Personal Data From: You may share personal data about yourself and your circumstances with us through use of our website or within phone calls, emails or otherwise. We may also receive personal data about you from third parties such as from companies that we have purchased your account from, other companies which are our group companies and credit reference agencies.
What Categories of Personal Data Do We Collect? The personal data that we collect ourselves and receive from third parties may include the following: your name, address, e-mail address, phone number, debt information, payment history, credit reference information, and any other details relating to your account.
Also, each time you visit our website we may automatically collect information and personal data about your computer for system administration, including where available your IP address, operating system and browser type. We use a third party service, Google Analytics, to collect your reference number, other non-personally identifiable information that you enter and details of your behaviour patterns, including the tracking of visits across multiple devices. Google’s remarketing and advertising reporting has been enabled to provide additional information for the analysis of visitor characteristics and behaviour.
We do this to help us analyse how users use the site (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account. We do not allow Google to make any attempt to establish the identities of any users of our website.
We collect limited sensitive personal data as required by the Financial Conduct Authority (“FCA”) and we have set out more detail on this in the section headed “Sensitive Personal Data”.
Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.
USES MADE OF YOUR PERSONAL DATA
We may use personal data held about you in the following ways:
•for our debt collection purposes and those of our group companies including to manage your account, to tailor payment plans to your individual circumstances, to carry out our obligations arising from purchasing your account, to locate you and to check/update your contact details;
•to carry out account analysis for ourselves and our group companies such as to determine whether you are likely to pay your debts;
•to provide services to our clients in relation to debt collection (including to manage your account and to tailor payment plans to your individual circumstances), analysing your account (such as to determine whether you are likely to pay your debts, assessing affordability and to enable our client to make financial decisions), your payment history, account usage, check/update your contact details and to locate you;
•to administer our website;
•to improve our website to ensure that content is presented in the most effective manner;
•to allow you to participate in interactive features of our service, when you choose to do so; and
•to prevent money laundering and fraud.
Please note that as a user of our website, you are responsible for keeping any passwords used to access your personal account information confidential.
If you require further information about the purposes for which we use your personal data then please contact our office:
By letter: The C and L Group of Companies LTD 1000 Great West Rd Brentford TW8 9HH
BASIS FOR USING YOUR PERSONAL DATA
Our use of your personal data for the purposes set out above is for the legitimate interests of our business. As indicated above we may also pass your personal data to group companies and third parties, and this is also for our legitimate business interests.
HOW LONG WILL YOUR PERSONAL DATA BE KEPT BY US?
We will retain your personal data for 12 months from the closure of your last account with us or longer to satisfy any legal obligations.
DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
We may share your personal data with group companies as set out above as under the heading “Uses Made Of Your Personal Data”.
We may also share your personal data with certain third parties as follows:
•We may share your personal data with third parties who are our clients as set out above under the heading “Uses Made Of Your Personal Data”;
•We may subcontract some of our services to sub-contractors and we may share your personal data with our sub-contractors as data processors; and
•We may share your personal data with our suppliers who provide goods and services to us to enable them to provide these to us. These suppliers are our data processors and may only use your personal data in the way we specify.
SENSITIVE PERSONAL DATA
The Act defines certain personal data as ‘sensitive’ such as personal data regarding your ethnic origin, physical health and mental health.
We are required by the FCA to understand whether the people that we deal with could be regarded as vulnerable and this may involve collecting and using sensitive personal data. We may, for debt collection purposes, therefore ask you for some sensitive details or you may voluntarily give such personal data to us. We will only use this personal data for debt collection purposes and we will obtain your consent to processing this data. We may share any of your sensitive personal data with other members of the Group for debt collection purposes only. Any sharing of your sensitive personal data with clients will be on the basis of your consent or if we are required or permitted to do so under the Data Protection Act 1998.
CREDIT REFERENCE AGENCIES
Credit Reference Agencies (“CRAs”) hold personal data about consumers. Most of the personal data held by the CRAs relates to how you have maintained your credit accounts. They also hold address details and personal data from public sources such as the electoral roll, public records including county court judgments, and bankruptcy and insolvency data. We may obtain personal data about you from the CRAs for debt collection purposes and to check your credit history, verify your identity (or someone linked with you), to locate you and to prevent fraud protection and money laundering.
If you fall behind with your payments and a full payment or satisfactory payment plan are not made, then a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on your credit file for 6 years. Other organisations may see these defaults and any searches done on your file, and these may affect your ability to borrow from other lenders further details can be found at https://www.callcredit.co.uk/crain
WHERE WE PROCESS YOUR PERSONAL DATA
The data that we collect from you will only be transferred to or stored outside of the European Economic Area (EEA)where we are satisfied there is adequate controls and safeguards
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website.
RECORDED PHONE CALLS
We may monitor and/or record phone calls between our staff and you in order to offer you and our staff additional security, resolve complaints, for training purposes and to improve our quality and service standards.
Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.
We reserve the right to amend this policy from time to time and if we do we will bring the new terms to your attention when you visit the website.
COMPLAINTS AND ACCESS TO PERSONAL DATA
The Act gives you the right to access personal data held about you. If you would like to access this personal data, are unhappy with how we use your personal data then please contact us by letter at The C and L Group 1000 Great West Rd Brentford TW8 9HH
If you are not satisfied with our resolution of your concern then please contact the Information Commissioner’s Office on 0303 123 1113.