Why should you read this document?
During the course of dealing with us, we will ask you to provide us with detailed personal information relating to your existing agreement types, your previous address history and details of your Date of Birth. (Your Personal Data). This document is important as it allows us to explain to you what we will need to do with Your Personal Data, and the various rights you have in relation to Your Personal Data.
What do we mean by “Your Personal Data”?
Your Personal Data means any information that describes or relates to your personal circumstances. Your Personal Data may identify you directly, for example your name, address, date or birth. Your Personal Data may also identify you indirectly, for example, your employment situation.
In the context of providing you with assistance in relation to your claim Your Personal Data may include:
- Title, names, date of birth, gender, nationality, civil/marital status, contact details, addresses and documents that are necessary to verify your identity
- Employment details, employment history
- Bank account details, loans and credit agreement details, personal credit history,
The basis upon which our Firm will deal with Your Personal Data
When we speak with you about your Claim we do so on the basis that both parties are entering a contract for the supply of services.
In order to perform that contract, and to arrange the service you require, we have the right to use Your Personal Data for the purposes detailed below.
Alternatively, either in the course of initial discussions with you or when the contract between us has come to an end for whatever reason, we have the right to use Your Personal Data provided it is in our legitimate business interest to do so and your rights are not affected. For example, we may need to respond to requests from our regulator regarding how we processed your claim, or to make contact with you to seek feedback on the service you received.
In conjunction with requests from our regulator, we will use Your Personal data for contractual responsibilities we may owe our regulator Ministry of Justice, or for wider compliance with any legal or regulatory obligation to which we might be subject. In such circumstances, we would be processing Your Personal Data in order to meet a legal, compliance or other regulatory obligation to which we are subject.
How do we collect Your Personal Data?
We will collect and record Your Personal Data from a variety of sources, 3rd party data providers and lead generators who we have carried out Due Diligence on, and who have provided us with information regarding how they collected your data. Further information in relation to your claim may result in you providing information to us verbally and any missing information in writing, including email.
We may also obtain some information from third parties.
What happens to Your Personal Data when it is disclosed to us?
In the course of handling Your Personal Data, we will:
- Record and store Your Personal Data in our 3rd party software provider Leap, and on our computer systems (websites, email, hard drives, and cloud facilities). This information can only be accessed by employees and managers within our Firm and only when it is necessary to provide our service to you and to perform any administration tasks associated with or incidental to that service
- Submit Your Personal Data to the CICA, your GP, Hospital, lender/bank/other institutes that may have mis-sold PPI/PBA, 3rd parties to progress the case such as FOS/FSCS, both in paper form and on-line via a secure portal. The provision of this information to a third party is essential in allowing us to progress your claim and to deal with any additional questions or administrative issues that your opponent may raise.
- Use Your Personal Data for the purposes of responding to any queries you may have in relation to your claim or to inform you of any developments in relation to those claims which we might become aware.
Sharing Your Personal Data
From time to time Your Personal Data will be shared with:
- The CICA, MOJ, The Financial Ombudsman Service/Financial Services Compensation Scheme / Lenders or any 3rd parties involved in the process for reclaiming your mis-sold PPI/PBA. Third parties who we believe will be able to assist us with your application.
In each case, your Personal Data will only be shared for the purposes set out in this customer privacy notice, i.e. to progress your mis-sold PPI/PBA case.
Please note that this sharing of Your Personal Data does not entitle such third parties to send you marketing or promotional messages: it is shared to ensure we can adequately fulfil our responsibilities to you, and as otherwise set out in this Customer Privacy Notice.
We do not envisage that the performance by us of our service will involve Your Personal Data being transferred outside of the European Economic Area.
Security and retention of Your Personal Data
Your privacy is important to us and we will keep Your Personal Data secure in accordance with our legal responsibilities. We will take reasonable steps to safeguard Your Personal Data against it being accessed unlawfully or maliciously by a third party.
We also expect you to take reasonable steps to safeguard your own privacy when transferring information to us, such as not sending confidential information over unprotected email, ensuring email attachments are password protected or encrypted and only using secure methods of postage when original documentation is being sent to us.
Your Personal Data will be retained by us either electronically or in paper format for a minimum of six years, or in instances whereby we have legal right to such information we will retain records indefinitely.
Your rights in relation to Your Personal Data
- request copies of Your Personal Data that is under our control
- ask us to further explain how we use Your Personal Data
- ask us to correct, delete or require us to restrict or stop using Your Personal Data (details as to the extent to which we can do this will be provided at the time of any such request)
- ask us to send an electronic copy of Your Personal Data to another organisation should you wish
- change the basis of any consent you may have provided to enable us to market to you in the future (including withdrawing any consent in its entirety)
How to make contact with our Firm in relation to the use of Your Personal Data
If you have any questions or comments about this document, or wish to make contact in order to exercise any of your rights set out within it please contact:
0161 711 1299
If we feel we have a legal right not to deal with your request, or to action it in different way to how you have requested, we will inform you of this at the time.
You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.
If you have any concerns or complaints as to how we have handled Your Personal Data you may lodge a complaint with the UK’s data protection regulator, the ICO, who can be contacted through their website at https://ico.org.uk/global/contact-us/ or by writing to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.