Court Enforcement Specialists Privacy Policy

Summary


Summary Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB is a Data Controller and registered with the Information Commissioners Office [ICO] under reference ZA225779. Where we act as a data processor on behalf of a data controller (for example, when executing liability orders and collecting taxation on behalf of local Government), we will signpost you to the applicable privacy policy that sets out the required information as part of that data processing agreement. We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We keep to a minimum the information we hold about you. We use your data to carry out our services, respond to your enquiries, manage our relationship with you and meet our legal obligations. We delete your data when it is no longer needed for these reasons We do not trade your data. We do not give your information to third parties without your consent, but there are exceptions. You have privacy rights We do not process your data outside of the European Economic Area (EEA). Cookies We do not use cookies on this website Do you want more detail? To read more about how Court Enforcement Specialists uses your personal data, read the notice or notices, which apply best to your relationship with us: I am a client I am a debtor I am interested in a career with Court Enforcement Specialists I want to know my privacy rights To contact Court Enforcement Specialists with a data protection or privacy query regarding the processing of your personal data, please use the contact us form. This page was last updated 2018




Client


Client We keep to a minimum the information we hold about you We use your data to carry out our services on your behalf, respond to your enquiries, manage our relationship with you and meet our legal obligations We delete your personal data when it is no longer needed for these reasons We will only share data where disclosure is required or permitted by law or when we use third party service providers to supply and support our services to you We do not trade your personal data. You have lots of privacy rights We do not process your data outside of the European Economic Area (EEA) unless necessary for the performance of a contract. We are happy to answer questions – contact us We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. Information we hold about you As our client, we will hold the following information about you: Your name, identity and contact information Information about your business activities Information and documents about your matter or enquiries, including communications with you Billing and payment information Using your data References to the basis of processing are a reference to the article of the General Data Protection Regulation under which we undertake the processing in question. Live Chat enquiries are handled by Court Enforcement Specialists via a WIX application on the website. We will collect personal data from you in relation to the provision of our services to you that are necessary, adequate and relevant to the relationship. Providing you a service We use the information we hold about you and your business — both personal and otherwise — to give you the best service we can. To notify you about changes to our service To enable us to invoice you for our services, and keep track of payments that you make If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you (Processing is necessary for the performance of a contract - Basis: Article. 6(b): this is necessary to deliver an effective service to you.) Our collection methods are: Through engagement (or potential engagement) of our services Enquiries via our office, website or agents’ By communications, including email, telephone, post or social media Networking Through engagement of service providers Via third parties and/or publicly available resources Legitimate Interest and marketing: We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes for marketing, business development, statistical and management purposes. If you are an existing client or contact, we will send you information about other products, events and services that we feel maybe of interest to you. You have the right at anytime to contact us to ask us to stop contacting you for marketing purposes. We will never sell your data to a third party. (Processing is necessary for the purposes of the legitimate interest – Basis: Article 6(f): this is necessary for the interest pursued by the controller) Data Security We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. If you have particular security requirements, please contact us to discuss how we can support you. Your data and the EEA We do not transfer or process data outside the European Economic Area (EEA) unless the nature of the processing requires it (for example, where we are emailing a party to your matter who is based outside the EEA, or because you have chosen to use an email or other communications service which routes data outside the EEA). Your privacy rights You have lots of privacy rights in respect of our processing of your personal data. Click on privacy rights for more detailed information You also have the right to lodge a complaint about our processing with a supervisory authority — you probably want the UK's Information Commissioner's Office Third parties We will share data where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We may also pass your data to third party external organisations where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. We use third party service providers such as certificated enforcement agents, vehicle removal companies, security, tracing services and other organisations to help us provide services to you. These would include: Court services Protestor removal Traveler removal Forfeiture of lease Residential possessions Commercial rent arrears recovery Methods to take payment Telephony Banking Accounting Broadband Email providers Driving and Vehicle Licensing Agency (DVLA) Companies House Where personal data is passed to any of these organisations, if we stop using their services, any of your data held by them will either be deleted or rendered anonymous. We may also pass your data to third party external organisations where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. These requests are assessed on a case by case basis and we may need to seek your consent before doing so. All of our third party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third party service providers to process your personal data for specified purposes and in accordance with our instructions. Deletion and retention periods Data about clients: duration of your relationship with us, then seven years Data about specific matters: duration of the matter, then seven years Enquiry data: duration of enquiry, then 7 days Server logs: up to one year When assessing what retention period is appropriate for your personal data, we take into consideration: The requirements of our business and the services provided; Any statutory or legal obligations; The purposes for which we originally collected the personal data; The lawful grounds on which we based our processing; The types of personal data we have collected; The amount and categories of your personal data; and Whether the purpose of the processing could reasonably be fulfilled by other means. Subject Access Requests We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB. If we do hold your personal data we will respond in writing without undue delay and within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will: Confirm that your data is being processed; Verify the lawfulness and the purpose of the processing; Confirm the categories of personal data being processed; Confirm the type of recipient to whom the personal data have been or will be disclosed, and Let you have a copy of the data in an intelligible form. Please note that you may need to provide identification in order to prove who you are to access your data. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.




Debtors


Debtor Summary We keep to a minimum the information we hold about you We use your data to search for and take control of goods, execute writs, warrants of control, liability orders, forfeiture notices, other debts and to carry out evictions or repossessions. We delete your personal data when it is no longer needed for these reasons We will only share data where disclosure is required or permitted by law or when we use third party service providers to supply and support our services. We do not trade your personal data. You have privacy rights We do not process your data outside of the European Economic Area (EEA) From time to time we may be processing your data on behalf of another controller We are happy to answer questions – contact us We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. Information we hold about you We only process personal data that is necessary, relevant, adequate and lawful. We may hold the following information about you (but not limited to) to assist us in carrying out of one of our services, in the collection of any debt or supplying our services to you for a client: Your full names including previous Home and trade addresses Personal and work email addresses Telephone numbers (landline, mobile) Date of birth Gender Description of our interactions Social Media (handle, signature, username) National Insurance Number Occupations Employee / Employment status Financial Information (Income / benefit claims / expenditure) Marital Status Housing Status Sensitive Data - Special category data (Health, Vulnerability) Vehicle Registration Number (VRN) Information about your business activities Information and documents about your matter or enquiries, including communications with you Billing and payment information Video imagery – Body Worn Video (BWV) cameras maybe worn by Enforcement Agents’. This may collect personal and special category data. Using your data References to the basis of processing are a reference to the article of the General Data Protection Regulation under which we undertake the processing in question. We use personal data that is given to us by you or anybody else such as your creditor, the court, local authority, landlord, land owners, enforcement agency, key worker, debt advice charities and others. Live Chat enquiries are handled by Court Enforcement Solutions via a WIX application on the website. Court Enforcement Specialists will process your data: As necessary to comply with a legal obligation – Article 6(c) eg – When you exercise your rights under data protection law and make requests For compliance with legal and regulatory requirements and related disclosures For establishment and defence of legal rights For activities relating to the prevention, detection and investigation of crime To verify your identity, fraud prevention and money laundering checks To monitor emails, calls, other communications to you and activities about your case As necessary to perform a contract on behalf of your creditor and you for the relevant service – Article 6(b) eg – To manage the performance of the contract To manage mediation activities To update records To trace your whereabouts to contact you regarding your contract and recovery of a debt As necessary for our own legitimate interests or of those persons and organisations – Article 6(f) eg – To protect you and us To prevent malicious or fictitious allegations, aggression and assault eg Body Worn Video For good governance, accounting, managing and auditing our business operations To search credit reference agencies To monitor emails, calls, other communications and activities on your case Body Worn Video (BWV) data is not reviewed unless necessary to assist in identifying a data subject requesting information, to answer a complaint or it is to be provided as evidence to law enforcement following an allegation of crime. In some instances Court Enforcement Specialists will be acting as a controller of the BWV data being processed and on other occasions defined as a processor as processing on behalf of another controller (eg Enforcement Agency). Please refer to our Subject Access Request information for more detail. Based on your (explicit) consent – Article 6(a) and 9(2)(a) eg – When you request us to disclose your personal data to other people or organisations such as a debt advice charity, key worker, family member or other handling your case When we process special category data of personal data about you at your request to help us assess and make legal and duty bound decisions about your case (eg racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation) When we assess if you are vulnerable, or have the capacity to handle your own finances. You are free at anytime to change your mind and withdraw your consent, but there maybe exceptions if being processed under a legal obligation ie If you are vulnerable and we know you are vulnerable and you withdraw your consent, we have a legal obligation to make decisions based on the information provided. We use such data to make informed decisions on all of the information available to us, our instruction from our clients’ and any legal obligation. Other uses include; We use your information to handle and resolve complaints. We use your data to verify who we are speaking to. To comply with any contractual or legal obligations, including sharing data with law enforcement Click on privacy rights for more detailed information Our collection methods are: Via the courts, a creditor, landlord, landowner, enforcement agency Through engagement in person Enquiries via our office, website or agents’ By communications, including email, telephone, post or social media Through engagement of service or your advice providers Via third parties and/or publicly available resources Data Security We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractor and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. If we are processing your personal data on behalf of another, please refer to the applicable Data Controllers privacy notice for more information. If you have particular security requirements, please contact us to discuss how we can support you. Your data and the EEA We do not transfer or process data outside the European Economic Area (EEA) or where the nature of the processing requires it (for example, where we are emailing a party to your matter who is based outside the EEA, or because you have chosen to use an email or other communications service which routes data outside the EEA). Your privacy rights You have lots of privacy rights in respect of our processing of your personal data. Click on privacy rights for more detailed information You also have the right to lodge a complaint about our processing with a supervisory authority — you probably want the UK's Information Commissioner's Office Telephone: 0303 123 1113 Online: https://ico.org.uk/concerns Third parties We will share data where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you. We use third party service providers such as certificated enforcement agents, vehicle removal companies, security, tracing services and other organisations to help us provide services to you. These would include: Court services Protestor removal Traveler removal Forfeiture of lease Residential possessions Commercial rent arrears recovery Methods to take payment Telephony Banking Accounting Broadband Email providers Data Controllers Driving and Vehicle Licensing Agency (DVLA) Companies House Where personal data is passed to any other organisation, if we stop using their services, any of your data held by them will either be deleted or rendered anonymous. We may also pass your data to third party external organisations where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so. These requests are assessed on a case by case basis and we may need to seek your consent before doing so. All of our third party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third party service providers to process your personal data for specified purposes and in accordance with our instructions. Deletion and retention periods Data about debtors: duration of your relationship with us, then seven years Data about specific matters: duration of the matter, then seven years Enquiry data: duration of enquiry, then 7 days As compulsory in the Data Controller – Data Processor contracts When assessing what retention period is appropriate for your personal data, we take into consideration: The requirements of our business and the services provided; The contractual requirements of data sharing agreements with our clients’ Any statutory or legal obligations; The purposes for which we originally collected the personal data; The lawful grounds on which we based our processing; The types of personal data we have collected; The amount and categories of your personal data; and Whether the purpose of the processing could reasonably be fulfilled by other means. Subject Access Requests We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB. If we do hold your personal data we will respond in writing without undue delay and within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will: Confirm that your data is being processed; Verify the lawfulness and the purpose of the processing; Confirm the categories of personal data being processed; Confirm the type of recipient to whom the personal data have been or will be disclosed, and Let you have a copy of the data in an intelligible form. Please note that you may need to provide identification in order to prove who you are to access your data. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.




Applying for a Job


Recruitment To the extent that we are processing your Curriculum Vitae (CV) based on your consent, you have the right to withdraw your consent at any time. We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. Curriculum Vitae We give you the option of submitting your CV via email or our web based contact form. You can do this either to apply for a specific advertised job or for consideration for positions as they come up. Your CV will be stored in our database, and will be accessible by management. We keep to a minimum the information we hold about you. We use your CV to assess your suitability for job vacancies, respond to your enquiries and meet our legal obligations. We delete your CV when it is no longer needed for these reasons We do not trade your data or share with other companies. You have lots of privacy rights Your data does not leave the European Economic Area (EEA) when emailed to our company We will not process your personal data outside of the EAA without your explicit consent. From time to time this may be necessary for overseas deployments. You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission). Equal Opportunities Court Enforcement Specialists Limited is an equal opportunities employer and a company committed to diversity. This means that all job applicants and members of staff will receive equal treatment and that we will not discriminate on grounds of gender, marital status, race, ethnic origin, colour, nationality, national origin, disability, sexual orientation, religion or age. Information we hold about you If you contact us we will hold the following information about you Your name, identity and contact information Information about your business activities Information and documents about your enquiries, including communications with you The information supplied in your CV Using your data References to the basis of processing are a reference to the article of the General Data Protection Regulation under which we undertake the processing in question. Dealing with your CV submission If you send us your CV via our website or by email, we will follow up your submission and let you know if we have any suitable vacancies. We will only keep successful applicant’s data. Live Chat enquiries are handled by Court Enforcement Solutions via a WIX application on the website. (You the data subject have given us consent to process your personal data for one or more specific purposes ie Apply for a job – Basis Article. 6.(a): this is necessary to assess your application and suitability) Data Security Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. Those employees will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. If you have particular security requirements, please contact us to discuss how we can support you. Your personal data and the EEA We do not transfer or process data outside the European Economic Area (EEA) unless the nature of the processing requires it (for example, where we are emailing a party to your matter who is based outside the EEA, or because you have chosen to use an email or other communications service which routes data outside the EEA). Your privacy rights You have lots of privacy rights in respect of our processing of your personal data. Click on privacy rights for more detailed information You also have the right to lodge a complaint about our processing with a supervisory authority — you probably want the UK's Information Commissioner's Office Telephone: 0303 123 1113 Online: https://ico.org.uk/concerns Third parties We do not trade your personal information and as a general principle, we will not transfer your personal data to third parties without your permission. There are three exceptions to this: It is possible, though unlikely, that we might be forced to disclose your information in response to a court order or other binding mandate. We also have a small number of companies providing services to us. Telephony services, which would get to see your phone number if we call you, and a broadband supplier which could see your email address (but not the content of what you send us, if you encrypt it) and a Live Chat application. We also use an external accountancy service but, unless you are a sole trader or a partnership, they are unlikely to see any personal data relating to you. Due to the nature of our services, clients under contract may ask to see CV’s of staff that have been chosen to work for them ie Protestor removal. (Please contact us if you wish to discuss this) Deletion and retention periods Data about successful applicants: duration of your relationship with us, then seven Years Enquiry data: duration of enquiry, then 7 days Data about unsuccessful applicants: duration of application, then 7 days Data about specific matters: duration of the matter, then seven years When assessing what retention period is appropriate for your personal data, we take into consideration: The requirements of our business and the services provided; Any statutory or legal obligations; The purposes for which we originally collected the personal data; The lawful grounds on which we based our processing; The types of personal data we have collected; The amount and categories of your personal data; and Whether the purpose of the processing could reasonably be fulfilled by other means. Subject Access Requests We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB. If we do hold your personal data we will respond in writing without undue delay and within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will: Confirm that your data is being processed; Verify the lawfulness and the purpose of the processing; Confirm the categories of personal data being processed; Confirm the type of recipient to whom the personal data have been or will be disclosed, and Let you have a copy of the data in an intelligible form. Please note that you may need to provide identification in order to prove who you are to access your data. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.




Your Privacy Rights


Your privacy rights The right to be informed – which is what this privacy notice is about The right to access the data we hold about you The right to object to direct marketing (We do not carry out direct marketing) The right to object to processing carried out on the legal basis of Legitimate Interest The right to erasure (exceptions may apply) The right to data portability The right to have your data rectified if it is inaccurate The right to have your data restricted from processing To exercise any of these rights, please contact us We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. Subject Access Requests: We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request under the GDPR is your right to request a copy of the information that we hold about you. Such requests must be in writing to Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB. If we do hold your personal data we will respond in writing without undue delay and within one calendar month of your request (where that request was submitted in accordance with this policy). The information we supply will: Confirm that your data is being processed; Verify the lawfulness and the purpose of the processing; Confirm the categories of personal data being processed; Confirm the type of recipient to whom the personal data have been or will be disclosed, and Let you have a copy of the data in an intelligible form. Please note that you may need to provide identification in order to prove who you are to access your data. "We may supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity. CRAs will share your information with other organizations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone. How to complain: If you are unhappy with how we have used your personal information please contact, the Chief Privacy Officer Court Enforcement Specialists Limited, Victoria House, Great Ancoats Street, Manchester, M4 7DB, and your complaint will be investigated.





Helpful Contacts

Money Advice Service: 0300 500 5000

Debt Advice Foundation: 0800 043 4050

CAB: 0300 330 1313

PayPlan: 0800 280 2816

National Debt Line: 0808 808 4000

Stepchange: 0800 138 1111

Helpful Links

Head Office

Phone:

0161 507 0626

Email:

info@courtenforcementspecialists.co.uk

Victoria House, Great Ancoats Street, Manchester, M4 7DB

Professional Business of the Year-02[147
New Business Start-up of the Year-02[147
ICO_logo.png
logo_3x.png
html_logo[182070].png

© 2018 by Court Enforcement Specialists

Court Enforcement Specialists Ltd operates in England and Wales.