Privacy

Who are we?
How we use your data?
Personal data we may collect
Uses made of you personal data
Legitimate business interests
Website cookies
Recorded phone calls
Other websites
Changes to our privacy policy
Complaints and access to personal data

Who are we?

BPO have a legitimate business purpose to hold and process data in relation to debt collection activities either for our own data or data provided to us by our various corporate clients.

This privacy policy outlines how BPO Collections Ltd ("BPO") will use, store and share your personal data and supplements any fair processing notice provided to you. Please note that in this Privacy Policy "BPO", "we", "us" and "our" means BPO Collections Limited.

We will use your personal data fairly and lawfully and in accordance with the Data Protection Act 1998 ("the Act"). For the purposes of the Act, we are data processors.

We collect limited sensitive personal data as required by the Financial Conduct Authority ("FCA") and we have set out more detail on this in the section headed "Sensitive Personal Data".

BPO registration details can be viewed through the FCA website register (https://register.fca.org.uk/) by searching on "BPO Collections Ltd"

Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.

The following sections outline BPO’s Fair Processing and Privacy Policy.

How We Use Your Data

BPO have a legitimate business purpose to hold and process data in relation to debt collection activities either for our own data or data provided to us by our clients.

Personal Data We May Collect And Use

Where We Get Your Personal Data From?

You may share personal data about yourself and your circumstances with us through direct use of our website or within phone calls, emails or otherwise. We may also receive personal data about you from our clients and third parties such as from companies that we have purchased address and telephone details and credit reference agencies.

What Categories of Personal Data Do We Collect?

The personal data that we collect ourselves and receive from third parties may include the following:
your name, address, e-mail address, phone number, debt account information, payment history, credit reference information, and any other details relating to your debt account and associated address details.

Also, each time you visit our website we may automatically collect information and personal data about your computer for system administration, including where available your IP address, operating system and browser type. We use a third party service, Google Analytics, to collect your reference number, other non-personally identifiable information that you enter and details of your behaviour patterns, including the tracking of visits across multiple devices. Google’s remarketing and advertising reporting has been enabled to provide additional information for the analysis of visitor characteristics and behaviour.

We do this to help us analyse how users use the site (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account. We do not allow Google to make any attempt to establish the identities of any users of our website.

To find out more about how these cookies are used and to opt-out of being tracked, please see our "Cookies" section below.

We collect limited sensitive personal data as required by the Financial Conduct Authority ("FCA") and we have set out more detail on this in the section headed "Sensitive Personal Data".

Please note that we may combine personal data we receive from other sources with personal data you give to us and personal data we collect about you.

Uses Made of Your Personal Data

BPO will only process data on behalf of our clients and will process this data in accordance with this privacy policy.

BPO may use personal data held about you in the following ways:

for our debt collection purposes including:
• to manage your account,
• to tailor payment plans to your individual circumstances,
• to carry out our obligations arising from processing your account (such as notifying our client of fraud activity or criminal activity,
• to locate you at a new address and to check/update your contact details;
• to carry out account analysis for ourselves and our group companies such as to determine whether you are likely to pay your debts;
• to provide services to our clients in relation to debt collection (including to manage your account and to tailor payment plans to your individual circumstances), analysing your account (such as to determine whether you are likely to pay your debts, assessing affordability and to enable our client to make financial decisions), your payment history, account usage, check/update your contact details and to locate you;
• to administer our website;
• to improve our website to ensure that content is presented in the most effective manner;
• to allow you to participate in interactive features of our service, when you choose to do so; and
• to prevent money laundering and fraud.

Please note that as a user of our website and our call centre services, you are responsible for keeping any passwords or personal account data confidential and secure.

If you require further information about the purposes for which we use your personal data then please contact us by Email: Clientservices@bpomail.co.uk

Subject – Data Protection Query,
BPO Collections Ltd, Marina Quay, Dock Road, Ardrossan, Ayrshire, KA22 8DA.

Legitimate Business Interests

Our use of your personal data for the purposes set out above is for the legitimate interests of our business. As indicated above we may also pass your personal data to group companies and third parties, and this is also for our legitimate business interests.

HOW LONG WILL YOUR PERSONAL DATA BE KEPT BY US?

We will retain your personal data for five years from the closure of your last account with us.

DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We may share your personal data with group companies as set out above as under the heading "Uses Made of Your Personal Data".

BPO may also share your personal data with certain third parties as follows:
• We may share your personal data with third parties who are our clients as set out above under the heading "Uses Made of Your Personal Data";
• We may subcontract some of our services to sub-contractors and we may share your personal data with our sub-contractors as data processors; and
• We may share your personal data with our suppliers who provide goods and services to us to enable them to provide these to us. These suppliers are our data processors and may only use your personal data in the way we specify.

If BPO transfers or sells part or all of the business entity to a third party, your personal data may be disclosed to the third party and any relevant advisors. Further, if the transaction goes ahead, the third party may use or disclose your personal data as set out in this policy.

We may share your personal data with third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or to protect the rights, property, or safety of BPO, our clients, our employees agents and subcontractors or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

SENSITIVE PERSONAL DATA

The Act defines certain personal data as ‘sensitive’ such as personal data regarding your ethnic origin, physical health and mental health.

We are required by the FCA to understand whether the people that we deal with could be regarded as vulnerable and this may involve collecting and using sensitive personal data. We may, for debt collection purposes, therefore ask you for some sensitive details or you may voluntarily give such sensitive personal data to us. We will only use this sensitive personal data for debt collection purposes and we will obtain your consent to processing this data. Any sharing of your sensitive personal data with clients will be on the basis of your consent or if we are required or permitted to do so under the Data Protection Act 1998.

CREDIT REFERENCE AGENCIES

Credit Reference Agencies ("CRAs") hold personal data about consumers. Most of the personal data held by the CRAs relates to how you have maintained your credit accounts. They also hold address details and personal data from public sources such as the electoral roll, public records including county court judgments, and bankruptcy and insolvency data. We may obtain personal data about you from the CRAs for debt collection purposes and to check your credit history, verify your identity (or someone linked with you), to locate you and to prevent fraud protection and money laundering.

If you fall behind with your payments and a full payment or satisfactory payment plan are not made, then a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on your credit file for 6 years. Other organisations may see these defaults and any searches done on your file, and these may affect your ability to borrow from other lenders. BPO do not impact credit files as we pass information to our clients for them to determine if a customer’s credit file will be updated.

WHERE WE PROCESS YOUR PERSONAL DATA

The data that we collect from you will not be transferred to or stored anywhere outside of the European Economic Area (EEA).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website.

Website Cookies

"Cookies" are small pieces of information sent by a web server (such as that used to run this website) to your computer, which are then stored on the computer’s hard drive. Although cookies contain identifying information, except where we mention that we collect your reference number below via Google Analytics, they do not contain any information that identifies you personally, but they allow us to recognise you when you return to our website

We do not use persistent cookies i.e. those that are pushed out to a user’s machine and stored. This website uses Session Cookies. These are temporary cookies, which only exist in the period you access the website (or more strictly, until you close the browser after accessing the website). Session cookies help the website remember what you chose on the previous page, therefore avoiding the need to re-enter information and improve your experience whilst using the site. These cookies do not contain personal information and cannot be used to identify you.

We also use cookies to help us improve our service to you. For example, we use Google Analytics, a popular web analytics service provided by Google. Google Analytics uses cookies to help us analyse how users use the site (including behaviour patterns and the tracking of visits across multiple devices), to establish more about our website users and to assist us in managing your account. The cookies collect your IP address, your BPO reference number and certain non-personally identifiable information that you enter. Google’s remarketing and advertising reporting has been enabled to provide additional information for the analysis of visitor characteristics and behaviour. Find out more about how these cookies are used on the Google Privacy site.

You can change your browser settings so that cookies are not accepted. If you do this, you may lose some of the functionality of this website, including the use of the secure area of the website.

For further information about cookies and how to disable them please go to: www.aboutcookies.org.

Cookie Policy Website Detail:

Cookies

To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

How do we use cookies?

A number of our pages use cookies to remember:
If you have agreed (or not) to our use of cookies on this site.
If you have logged into the secure section of this site.

How to control cookies

You can control and/or delete cookies as you wish – for details, see aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.

RECORDED PHONE CALLS

We may monitor and/or record phone calls between our staff and you in order to offer you and our staff additional security, resolve complaints, for training purposes and to improve our quality and service standards.

All call recordings are hosted on UK based servers that meet GDPR regulatory standards, these are retained for up to 30 days on our dialler supplier and then held up to 5 years on BPO Servers.

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.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this policy from time to time and if we do we will bring the new terms to your attention when you visit the website or contact our offices.

Complaints and access to personal data

The GDPR regulation gives you the right to access personal data held about you.

GDPR Customer Rights, under article 12 of GDPR you have rights such as access, Verification, correction and objection to automated processing of your data.

BPO have legitimate interest to only allow you to ensure accuracy of the records we keep and the erasure of non-essential data (we have the right to hold your contact data for the legitimate pursuit of debt collection practices).

Record retention

BPO will retain data for 5 year after the last activity has concluded upon your account (examples of this would be final payment or from when the account was returned to our client).

If you would like to access this personal data, or are unhappy with how we use your personal data please contact BPO on the details provided below:

By email: Clientservices@bpomail.co.uk Email Subject: "Data Protection Query – Complaint"

By letter: "Data Protection Query – Complaint"
BPO Collections Ltd, Marina Quay, Dock Road, Ardrossan, Ayrshire, KA22

Information Commissioner’s Office – Escalation and Dispute Resolution

If you are not satisfied with our resolution in relation to your concern then please contact the Information Commissioner’s Office ( https://ico.org.uk/concerns/ ) or telephone 0303 123 1113/

Questions and Queries

If you have more general questions or comments in relation to GDPR please contact:

By email: Clientservices@bpomail.co.uk Email Subject: "Data Protection Query"

By letter: Data Protection Query
BPO Collections Ltd, Marina Quay, Dock Road, Ardrossan, Ayrshire, KA22 8DA