At McCambridge Duffy we are committed to maintaining the trust and confidence of visitors to our website.
The aim of this policy is to provide a clear understanding of what happens to the information you send to us and how we will use that personal information in providing our advice and services to you including how we protect that information in line with new GDPR legislation.
We can only use your personal information where it falls into one or more of the following categories:
We first obtain information about you when you visit our website and contact us for advice on your debts and information on the services we offer. You can contact us either via email, an online form, online web chat or a phone call to us.
When you make an enquiry with us, we will use your personal information to contact you to discuss your financial situation and provide you with details on any solutions we might be able to offer you. During our initial advice stages, if you cannot provide additional information that is requested, we may not be able to progress with your application or enquiry.
We may use your personal information to contact you in regards to your enquiry and to process any application for a solution. We may contact you by the methods you have provided, for example via phone call, email, text message, communicating via online web chat or in writing/ by post.
After you have requested initial advice and if you decide to proceed with any of the services we offer, the sections below explain how we will process your personal data in order to provide that particular service.
Where we are providing you with an Insolvency Solution, such as an Individual Voluntary Arrangement (IVA), or any other financial services solution, we will process your personal information to administer the service. This may include contacting you for further information or providing you with updates on the progress of the service we provide to you.
Where we provide ongoing services we will normally require you to agree to the terms and conditions outlined for that solution. The terms and conditions will explain how our service works and where we will be required to utilise your personal information. For instance, if you were entering into an Insolvency solution, we may need to share your information with the creditors or collection agencies involved.
For more information on the terms and conditions of our solutions you can read the Insolvency Solutions section below.
If you enter into an Insolvency Solution with us, such as an IVA, we will need to use your personal information as follows:
If at any time you have any changes in circumstances to the information we hold on you during the term of your arrangement, you must inform us immediately.
We will need to share some of your information with external parties who are involved in your Insolvency Arrangement. These are:
These external companies help us to provide and maintain an efficient service to you. We have contracts in place with relevant providers to ensure that they comply with their own 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 are required to do so under a legal or regulatory obligation, for example where we are required to do so by a court order, the police, local authorities or the courts. We might share some of your information with the emergency services if you are in any immediate danger.
If you do not proceed with any solution, your personal information will normally be deleted after 12 months unless otherwise agreed with you. You have a right to view, amend or request deletion of the information that we hold on you sooner if you wish. You can request this in writing via email or by post.
If you enter into an Insolvency solution, we will keep your information on file to ensure that we provide you with our service and that we comply with our legal and regulatory obligations. Your information will be stored for 10 years from the date of completion of your solution or from the date when your solution is terminated and you no longer use our service. We cannot delete this data sooner if you request us to do so, because we are required to keep it by law. We will delete your data after this 10 year period.
After the 10 year time period we will delete the information or keep data in an anonymous format so that it cannot be connected back to you.
Data protection defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual life, 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.
If you provide personal information about other people, for example, a partner or a carer, you must do so with the permission of the other person. If you enter into a joint application or solution with another person, (for example if you have joint debts and you enter into interlocking IVAs) your personal information and any information about the service provided to you will be shared with the other person.
We collect your information in a number of ways
To help us understand you better and provide you with information about other services which may be suitable and relevant, we will use your personal information to create a profile of you and your circumstances. This allows us to provide more relevant, accurate and tailored services to you. For example, we may assess your income and expenditure to determine whether you would be eligible for a debt solution through us. We believe we have a legitimate interest to do this and that it is not against your rights.
However, if you don’t want us to profile your personal information this way, to then better enable us to tailor any marketing communications to you, you can contact us to let us know that you wish for your personal data not to be used in this way.
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 services or to help improve our current services. Although this information would really help us, you are not required to provide us with this information unless you are happy to. We consider that this is in our legitimate interests to contact you in this way for market research purposes.
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.
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 in accordance with our complaints procedure.
As part of our legitimate interest to develop our business and our services we will use your personal information to assess our performance as a business and for quality assurance and 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.
We may also share your personal information with the following organisations
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.
The personal information we have collected from you may be shared with law enforcement agencies and fraud prevention agencies that will use it to prevent fraud, money-laundering (such as Lexis Nexis) and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information is used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us or email our Data Protection Officer at firstname.lastname@example.org
We use publicly available social media platforms to promote our services, to provide updates and to share any news or promotional updates. We may collect personal information from these social media platforms, for example, if you post a message to our Facebook page. By providing any of your information to us through these platforms you should be aware that:
We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:
To help us keep you up to date about the services we provide to you and to ensure that you are kept fully informed we may contact you by letter, telephone, email, text, push notifications, social media or may send you messages by any online customer platforms or other electronic means.
If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing a service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.
It is important that you keep us up to date when you change your contact details to ensure that we use your up to date contact information.
Access to your personal information
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 in writing via email or by post.
Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it where you have given your agreement.
Right to have your personal information corrected
If the personal information we hold about you is incorrect you have the right to request that we correct this.
Right to stop or limit the processing of the data we carry out
You may 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.
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.
Whilst you continue to be our customer, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. The service specific information above sets out how long your personal information will normally be kept for.
If you do not go ahead with any service offered by the Group, your personal information will normally be deleted after 2 years unless we have another reason to keep your data, for example, if you have given your consent to receive marketing or promotional messages from us.
If you have provided us with your consent or where we are legally entitled to do so, we may contact you to let you know about other services that we provide which we think you may be interested or that may benefit you. We may do this through post, emails, text messages, telephone, push notifications, social media or other electronic means.
You can easily let us know at any time if you would no longer like to receive these messages. You can contact us using the details below, emailing our Data Protection Officer at email@example.com or unsubscribing using the link or information within the message.
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
We record some of the telephone calls you make to us or we make to you or any other third party. 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 6 years from the date the telephone call was made or longer if we are required to do so by our regulators.
If you do not proceed with any of the services that we offer, call recordings will normally be deleted after 12 months unless otherwise agreed with you. You have a right to request deletion sooner if you wish. You can request this in writing via email or by post.
Data Protection Officer
35 Templemore Business Park
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/
Date last updated: 29/05/2018
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© 2018 McCambridge Duffy Insolvency Practitioners.
All rights reserved
McCambridge Duffy LLP is a Limited Liability Partnership
registered in England and Wales.
Registered number 0C309544
Registered office 17 Hanover Square, Mayfair,
London, W1s 1HT