Who is the Data Controller?

Moorcroft Debt Recovery Limited is a company registered in England and Wales with offices at PO Box 17, Moorcroft House, 2 Spring Gardens, Stockport, SK1 4AJ.

We are registered with the Information Commissioner's Office with registration number Z5351122.

Sometimes we are not the Data Controller, but will be a Data Processor acting on behalf of and in line with instructions from a lender (such as your Bank or credit card provider) who has a contract with you.

Our Data Protection officer can be contacted via the above postal address or via email at [email protected]

Why do we use your information?

We use your personal information for a variety of reasons related to our business activities including the collection of debts, administration of customer accounts, to contact you and trace you if necessary and to comply with our legal and regulatory obligations.

What is the legal basis for this use?

In most cases our use of your information is necessary and carried out on the following legal grounds:

• For the performance of a contract with you (such as your loan agreement).
• Where necessary for our legitimate interests or the legitimate interests of your lender who we act on behalf of (under your loan agreement); and
• Where necessary in order to comply with a legal obligation (for example making reports to our regulatory authority or to law enforcement agencies).

Where our use of your data is not necessary for one of the purposes outlined above we may seek your consent to use it in a particular way, for example if we ask you to provide feedback or you tell us about a change in circumstances relating to your health.

Where we ask for your consent you may refuse and can withdraw your consent at any time by contacting us using the details set out below.

What information about you do we use

We collect and use the following information about you:

• Information from your lender about your account(s), including your contact and personal details, information about your financial circumstances and the transaction information of your account(s);
• Information about you from third party organisations, such as Credit Reference Agencies (CRAs), Fraud Prevention Agencies (FPAs) and tracing agents;
• Information obtained from other public data sources which might include data from the electoral roll, public records including county court judgments, and bankruptcy and insolvency data;
• Information about your use of our website (see Cookies below)
• Call recordings when you speak to us over the telephone and voice recordings when you speak to one of our Field Operatives
• Information you (or your third party representative(s)) provide us with or share publically
• Where we are provided with an email address this may be used to contact you regarding your account.

Automated decision making and profiling

We sometimes use automated decision making and profiling in our processing activities, however this would not have a legal impact on an individual. We acknowledge a data subject’s right not to be subject to automated decision making and profiling, should this activity have legal or similarly significant implications.

When might we collect and use sensitive information about you?

We always seek to treat customers fairly and be responsive to their individual needs. Sometimes you may disclose some types of information which are classed as sensitive under the law. A common example of this is information about your mental or physical health. We will ask your consent to record this information. Not agreeing to us recording this information may impact on our ability to make adjustments for your circumstances. We collect this information so that we can treat you fairly and according to your needs.

Who do we share your information with?

We may share your information with:

• Our client(s) (your lender(s)) and their representatives;
• Third party service providers, such as tracing agents, our legal advisers and our website support;
• CRAs and FPAs to which we may report positive, delinquent and default data about your account(s) on a regular (minimum monthly) basis;
• Law enforcement agencies or regulatory bodies where we are required to do so;
• Other members of our group of companies, and any purchaser or proposed purchaser of all or part of the same or their assets, together with their professional advisors;
• You or your third party representatives (in line with your rights); or
• We believe, in good faith, that it is necessary to protect our rights, property, safety or reputation or the rights, property, safety or reputation of any of our clients or partners.

Records remain on file with CRAs and FPAs for 6 years after they are closed, whether settled by you or defaulted. This information may be supplied to other organisations which search your credit record. More information about CRAs and how they use personal information is available at the Experian website or you can contact the agencies below:

• TransUnion
  Consumer Services Team, PO Box 491, Leeds, LS3 1WZ Tel: 0330 024 7579 or visit the Transunion website here
• Equifax PLC
  Equifax Ltd, Customer Service Centre, PO Box 10036, Leicester, LE3 4FS Tel: 0800 014 2955 or visit the Equifax website here
• Experian
  Consumer Help Service, PO Box 8000, Nottingham, NG80 7WF Tel: 0844 481 8000 or visit the Experian website here

Where is your information stored?

The information we collect about you will be held on our secure servers within the European Economic Area (the EEA) and will not be transferred or stored outside the EEA. We take steps including encryption, to ensure that your information is kept secure and is protected from access by unauthorised processing, accidental loss, destruction and damage.

How do we process any personal information freely provided to us by any individual?

As a Debt Recovery Agency we are required to seek contact and primarily discuss affordable repayment options.  We are also required to review supporting financial evidence in line with regulatory guidance we are obliged to follow and in order for any repayment offer to be fully considered as being affordable, suitable and appropriate. In line with regulatory guidance we would have legitimate interests to request such information from any individual whose account we are assisting with.

If a customer wishes us to consider personal information about their health any such decision to provide this additional detail would rest completely with the individual.

• If the information is advised to us by telephone we would ask for explicit consent before we could accept and consider the information and note it on our system.
• If the information is sent by written communication we would consider that an individual is freely providing this additional detail and wants us to accept the written communication provided so we can provide appropriate assistance.  However, we also require that you do confirm within your written communication that you provide your explicit consent to save the information against your account. We may also attempt to call you directly to clarify consent if it is not confirmed and advise how we can assist you further.

So that you can make an informed decision about any personal information you wish us to record we can reassure that information is securely protected and is not at any time shared with any third party.

How long will your information be kept on file?

We keep your information for as long as it is necessary to provide you and our client with the services which we have been requested to perform and, to the extent it is necessary for the protection of our legitimate interests, in accordance with our internal retention policies and in agreement with our clients.

Recorded phone calls

We may monitor and/or record phone calls between our call centre staff and you in order to assist in providing both you and our staff additional security, to help resolve complaints and for overall training and quality purposes.

Voice Recordings

Should you receive a visit from one of our Field Operatives, your conversation may be recorded in order to assist in providing both you and our staff additional security, to help resolve complaints and for overall training and quality purposes.

Use of our website

To guarantee the smooth running of our website, we do monitor when customers log-in using their Moorcroft reference number and date of birth. If you choose to log-in to our website you may receive an automated email to ensure that your user experience was satisfactory and you found everything you were looking for.

Other websites

Our site may, from time to time, contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or your use of those websites.

Your rights

• Right of access
  You have a right to access the personal information we hold about you and be told why we use it
• Right of rectification
  You can ask us to correct or update your information to ensure it is accurate and complete
• Right to erasure and right to restrict processing
  You can ask us to stop processing and to delete your data in certain circumstances (for example where it is processed with your consent, or it is no longer necessary for us to process it)
• Right to data portability
  You have a right to ask us to provide you with information in a form that suits you, and/or to provide your information to a third party
• Right to object
  You have a right to object to our processing of your information
• Rights: profiling and automated decisions
  You have a right not to be subject to automated decisions which have a legal effect and to be protected by safeguards in respect of any profiling
• Rights in relation to CRAs
  You have a right to be told which CRAs we have used and obtain a copy of your file from CRAs

You can exercise the above rights by contacting us (see details under 'Contact and complaints' below). Further information is also available from the ICO's website here.

Please note that where we are acting on behalf of your lender, they may in some circumstances stipulate that we must refer your request or query to them as they are the 'controller' of your data. We may alternatively request that you contact them in the first instance. For security purposes you may be asked to provide evidence of your identity if you make a request to exercise your rights.

For further details of how to make a Data Subject Access Request (DSAR), please click here.

For further details of how to exercise any of your other rights under GDPR, please click here.

Contact and complaints

You can contact us by post at the address shown above or by telephoning 0161 475 2834.

If you have questions or want to exercise your rights, please email [email protected]. If you wish to make a complaint, please email [email protected].

You can also make a complaint to the ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113 or visit the website here.

Cookies notice

We use cookies (a cookie is a small, sometimes encrypted, text file which is placed onto your device) which allows our website to recognise users' devices, amongst other things, to:

• Recognise you whenever you visit our website;
• Obtain information about your preferences, online movements and use of the internet; and
• Carry out analysis to help improve our content and to better understand our user, customer and visitor requirements and interests.

We use session cookies (these are deleted when the web browser session is closed) which are necessary in order for this site to function as intended.

In some cases we will need your agreement in order to use cookies on this website, By continuing to use our website you are agreeing to the use of our cookies as described in our privacy policy. The exception is where the cookie is essential in order for us to provide you with a service you have requested.

In addition to our cookies we may use third party cookies.

Description of cookies

• Name of cookie
  NID
• Owner
  Google
• Purpose for the cookie
  The NID cookie contains a unique ID Google uses to remember your preferences and other information, such as your preferred language (e.g. English) etc.

• Name of cookie
  GRECAPTCHA
• Owner
  Google
• Purpose for the cookie
  Is a CAPTCHA system that enables web hosts to distinguish between human and automated access to websites.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies here. For more information about cookies generally, please see the website here.

Updates

Updates to this policy are published on our website and, where appropriate, sent by email.