GDPR: Data Privacy Notice for Customers

Introduction

Jacobs (“We”) are committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person


Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.

Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership,political opinions, religious or philosophical beliefs.

Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who Are We?

Jacobs are registered as Data Controllers with the Information Commissioners Office. However for the purposes of managing cases from Clients we are the Data Processor. This means we only act on documented instructions of the Data Controller.

Our contact details are:

6 Europa Boulevard,
Birkenhead,
CH41 4PE


For all data matters contact:

Data Protection Officer,
6 Europa Boulevard,
Birkenhead,
CH41 4PE

3. The Purpose(s) of Processing Your Personal Data

We use your personal data for the following purposes:

The collection of outstanding Liability Orders, Fines, Warrants and debts owed to our Clients in accordance with legislation, codes of conduct and best practice.

4. The Categories of Personal Data Concerned

With reference to the categories of personal data described in the definitions section, we process some or all of the following categories of your data:

• Name;
• Date of birth;
• Business/company name;
• Job title;
• Profession;
• Visual and audio images of you through our use of Body Worn Video and audio recording equipment;
• Contact information such as email addresses and telephone numbers;
• Demographic information such as postcode and preferences;
• Financial information such as credit / debit card numbers;
• Personal data collected arising out of the debt collection and enforcement process (some of which may include sensitive data related to the customer or other third parties), such as information on the physical or mental health or condition of the debtor and details of incidents occurring during debt enforcement visits;
• IP address (automatically collected);
• Web browser type and version (automatically collected);
• Operating system (automatically collected);
• A list of URLs starting with a referring site, your activity on our Site, and the site you exit to (automatically collected);
• Caller line identification;
• Complainants and other individuals in relation to a service complaint or enquiry;
• Vehicle registration keeper details;
• Banking details that you have permitted us to use on your behalf.


We have obtained your personal data from:

• Clients
• Approved Trace suppliers
• Approved outsourced data suppliers
• Social Media including Facebook, Twitter, Instagram
• Information you have provided as part of an application form
• Information you have provided to support a means enquiry

5. What is Our Legal Basis for Processing Your Personal Data?

Personal Data (Article 6 of GDPR)

Our lawful basis for processing your general personal data:

Processing necessary for compliance with a legal obligation and for the performance of a task carried out in the public interest as Jacobs are acting on the basis of authority from the court and their power to enforce warrants is set out in statue (The Tribunal Courts and Enforcement Act 2007). The processing is necessary to identify persons with outstanding Liability Orders, Fines, Warrants or Debts owed to our Clients, and obtain payment.

More information on lawful processing can be found on the ICO website.

6. Sharing Your Personal Data

Your personal data will be treated as strictly confidential.

We may sometimes contract with third parties to supply services to you on our behalf. These may include payment processing, correspondence management, tracing and mailing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may, from time to time, share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply, as required, with any legally binding request that is made of us.

We may share your data in pursuing an interest that corresponds with a general public interest or a third party’s interest. This may include situations where we are required to go beyond its specific legal obligations set in laws and regulations to assist law enforcement or private stakeholders in their efforts to combat illegal activities, such as money laundering, fraud prevention or misuse of services. However the use of personal data in such circumstances will be restricted to data which is relevant to our services and necessary to identify you.

7. How Long Do We Keep Your Personal Data?

We keep your personal data for no longer than reasonably necessary which we deem to be a period of 7 years in order to assist us to contact you and possibly prevent unnecessary fees, deal with Client Queries, confirm fees and VAT queries to the relevant authorities, deal with any legal challenges which can take up to 6 years to be initiated, and for the Health and Safety of our staff. In terms of call recordings and Body Worn Video recordings we only retain these for 28 days, unless they are being used to investigate a complaint.

8. Providing Us With Your Personal Data

We receive sufficient information about you from our Local Authority Council Clients to allow us to enforce the Court Orders and debt we are instructed to collect. Where we request extra information from you such as financial circumstances, evidence of vulnerability and contact details such information is requested to assist us in our statutory duties and to assist us to follow the appropriate Regulations. If you do not provide us with information we request will have to make decisions on the limited information we have.

9. Your Rights and Your Personal Data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

10. Transfer of Data Abroad

We do not transfer personal data outside the EEA.

11. Automated Decision Making

We do not use any form of automated decision making in our business with actions undertaken being determined by rules and not of an autonomous nature

12. Further Processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to Make a Complaint

To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer, 6 Europa Boulevard, Birkenhead. CH41 4PE.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.