T and governs the privacy of its users who choose to use it. It explains how we comply with the GDPR (General Data Protection Regulation), the DPA (Data Protection Act) [pre GDPR enforcement] and the PECR (Privacy and Electronic Communications Regulations).
We and this website comply with the DPA (Data Protection Act 1998) and GDPR (General Data Protection Regulation) which came into effect from 25 May 2018. We will update this policy accordingly after the completion of the UK’s exit from the European Union.
For the purpose of the DPA and GDPR, we are the data controller and any enquiry regarding the collection or processing of your data should be addressed to Mr D Rowland at our address Castle House, Park Road, Banstead, Surrey SM7 3BT.
By using this Website you consent to this policy. We are registered with the Information Commissioner’s Office under registration number Z2017305.
Information we may collect:
We will collect personal data on this Website only if it is directly provided to us by you; the user, e.g. your email address, name, home or work address and telephone number and therefore had been provided by you with your consent. Normally you will only provide such details if you’re making a general enquiry about your case, providing us information or you are making a payment.
Your payment information (e.g. credit/debit card details) provided when you make a payment on our website is not received or stored by us. That information is processed securely and privately by the third party payment processors that we use. Confero Collections Ltd will not have access to that information at any time. We may share your personal data with our payment processors, but only for the purpose of completing the relevant payment transaction. Such processors are banned from using your personal data, except to provide these necessary payment services to us, and they are required to maintain confidentiality of your personal data and payment information.
We may also collect other information that is relevant to the service we provide to identify you or if we are required to so by law. For example, credit or debit card details, CCTV and audio data obtained from Body Worn recording equipment, recruitment data and personal data of a sensitive nature pertaining to a customers’ or third parties vulnerability status.
The list is not exhaustive; however, any sensitive data will only be shared with the relevant client to ensure that an individuals’ case can be dealt with in an appropriate manner and for the collection of debt only. We will only share this information if we are able to do so by law or we have obtained your consent, before we process this data.
Use of your information & Legal Basis
We may hold and process personal data in accordance with the DPA and GDPR. The grounds on which we rely are as follows:
- Legal and Statutory Obligation
- Legitimate interests
- Contract/provision of service
The information that we collect and store relating to you is primarily used to enable us to provide our services to you and our clients and to meet our legal & Statutory Obligations to our clients, staff and Enforcement Agents working on our behalf. In addition, we may use the information for the following purposes:
- To manage changes to our website, such as any improvement or service changes that may affect the service we provide to you.
- Responding to general enquiries and complaints made by you
- To enable a vulnerability status to be identified and dealt with accordingly
- Where you have consented and or we are permitted by law, we may also use your data for marketing purposes which may include contacting you by telephone email or post to provide information on other parties’ products’ or services that we feel may be of interest to you.
- Where you have consented to receive our e-newsletters, from time to time to provide that to you.
- Supplying our services to you and our clients
- Enabling credit and debit card payments by customers on behalf of our clients
- For the Health and Safety of staff members involved in the services we provide.
Disclosure of your information
We may disclose your information to regulatory bodies to enable us to comply with the law and to assist fraud protection and minimise risk. We may also be required to disclose your information where we are involved in legal proceedings. It should be noted that we do not require your consent when we are acting with lawful authority i.e. legislation or a Court Order.
Where you have consented for us to do so, we may provide your data to selected third parties who may be providing services on our behalf such as payment processing.
We may also disclose your information for the prevention or detection of crime or for the misuse of services. The data disclosed; however, will be relevant to our services and to assist in identifying you.
Please be aware that we do not reveal information about identifiable individuals to third parties other than those required to assist us in providing the service/contract to our clients for example; professional tracing companies and the Driver and Vehicle Licensing Agency (DVLA).
Controlling the use of your data
If you have given us consent to use your data for a particular purpose you can revoke or vary that consent at any time. If you do not want us to use your data or want to vary the consent that you have provided, you can write to us at the address detailed at the start of this policy or by emailing us at email@example.com.
Where we store and transfer your data
As part of the services offered to you, for example through our Website, the information you provide to us may be transferred to and stored in countries outside the European Economic Area (EAA) as we use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the EEA, or use servers based outside of the EEA. This is generally the nature of data stored in “the Cloud”. It may also be processed by staff operating outside the EEA who work for one of our suppliers e.g. our website server host, or work for us when temporarily outside of the EEA.
We do not use or disclose sensitive personal data, such as race, religion, or political affiliations, without your explicit consent.
Otherwise, we will process, disclose or share personal data only if required to do by law or in the good faith belief that such action is necessary to comply with legal requirements, legislation or legal process served on us or the website.
You have the right to opt out of our processing your personal data for marketing purposes by contacting us at firstname.lastname@example.org.
What are cookies? Cookies are small files saved to the user’s computer hard drive that track, save and store information about the user’s interactions and usage of a website. This allows the website, through its server to provide the users with a tailored experience within the website being viewed.
Website Visitor Tracking
This website uses tracking software to monitor its visitors to better understand how they use it. The software will save a cookie to your computer hard drive in order to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.
Users are advised that if they wish to deny the use and saving of cookies on to their computer hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors or use the cookie control system if available upon their first visit.
Downloads & Media Files
Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party antivirus software or similar applications.
We accept no responsibility for third party downloads and downloads provided by external third party websites and would advise users to verify their authenticity using third party antivirus software or similar applications.
Contact & Communication With us (Security)
The transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of data while you are transmitting it to our site. Users contacting us through this website do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
Where we have given you (or where you have chosen) a password (if applicable) so that you can access certain parts of our site, you are responsible for keeping this password confidential. You should choose a password that is not easy for someone to guess.
The DPA and GDPR give you the right to access information held about you by us. Please write to us or contact us by email if you wish to request confirmation of what personal information we hold relating to you. You can write to us at the address detailed at the beginning of this policy or by email to email@example.com. There is no charge for requesting that we provide you with details of the personal data that we hold. We will provide this information within one month of you requesting the data.
You have the right to change the permissions that you have given us in relation to how we may use your data. You also have the right to request that we cease using your data or that we delete all personal data records that we hold relating to you. You can exercise these rights at any time by writing to us at the addressed detailed at the beginning of this policy, or by email to firstname.lastname@example.org. Should we decline your request, we will write to you clearly explaining the reason for our decision.
External Website Links & Third Parties
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text / banner / image links to other websites).
Shortened URL’s; URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is especially used in social media and looks similar to this (example: http://bit.ly/zyVUBo). Users should take caution before clicking on shortened URL links and verify their authenticity before proceeding.
We cannot guarantee or verify the contents of any externally linked website despite our best efforts. Users should therefore note they click on external links at their own risk and we cannot be held liable for any damages or implications caused by visiting any external links mentioned.
These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.
Social Media Policy & Usage
We adopt a Social Media Policy to ensure our business and our staff conducts themselves accordingly online. While we may have official profiles on social media platforms, users are advised to verify authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.
There may be instances where our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about some social media privacy and usage policies in the resources section below.
Changes to this policy
We may update these polices to reflect changes to the website and customer feedback. Please regularly review these policies to be informed of how we are protecting your data.