PRIVACY POLICY

INTRODUCTION

Ethical Debt Resolution Limited (“we” or “us” or “our”) are committed to protecting your personal data and privacy. This privacy policy relates to our use of any personal data we collect from you, either directly through the website, email, telephone, or indirectly via DVLA (Driver Vehicle Licencing Agency).

Whenever we access such information, we are legally obliged to use your information in line with all applicable laws concerning the protection of personal data; including the Data Protection Act 1998 (DPA) and The General Data Protection Regulation 2016 (GDPR) together and with other subsequent laws “Data Protection Laws”.

DATA PROTECTION PRINCIPLES

We comply with UK Data Protection Law which states that any personal information we hold about you must be:

• Kept securely.
• Kept only as long as necessary for the purposes we have told you about.
• Used lawfully, fairly and in a transparent manner.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Collected only for valid purposes and not used in any way that is incompatible with those purposes.
• Accurate and kept up to date.

WHERE YOUR PERSONAL DATA IS COLLECTED

Your data may have been collected from the following sources:

• Our client, the creditor, chose to engage us for the recovery services we offer. This may contain Driver and Vehicle Licensing Agency (DVLA) data obtained by our client.
• Third parties such as credit reference and tracing agencies and other third parties (where necessary)
• You when you provide such information when contacting us by, including but limited to, post, phone, e-mail, when you use our automated payment website, telephone payment lines and through discussions with our employees. This information may include bank account number or number, payment card details and a delivery address.
• The information you provide to enable us to assess your ability to make payments or the special category information you provide if you claim to be vulnerable person.
• Your use of our websites or web chat.
• Video recordings that may evidence a visit by one of our enforcement agents or a visit by you to one of our offices and through voice recordings made during any telephone calls you make to us.

YOUR RIGHTS

Under GDPR, you may request to:

• be informed: we must make available this privacy notice with the emphasis on transparency over how we process your data.
• access: you are entitled to find out what details we may hold about you and why.
• rectification: we are obliged to correct or update your details.
• erasure: this is also known as the right to be forgotten.
• restrict processing: you have the right to block or suppress the processing by us of your personal data.
• data portability: you have the right to obtain and reuse the personal data that you have provided us.
• object: you have the right to object to us processing your data in relation to direct marketing and or profiling.
• rights in relation to automated decision making and profiling: we do not use any automatic decision making or processing.

HOW YOUR DATA WILL BE USED

All personal data that we receive is processed in accordance with this privacy Notice.

We may process the personal information relating to you which we receive from clients and other sources from one or more of the following reasons, as appropriate:

• To enable us to recover debts owed by the debtors of the client including, for certain types of debts, undertaking enforcement activity using the process contained in Schedule 12 to the Tribunals, Courts and enforcement Act 2007, processing of private parking charge appeals on clients behalf, recovery of unpaid council tax from a debtor’s wages in accordance with an attachment of earnings process, the instructions of insolvency solicitors, the service of arrest warrants and High Court Enforcement Officers and the inspection of commercial properties, as appropriate. Where necessary, we may also disclose personal data to third party tracing agencies to assist it in locating debtors and may receive further personal data from such agencies and from the debtors themselves.
• To process contact details provided (address, email and phone) to enable you to have access to your payment account and to verify or contact you on matters relating to this account.
• To keep a record of correspondence and agreements made with the debtor, including payment plans that reflect your individual circumstances.
• To process and keep a record of all payments made by the debtor.
• To process the personal data, we collect from the use of Body Worn Video cameras and the recording of telephone calls with debtors to:
• Ensure compliance with applicable laws and be able to respond adequately and fairly if   complaints are made against such process.
• Monitor the performance of its employees and agents.

THIRD PARTIES

• We keep information within the ‘organisation’ except where disclosure is required or permitted by law, or when we use third-party service providers (data processors) to supply and support our services. We have contracts in place with our data processors, this means they cannot do anything with your personal data unless we have instructed them to do so. They will hold it securely and retain it for the period we instruct.
• We share and or receive data from the following third-party data providers: IPC and DVLA and this data may be shared for auditing purposes.
• If you need further information regarding our General Data Protection Policy. please send an email to admin@edrltd.co.uk or by post to Unit 111, 45 Gold Street, Northampton, Northamptonshire, NN1 1RA

OTHER ORGANISATIONS

DVLA
Swansea
SA99 1BA

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

The IPC
Waterside House
Macclesfield
SK10 9NR

Postworks Limited, Unit 2
94A Wycliffe Road, Northampton, NN1 5JF