TRACE DEBT RECOVERY LTD (10079126) is a company registered in England and Wales whose registered office is at Suite S2, Barratt House, Kingsthorpe Road, Northampton, England, NN2 6HT.
We operate under the General Data Protection Regulations which came into effect in law on 25th May 2018 along with a new Data Protection Act (collectively referred to below as the DPA).
What we do
We assist commercial clients recover outstanding debts that are owed to them.
Information regarding consumers who owe debts are shared with us by our client. This will include the name, address, back-ground on the issue and amount of the debt that is owed.
Your personal data is being obtained, retained and processed for debt recovery to be achieved.
The Legal Position
This privacy notice includes the following information to help you understand clearly how your data is being used:
- The lawful basis for processing your data
- Categories of data processed
- What we do with your personal data.
Your rights under the DPA are as follows:
- The right to be informed
- The right of access
- The right to rectification
- The right to erasure
- The right to restrict processing
- The right to data portability
- The right to object
- Rights in relation to automated decision making and profiling.
Please note that you have the right to request the above, however, when we receive your requests we may object to your request if we do not agree with it. However, if you do make the request we will tell you if the request has been granted or not.
Right of Access:
You have the right to submit a Subject Access Request and this can be done by contacting our Data Protection Officer (DPO). We will need to obtain proof of your identity before providing you with information we hold about you. You can make a request by; emailing email@example.com, or by writing to Data Protection Officer, Trace Debt Recovery UK Limited, PO Box 1448, Northampton, NN2 1DW.
In order to provide you with a copy of the data we hold we will need to verify that you are the data subject and will ask you for proof of identity (passport, photo driving licence, national identity card or birth certificate) and we will ask for proof of address (utility bill, bank statement, credit card statement (no more than 3 months old), current driving licence, current TV licence; local authority tax bill or HMRC tax document (no more than 1 year old)).
If you require more information about items raised in this notice we would recommend the ICO website, www.ico.org.uk.
Our Lawful Justification for Processing Your Personal Data
- The processing is necessary for a contract which has been entered into between our client and you and because it is necessary for the legitimate interests of our client to recover the outstanding debt.
- We are provided your information by our client in order to settle the contract between you and our client.
- On behalf of our client, we are entitled to pursue an individual for an unpaid debt. We do so as we provide extensive resources and legal knowledge on recovery of outstanding debts that are due to be paid.
The Single Category “Personal Data” we Process:
- Unpaid Debt:
As you have a contract with our client, we are provided your details to recover that debt and do so by using that information. We hold your data in order to assist them with that process and are classed as the “Processor” under GDPR. We ensure that we comply with the “Controller’s” requirements of holding your data. Upon payment of your debt, we will delete the data and return it to our client.
Collecting Your Personal Data
We receive personal data relating to unpaid debts from the following sources:
- From our clients who have employed us to recover unpaid debts, owed to them by their customers.
- From credit reference agencies and address tracing services.
- We may collect data from you when you contact us by letter, email, telephone or through our online contact portal. Or from anyone you authorise to contact us on your behalf.
Types of personal data: The personal data we aquire, retain and process form the sources stated above may include any of the following: your name and address, vehicle registration number, phone number, email address, details of the debt and the contract between you and our client, photographic evidence (in the case of a parking charge), your statements from any communications with us.
Sensitive personal data: When communicating with us you may voluntarily disclose sensitive data about yourself. We will only use this data for debt collection purposes and only share this data internally with authorised staff or with our client if they need to be aware of this information for the purpose of debt collection.
Sharing Your Personal Data
We may share your personal data with the following bodies:
- Credit refence agencies to verify your contact details to ensure you receive our communications.
- Printing and mailing service providers in order to send you letters.
- Email and text messaging providers in order to contact you through electronic means.
- Secure payment providers for processing card transactions through our electronic payment services.
- Your data may also be returned to our client and we will inform our client on any communications that you have with us and our views and advice.
- Where the debt remains unpaid your data may be passed to a solicitor for legal action through the court or to answer any legal questions.
- Any other authorised sub-contractors.
We hold your data securely and we will not transfer your personal data out of the EU.
Storing Your Personal Data Securely
We will not hold your information for longer than is necessary for the purposes outlined in this privacy notice. We may hold your data for up to 6 years in order to protect our position in the event of any legal disputes. This may be extended if disputes are ongoing.
All information that you provide to us is stored on secure servers. In addition, we seek to protect the privacy of your information at all times when you visit our website. If you choose to send personal information to us (for example by contacting us online) the information you supply will be transmitted and processed in a secure manner.
Your personal information will not be communicated to non-connected third parties (i.e. marketing or advertising companies), except where there is a direct link from this site to an external website and you choose to supply your information independently on those sites. Please read the privacy notice and terms and conditions of any external sites you may be directed to from this site.
Remain vigilant when using your personal details on the internet.
Web Privacy and Cookies
We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in line with this policy.
What we collect
We may collect the following information via this website:
- Any personal details you type in and submit, such as name, address, email address, etc.
- Your IP address (this is your computer’s individual identification number) which is automatically logged by our web server. This is used to note your interest in our web site.
- Your preferences and use of email updates, recorded by emails we send you (if you select to receive email updates on products and offers).
- Session information stored in cookies, these do not include any personal information and are used to ensure the correct data is extracted from the database when using our interactive systems.
- Under no circumstances will we hold sensitive payment details such as your card number, expiry date and security code.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website. Further information can be found by viewing our Cookies Policy.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question
Changes to Our Privacy Notice
The ICO have advised that standard forms can make it easier both for organisations to recognise a subject access request and for individuals to include all the details we might need to locate the information you want. We therefore recommend you use our standard form available here, however you do not have to use this form, as long as the request is clear and we are able to verify your identity from the information you have provided.
If you have any queries relating to your data, please contact us by e-mail at: firstname.lastname@example.org, or write to “Data Protection Officer, Trace Debt Recovery UK Limited, PO Box 1448, Northampton, NN2 1DW” or call 01604 968 123.