Privacy Policy

INTRODUCTION

This privacy policy provides you with information as to how we use your personal data, we are required by law to explain this to you.  Each section of this policy provides you with different information:

      • GDR as a data processor and our contact details
      • Types of personal data we collect and how we collect it
      • The legal basis on which, and the purposes for which, we are processing your personal data
      • How long we keep your personal data for
      • Who we share your personal data with
      • Transferring your personal data outside of the EEA
      • Credit Reference Agencies
      • Sharing information to prevent crime or harm
      • How you can manage your personal data
      • Cookies
      • How to complain

Our policy will set out how your personal data will be used by Global Debt Recovery Limited as a data processor.

You can contact our Data Protection Officer in writing to 8-10 Coombe Road, New Malden, KT3 4QE or via email: info@globaldebtrecovery.com

If there is ever an occasion that we need to tell you about specific processing of your information that you have provided us with, we will send you a notice at the point we receive this information.

 


GLOBAL DEBT RECOVERY

Global Debt Recovery Limited is the processor of your personal data.  We are authorised and regulated by the Financial Conduct Authority (FCA).

For the purpose of this policy we will refer to Global Debt Recovery Limited as GDR.

 


WHAT TYPES OF PERSONAL DATA DO WE COLLECT AND HOW DO WE COLLECT IT?

The following list confirms the type of personal data we collect:

      • Personal data – information that can be used to identify you as an individual such as your name, address and contact details, IP address
      • Financial data – Information from your credit file, income and expenditure data, account information and any other information relating to your ability to repay your account

 


SPECIAL CATEGORIES OF PERSONAL DATA

Some categories of personal data are more sensitive, these are known as special categories of personal data for example:

      • Racial
      • Biometric data (physical characteristics)
      • Ethnic origin
      • Religious beliefs
      • Data concerning health, sexual orientation

If you ever disclose any of the personal data listed above to us we will only keep this on record if it is necessary for the provision of our services to you.  If we do need to record this data we will always request your explicit consent to do so.  We will only store this data for as long as it is relevant and you have the right to withdraw your consent at any time, if you do we will delete the special category data from our records.

If you disclose special category personal data to us without us having the opportunity to obtain explicit consent, for example you send us an email detailing your medical situation, you will have given your consent for us to process that data.  We will record this information and write to you to explain how we will use it and how you can withdraw your consent.

 


HOW DO WE COLLECT YOUR PERSONAL DATA?

      • We collect your information using the following methods:
      • We obtain data from our client, the owner of your account
      • We keep records of correspondence between us, including letters, webchat, email, SMS and any other communications
      • We record phone calls and webchats between you and our staff for training and monitoring purposes, monitoring these calls helps us to improve and enhance our services
      • When you use our website we collect information concerning your usage of the website, behavioural patterns, which pages you viewed, traffic data and the originating domain name of your internet service provider
      • We operate CCTV at our business premises, if you were to visit one of our office your image could be captured on CCTV
      • We access third party data sources and combine and process data from those sources with your personal data.  Examples of these sources include the Land Registry, Credit Reference Agencies (CRAs), registers of court judgements, bankruptcies, post code look up databases and telephone number verification databases

 


HOW DO WE USE YOUR PERSONAL DATA?

We use your personal data:

      • To help us service your account
      • To manage our operations and improve our service to you
      • To manage security, risk and crime prevention
      • To meet our regulatory requirements
      • To undertake statistical analysis for business improvement

In order to process your personal data we need to have a justified legal basis, this means that processing your data must be necessary for one or more of the following:

      • To comply with a legal obligation
      • Where we have a legitimate interest
      • To perform a contract that you are party to
      • When you give us your consent
      • To protect your vital interests

The lawful bases that we rely on to process your personal data are as follows:

      • Performance of a contract
      • Legitimate interests
      • Compliance with a legal obligation

As a business, our key function is the recovery of debt.  As part of our recovery process we are required to perform trace and debt collection activity.  We also are required to validate your identity, contact you in writing or via email, SMS or telephone, we need to agree payment arrangements and process payments.

 


LEGITIMATE INTERESTS

We will collect personal data and share your personal data with Credit Reference Agencies in order to help promote responsibly lending.

 


MANAGEMENT OF YOUR ACCOUNT

We have an obligation to manage your account on behalf of our clients.  Where your account is a consumer credit agreement, we have a legal obligation to provide you with statutory communications.  We have a legitimate interest in understanding your ability to repay the outstanding balance as well as how best to communicate with you; in order to do this at times we will you automated processes to make decisions about how best to engage with you.

 


TRAINING, MONITORING AND IMPROVING OUR SERVICE

In order to ensure we provide the best service we can, we use recordings of telephone calls, which will inevitably contain personal data of our customers, to train staff.  We may monitor your website usage, collecting information to help improve our services, business efficiency and analysis activities.

 


COMPLYING WITH LEGAL AND REGULATORY REQUIREMENTS

      • Legitimate interests
      • Performance of a contract
      • Compliance with a legal obligation

At times we share data with other third parties because we have a legal or regulatory requirement to do so, for example the Financial Conduct Authority.  In the event that you are unhappy and have made a complaint to the Financial Ombudsman Service, we will share your personal data with them enabling them to review your complaint.

 


HOW LONG WE KEEP YOUR PERSONAL DATA

We will keep your personal data for as long as you are a customer of GDR and we will then retain this data for a further 6 years once we have closed your account, this is so we can respond to any complaints or queries and to comply with legal and regulatory obligations that require us to keep certain records.

 


WHO WE SHARE YOUR PERSONAL DATA WITH

At times we will need to share your personal data with other companies, here we explain who and why:

      • Other debt collection agencies that our client has instructed to act on their behalf
      • Other companies that may help us to validate that the data we hold is accurate or to obtain new information – for example a new telephone number
      • Your original creditor
      • Suppliers and service providers – for example companies that provide GDR with an IT service
      • Any person of company that you provide consent for us to communicate with – for example a friend, family member or a Debt Management Company

 


TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE EEA

It is highly unlikely that GDR would transfer your data outside of the EEA, however, if we did we will ensure that your data is protected and that the appropriate contractual requirements are in place.

 


CREDIT REFERENCE AGENCIES NOTICE EXPLAINED

Occasionally our clients require us to share details of your account with a Credit Reference Agency to promote responsible lending. We also obtain data from the Credit Reference Agencies for the following purposes:

      • To recover debts
      • To trace your whereabouts
      • To prevent fraud and other crime
      • To validate personal information that may be passed to us from your or other legitimate sources
      • To inform us of the best way to engage with you

The following is the type of information that we may exchange:

      • Full name
      • Full address, including address history
      • Financial situation
      • Personal details of any person you are financially linked with

The Credit Reference Agencies may share the data that we provide to them with other organisations.  You can find out more using the following website:

 


SHARING INFORMATION TO PREVENT CRIME OR HARM

We have systems that protect our customers and ourselves against fraud and other crime, including money laundering.  Customer information can be used to prevent crime and trace those responsible.

As part of our ongoing monitoring of your account and to service your account, we have legal obligations that require us to obtain certain personal details to validate your identity, both at the beginning of your relationship with us and throughout it. If false or inaccurate information is provided by you, or if fraud or another financial crime is identified or suspected, we will obtain publicly available information, such as media reports or regulator publications, which may contain personal details about you such as any criminal convictions.

If fraud or another financial crime is identified or suspected, we will be required to pass your personal data to fraud prevention agencies or other authorities for the prevention and/or detection of financial crime. We have legal obligations to pass this data to fraud prevention agencies and this is our legal basis for sharing personal data in this way.

The agencies we may share your personal data with are:

      • CIFAS
      • The National Crime Agency
      • Action Fraud
      • The Police
      • Her Majesty’s Revenue and Customs

If we have reason to believe that you are in prison, we will obtain publicly available information, which may contain some of your personal data such as the name of the Prison you are in and the length of your sentence, to update the information we hold about you and to manage your account in the most appropriate way.

If we have reason to believe that you are in immediate danger, we will pass your personal data, including any details we have about your physical or mental health, to the Police and other emergency services in order to protect your vital interests.

 


YOUR RIGHTS – OBJECT TO PROCESSING

You have the right to object to us processing your data if the processing itself is an unwarranted interference with your interests or rights. You can find out more about how and why we process your personal data in the section ‘How we use your personal data?’

If you still believe that you have a valid and justifiable reason to exercise this right you can contact us on the details below.

 


YOUR RIGHTS – RESTRICT PROCESSING

If you believe we are processing your personal data unlawfully or you believe that we no longer need your personal data you have the right to request that we restrict the processing of your personal data.

 


YOUR RIGHTS – RIGHT TO BE FORGOTTEN

Under data protection legislation you have the right to request that we delete your personal data if you believe we no longer have a lawful basis to process it. If you feel that we should not be processing your personal data you can submit a request on the below details.

 


YOUR RIGHTS – RIGHT TO RECTIFICATION

Upon obtaining personal data we conduct checks to validate that it is accurate as we are reliant on you and other third parties to provide us with correct information. If you believe that any of the personal data we hold for you is incorrect, it is important that you make us aware as soon as possible, for example if you have a new phone number or have moved address.

 


AUTOMATED PROFILING AND DECISION-MAKING

The new data protection legislation changes stipulate that where profiling or automated decision making produces a legal effect or similarly significantly affects you, we need to make you aware of your right to object. We do not believe that the profiling and decision-making that we conduct has either a legal effect or similarly significant impact on you but we will keep such processes and controls under review and update this notice accordingly.

If you have any further questions regarding any of the above information please contact our Data Protection Office on: info@globaldebtrecovery.com

 


YOUR RIGHTS – TO PORTABILITY

You have the right to request that we transfer personal data you have provided to us either to yourself or to another data controller. You can exercise the right to data portability by contacting us on the below details:

 


YOUR RIGHTS – ACCESSING YOUR DATA

You have the right to see the personal data relating to you that we hold.

We take the protection of your personal data seriously, so we reserve the right to request proof of your identity before supplying any personal data.

Once we have validated your identity, we will respond to your request within one calendar month. We typically will send your personal data on an encrypted email, if however you wish to receive it in a different format for example, as a printed document then please let us know.

In order to make this request please contact us on the below details:

      • Email:  info@globaldebtrecovery.com
      • Writing: Global Debt Recovery Limited, 8/10 Coombe Road, New Malden, KT3 4QE
      • Call us: 020 8336 7100

 


HOW TO COMPLAIN

If you would like to make a complaint or have a query about how we use your personal data, you can contact us on the below details:

If you are unhappy about how we have handled your complaint you have the right to complain to the Information Commissioners Office: