NETCHWOOD FINANCE LIMITED
This Privacy Notice will apply to you if you provide your personal information to us, even if you decide not to go ahead with any product or service we offer. Within this Privacy Notice we have set out how Netchwood Finance Limited will use your personal data to provide our product or service to you. The legislation relevant to this Notice is the General Data Protection Regulations 2018 (the ‘GDPR’), and the Data Protection Act 2018.
Who are we are:
Netchwood Finance Limited
Atlantic Business Centre
Registered Number: 06937144
Data Protection Licence: Z1810628
We are the ‘Data Controller’ for the purpose of the GDPR.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
- Initial application: by phone, email, our website, by a third party or by any other means.
- When you contact us by email, post, telephone or fax;
- When you respond to our request for updated financial information to enable us to meet our legal or regulatory obligations.
- 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.
- When you use an online platform, eg. An online portal.
- Through cookies on our website. You can set your browser not to accept cookies and these websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result;
- Where you have given your permission for a third party to provide information to us, such as your employer.
Special categories of personal data:
Some of the information which we collect will be special categories of personal data (also called sensitive personal data) to which greater protection is provided by the data protection laws. The information which falls within this category includes information about disability and health, sexual orientation and/or gender identity, your racial or ethnic origin, your religious or philosophical beliefs, membership of a trade union, your political opinions.
HOW DO WE USE YOUR PERSONAL INFORMATION
We can only use your personal information if it falls into one or more of the following categories:
- is that it is necessary to fulfil a contract you have with us (for example an IVA contract), or
- you have provided consent to our use of your information, or
- we have a legal or regulatory obligation to do so, or
- it is necessary to carry out a task which is in the public interest, or
- it is necessary to protect your vital interests, or
- it is necessary to protect someone else’s vital interests.
Where you make an application or enquiry for one of our products or services we will use your information to provide you with appropriate information about any solutions we may be able to offer to you. If you cannot provide this information, we may not be able to progress with your application or enquiry.
We may also use this information to contact you about, and process your application, for example, sending you an email, text message or letter to welcome you to our services.
After you have made you initial application/enquiry, if you also decide to go ahead with any of the products or services that we offer, the sections below explain how we will also process your data when we provide that particular product(s) or service(s).
Where we are providing you with a debt solution, such as an Individual Voluntary Arrangement (IVA), we will process your personal information to administer the services we provide. The agreement between Netchwood Finance Ltd. and yourself (for example the IVA Proposal) will set out how we will provide the services to you and where we will be required, under the terms and conditions, to process your personal information. For example, we would need to your share information with your creditors to enable us to set up and administer an Individual Voluntary Arrangement.
If you enter into an agreement with us, for example an IVA, the information below specifically explains how and why your personal data will be used so that the services can be provided to you.
- Contact Details: Your full name, address, contact number, e-mail address etc. We need this so that we can keep you updated on the progress of your IVA and contact you when necessary. We also need this information to draft your proposal to creditors.
- Personal & Financial Details: Your date of birth, gender, any previous names that you were known by, your living arrangements, employment details, details of any dependants, creditor details (including the names of your creditors, reference numbers and balances), details of any assets you hold and your payment information. We need this so that we can decide whether an IVA is appropriate for you and so that we can draft and send a proposal to your creditors. Once you enter into an IVA, we need this information to ensure that we can collect payments and take any changes in circumstances into consideration when administering the IVA.
- Income and Expenditure: Details of your financial position including all sources of income and your household expenditure. We need this so that we can draft your proposal to creditors and set the correct level of payments to be paid into your IVA, and to keep your creditors updated in respect of your financial position.
- Special Personal Data: In some circumstances we may need to collect special personal data however we will not do so without express consent from you and we will only do so where it is necessary for the purposes of assisting with your financial situation.
- Creditor Reference Agency Data: We will ask for your consent to obtain information from a credit reference agency to obtain information about your financial situation, including information about your creditors, their status, outstanding balances and account numbers. We may also use this information to confirm your identity and to comply with anti-money laundering legislation.
- Call Recordings, Chat Logs and E-mails: When you contact us by telephone, your call may be recorded for training and monitoring purposes. We also keep any e-mail correspondence and online chat logs to help us to manage your IVA.
If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, linked Individual Voluntary Arrangements), your personal information and any information about the service provided to you will be shared with the other person. We will use the personal information about the other person in the ways as described in this Privacy Notice.
Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.
Sharing your information
- Your Creditors and their Representatives: Your personal data will be shared with your creditors, their agents, debt collectors, bailiffs and solicitors dealing with the debts. This is key to allow us to provide the service we have agreed to provide you and also ensures that we comply with our regulatory obligations.
- The Insolvency Service: If your IVA is accepted then details about you and your IVA will be recorded on the Insolvency Register which is accessible by the public. The information we share includes your name, gender, date of birth and address. We have a legal obligation to supply this information.
- Our Regulators: From time to time we may have to share your information with regulatory bodies. These include the Insolvency Practitioners Association, the Information Commissioners Office or any other regulatory body or authority who may request certain information as part of their supervisory role. We are under legal and regulatory obligations to provide this.
- Solicitors or agents: We may from time to time need to instruct solicitors to assist with the administration of your IVA or to assist us with legal, regulatory and contractual obligations.
- IT Providers: We may use a third party software company to help manage your data.
- External printing company, who print and post our paper correspondence, external file storage company who store our files for the period provided for by our regulatory body.
- Agents: Where we have a duty to investigate any potential compensation claims that you may be entitled to, for example payment protection insurance mis-selling claims, we will share some of your information with claims management companies.
These companies help us to provide our services to you. We require the providers of these services to comply with their data protection obligations and ensure that they have appropriate security measures in place.
- Third Parties: where your situation renders you unsuitable for a Netchwood Finance Ltd. product, or, for example, a conflict of interest prevents Netchwood Finance Ltd, from providing a product to you, we may introduce you to a partner who can administer a product suitable for your requirements. In such a situation, we would transfer data to our partners to enable our partners to deliver to you, products, services and information that you have expressed interest in, or that are compatible with the reason you provided your personal data. We may do this because you gave your consent. Once we have delivered your personal data to our partner that partner becomes the controller of your personal data and they will treat your personal data in accordance with their privacy notice.
HOW LONG DO WE KEEP YOUR DATA?
If you do not go ahead with any product or service with us, your personal information will normally be deleted after 6 months unless we have another reason to keep your personal information, for example, if you have given your consent to receive marketing information from us. We will delete your information sooner if you ask us to.
If you become our customer by entering a debt solution, we will keep your data to ensure that we provide you with our services and comply with our legal and regulatory obligations. Your data will be stored for 6 years from the date that we cease to provide you with our services. We cannot delete this data if you ask us to because we are required to keep it by law. After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.
SECURITY OF YOUR PERSONAL INFORMATION
The information that you provide will be stored securely on our electronic systems. Our security measures and procedures reflect the seriousness with which we approach security and the value we attach to your information. We endeavour to keep data only electronically: where paper data is kept, this is kept securely at our office premises, or by our third party storage contractor.
Only relevant members of staff will have access to the information you provide to us. Those members of staff will have received appropriate data protection training.
In relation to the information which we hold about you, you are entitled to:
- see a copy of the information – this is called a “Data Subject Access Request”.;
- ask us to rectify the information where it is inaccurate or is incomplete. If we agree the information is inaccurate or incomplete and make the rectification, we will inform any recipients of the information of the change, where possible;
- ask us to erase the information, but we will not be able to comply where we hold your information to fulfil our statutory regulatory and representative obligations;
- ask us to restrict what we do with your information, but there are a number of exemptions relating to this right;
- object to our use of your information and ask us to stop that use, in certain circumstances; and
- instruct us to provide you with the information we hold about you in a structured and commonly used format or transmit that information directly to another organisation.
Our obligations to comply with the above rights are subject to certain exemptions.
Where we are using some of your information because you have provided your consent to that use, you are entitled to withdraw your consent at any time. The lawfulness of our use of your information before consent was withdrawn is not affected. You can do this by writing to or by emailing us.
You also have the right to complain to the Information Commissioner’s Office (the “ICO”) if you are not satisfied with the way we use your information. You can contact the ICO – see https://ico.org.uk/global/contact-us/ for details.
Our Site may contain links to other websites which are outside our control and are not covered by this Privacy Notice. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their own privacy policies, which may differ from ours. Therefore, if you use these links to leave our Site and visit websites operated by third parties, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting those websites. Please check these policies before you submit any personal data to these websites.
REVIEWING OUR PRIVACY NOTICE
This policy will be kept under review and if amended, notification will be made on the Netchwood Finance Limited website.