If you have any questions about how we may use your personal information you can contact the Data Protection Officer DPO@totaldebtrelief.co.uk
This will likely include:
- 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
- employment information
- 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 orientation, 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, a joint Debt Management Plan), your personal information and any information about the service provided to you will be shared with the other person.
- When you make an application or enquiry to us either by phone, email, our website, or by any other means
- 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
- By adding reviews or interacting with us using social media such as Twitter or Facebook etc
- When you use online platforms, such as an online portal
- When we may need to obtain up to date information about you to meet our legal or regulatory obligations
- Where you have given permission for your information to be provided to us
- 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 which 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 our product or services we’ll use your information to provide you with appropriate information about any solutions that may be on offer to you. If you cannot provide this information we will not be able to progress with your application or enquiry.
We will also use this information to contact you about the progress of 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.
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 explains 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 known as a Debt Settlement Plan, 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 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 your share information with your creditors to enable us to set up and administer a Debt Settlement Plan.
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. We may also share this analysis with third parties who provide us with services and where we have a contractual obligation to do so.
- IT Service Providers who provide IT platforms or other IT services
- Payment Service companies that process transactions for us (e.g. Direct Debits)
- Communication providers (e.g. telephone line providers, and email and text service providers)
These companies help us to provide our services to you. We will have a contract in place with any provider who directly provides us with such direct services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.
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.
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.
- Company security policies and standards
- staff security awareness
- role based access controls to prevent unauthorised access to the information
- encryption and anonymisation technology
- anti-malware technologoies
- security monitoring
- security testing
- secure archiving and deletion
- compliance with industry regulation and legislation
Right of Access
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.
Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we will ask for proof of identity to enable us to locate the information and ensure that we’re only providing it were you have given your agreement.
Right to Rectification
If the personal information we hold about you is incorrect you have the right to request that we correct this.
Right to Erasure (right to be forgotten)
You can 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.
Right to Restriction of Processing
You have the right to request the restriction or suppression of their personal data.
This is not an absolute right and only applies in certain circumstances.
When processing is restricted, we are permitted to store the personal data, but not use it.
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 do not go ahead with any product or service offered by Total Debt Relief your personal information will normally be deleted after 2 years.
We do not have any control over the advertisements you see on other third party websites however you can request to opt out or customise these advertisements by using the Google Ads Preference Manager.
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 7 years from the date the telephone call was made.
Total Debt Relief Ltd
3rd Floor Broadstone House
If you are not happy with how we process your personal information you should contact us in the first instance. If you’re not happy with how we have dealt with your complaint you have the right to lodge a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/
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- Click on the ‘Search’ button on the tool bar
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