Protecting your personal information is extremely important to us at LFDS. The following Privacy Notice sets out how we collect, use and store your personal data and how we make sure your data is secure. This notice applies to you if you provide your personal information to us, even if you do not go ahead with an Individual Voluntary Arrangement (“IVA”).

If you have any questions about how we may use your personal information, please contact us using the details below.

1. THE INFORMATION WE COLLECT

The information we collect from you relates to assisting you with your debts, the assessment of your suitability for an IVA and if appropriate the setting up and implementation of your IVA. We will only collect data that we actually need for these tasks, or where we’re required to collect the information to enable us to perform our legal, regulatory or contractual obligations or if we have your permission.We will collect:

A. personal information (such as your name and date of birth)
B. your home address
C. contact information (e.g. telephone number, mobile, email)
D. special personal information (if necessary)
E. financial information
F. information about your employment

If you provide us with personal information about someone else (such as a partner) please do so only with that person’s express consent. If you enter into a joint IVA, your personal information and any information about the service provided to you will be shared with the other person.

We will also use the personal information about the other person as set out under the terms of this privacy notice.

2. HOW WE COLLECT YOUR DATA

We collect information about you in a variety of ways:
• Through your enquiry/application via telephone, email, through our website, through other media channels such as WhatsApp or by other electronic means
• Information received from a third party, for example a creditor providing information about an account you hold with them, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company
• By communicating with us on social media such as Facebook
• If we may need to obtain current information about you to meet our legal or regulatory obligations such as credit searches
• Where you have given permission for your information to be provided to us

3. USING YOUR PERSONAL DATA

We may only use/process your personal information lawfully if it falls into one or more of the following categories:

A. If you give specific consent
B. In order for us to meet our contractual obligations to you
C. Where we are legally required to do so
D. To protect your vital interests
E. If it is in the public interest
F. If we have a legitimate interest in doing so

4. HOW LFDS PROCESSES YOUR INFORMATION

Initial Advice/Enquiry
If you ask us for help or advice about your debts and/or make an application for us to assist you with an IVA, we will use your information to help us provide you with advice on appropriate solutions. If this information is not available, we may not be able to advise you or assist with an IVA.The information will be used to enable us to contact you via letter, email, text or telephone about your circumstances to provide advice and if relevant to keep you informed of where your IVA application is up to.In order to provide you with advice on your debts we must collect the following personal data:

A. Contact details so we can advise and keep you informed of where your application is up to
B. Details of who you owe money to and your assets – to enable us to give you correct advice on your personal circumstances
C. Details of what you earn and your monthly expenditure to allow us to assess which debt solution is the most appropriate for you and advise you accordingly
D. Your personal circumstances such as your employment, details of your dependents etc so we can provide suitable advice on financial solutions available to< you
E. Any special personal data relevant to your situation if it affects the advice or recommended solution

We may use information from your credit file to provide confirmation of your creditor details and any history of insolvency or outstanding county court judgements.

If a third party introduced you to us, we will share information about what debt solution we have recommended and whether you have chosen to use LFDS to provide that solution.

We may share your information with:
F.
i. any companies we work with such as professional advisers (eg solicitors) or on an outsourced basis such as insurers or our IT service provider but this will only happen if they agree to keep the information confidential.
ii. Our regulator, The Institute of Chartered Accountants, the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority which may request certain information where we have a legal or regulatory obligation to
provide this.
iii. With your authority or if we have a legitimate interest to do so or where we may be legally entitled to, we will share information with credit reference agencies, so we can obtain information about your financial circumstances or credit commitments.

Ongoing Services
Where we are providing you with an IVA we will process your personal data to administer your IVA. This may include contacting you if we need further information, or sending you updates on the progress. We will normally require you to agree to the terms and conditions of the IVA which will set out how we will provide the service to you and where we will be required, under the terms and conditions, to process your personal information. For example, we would need to share your information with your creditors to enable us to set up and administer an IVA. If an IVA is implemented on your behalf in our role as Supervisor of the arrangement we have a legal obligation to comply with relevant Insolvency legislation.

5. OTHER PURPOSES FOR PROCESSING YOUR PERSONAL DATA

Client Feedback
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 which may help us improve our current services.

Although this information would really help us, you wouldn’t be required to provide us with this information unless you were happy to. We consider that it is in our legitimate interests to contact you in this way.

Legal or Regulatory Obligation
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 other regulatory obligations.

Responding to Complaints or Enquiries
If you make an enquiry or complaint to 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.Internal AnalysisAs part of our legitimate interest to develop our business we will use your personal information to assess our performance and for 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.

Social Media
We use publicly available social media platforms to promote our services. If you post a message on our Facebook page or similar platforms you should be aware that:
• the social media web pages are publicly available and you must not provide any personal or sensitive information on our pages that are accessible to the public; and
• each social media platform will process any personal information you provide through the platform and will be processed in accordance with its own privacy policy. The privacy policies are available to view on each social media platform.

Cookies
When visiting our website, some information may be collected automatically using ‘cookies’.

These are small text files that allow the processing of your data and enable us to analyse how the website is being used. Cookies can be temporary or permanent.

Temporary cookies are part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.

Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off – this won’t stop a website from working, but it might mean it won’t work as well as it could, or that you have to do the same thing more than once.

Cookies tell website owners things like: what search engine a visitor used to find the website, how often they’ve visited it, how long they’ve spent on it, and so on.

The following cookies are the ones we use at LFDS:
• Facebook conversion tracking;
• Google Analytics – this is used to collect information about how visitors use our website. They keep track of when a visitor enters and leaves the website and any search engines and keywords that are used, including any personal and/or special categories of data; and
• Zopim – Online chat functionality.

For more information about cookies and how to turn them off, please visit the websites of the relevant provider.

6. SHARING INFORMATION OUTSIDE THE EEA

We will only share your personal information outside the European Economic Area (EEA), where we have your consent or to comply with a legal obligation, or where we work with a business partner to enable us to provide you with our services, and they process information outside of the EEA.If we do share your information outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA ensuring appropriate safeguards are in place.

This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as the EEA.More information on this can be found on the European Commission Justice Website.

7. SECURITY

We take the protection of personal information seriously and will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided.

Such measures include:
• company security policies and standards
• staff security awareness and training
• access controls to prevent unauthorised access to the information
• encryption
• anti-malware technologies
• security monitoring & testing
• secure archiving and deletion
• ompliance with industry regulation and legislation

8. CONTACTING YOU

To help us keep you up to date about the service we provide to you and to ensure that you’re kept fully informed, we may contact you by letter, telephone, email, text message, social media or may send you messages by any online customer platforms or other electronic means.If you start an application for an IVA through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason.

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 offers, products and services that we provide which may be of interest to you. We may do this through post, emails, text messages, telephone, social media 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.

You can easily let us know at any time if you would no longer like to receive these messages using the details below.

9. YOUR RIGHTS

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 called a “Data Subject Access Request”. You can request this information by contacting us as set out below. We won’t charge to provide you with this information.Before providing this information to you (or to another person or company where you have requested), 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.

Portability
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 and we will do our best to accommodate your request

10. HOW LONG WE KEEP YOUR PERSONAL DATA

A. If you enter into an IVA with LFDS, we will keep a record of your personal information where we are required to keep your data to meet our legal and regulatory obligations. This will normally be kept for 6 years after we have finished providing this service. Telephone
calls will be retained for at least 6 years from the date the call was made.

B. If you do not go ahead with an IVA, your personal information will normally be deleted after 2 years unless there is any other reason to keep your personal information, for example, if you have given your consent for some other purpose.

C. After the above time periods, we will delete or anonymise the data so that it cannot be linked back to you.

CONTACT US

If you have any questions or queries about how we use your personal information you can contact us at the address or email below:

Lawson Fox Debt Solutions Limited
Falcon Mill
3rd Floor
Handel Street
Bolton
BL1 8BL

Email: gdpr@lawsonfox.co.uk

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/