Introduction
This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we will store and handle that data, and how we will keep your data safe.
The purpose of this notice is to inform you of how we use your data and keep you fully aware of your rights.
It will be necessary, from time to time, to update this Privacy Notice. By coming back to this notice, at any point, you will see the updated Privacy Notice.
Who we are and what we do
Rundle & Co Ltd (Rundles) are one of the leading providers of ethical enforcement services to the public and private sector, we specialise in prompt recovery of debt including Council Tax, Business Rates, Road Traffic and Commercial Rent.
The Legal bases which we rely on to collect, store and use your data
Legal Obligation
Providing debt collection services. Your data is used to enable us to make contact with you and to allow Rundle & Co Ltd, on behalf of the Local Authority, to consider and make considered decisions when resolving your case. This also includes allowing us to make considered decisions when using special category data that we have collected from you, for example, medical information.
Legitimate Interests
We use Body Worn Camera’s in order to protect both our agents and customers. Rundle & Co is the controller of the data and processes it under the basis of Legitimate Interest. The camera footage is encrypted and stored on a secure server, viewable only when a complaint is made by the debtor or agent by senior management.
When do we collect your personal data?
- When we make contact with you from our contact centre
- When you make contact with our contact centre
- Through any written correspondence that you send to us either via email or through regular post or via courier
- When one of our enforcement agents visits you or makes contact with you
- When you make contact with one of our enforcement agents
- Through our website using the Contact Us options
- Through a third party that is acting on your behalf
What sort of data do we collect?
We collect the following types of information to assist us with the collection of debt and decision making:
- Names
- Addresses
- Email Addresses
- Telephone Numbers (landline and/or mobile telephone)
- Date of birth
- National Insurance number
- Occupation details
- Income details (including details of benefits)
- Special types of data – Medical details and/or vulnerability details
- Vehicle Identification Numbers (VIN) or Registration Mark
- Your image may be recorded on body worn cameras if visited by one of our enforcement agents, this may collect personally identifiable data in the process of image capture. (please note that camera technology is not used in any way in the process of enforcement of debt. They are used as a protection measure).
How and why we use your personal data
We want to make the whole experience as easy as possible for you, as much as us, in the collection of any debt that has been passed to us for collection from you.
- We use any data, collected from you or any that is passed to us from the creditor (e.g. Local Authority), to allow us to make contact with you and to enable us to understand your circumstances and make informed decisions based on all of the data provided and held. We also base these decisions on the terms of the contract with the Local Authority.
- We use your information to assess queries and complaints.
- We use special types of data to assess areas such as vulnerability and capacity to pay, enabling us to ensure that we can undertake each case uniquely and fairly.
- We use your data to protect our business and your account from fraud and illegal activities. When you call us, for example, we always ask a series of questions to establish the identity of who is calling before we start talking details.
- To protect both you and our enforcement agents we may use body worn video capture equipment. We do not, however, use this video capture as part of our debt collection process. It is for protection of the debtor and enforcement agent only. This video capture technology may collect, in the process of its use, personally identifiable data.
- To comply with our contractual or legal obligations, in some instances we will share your personal data with law enforcement.
Within the bounds of our obligations to our clients and current legislation you may have the right to change or ask for certain types of data to be removed. You will find more details in the section entitled What are my rights?
How we protect your personal data
We fully understand our obligation to keep your personal data safe at all times. We take great care with your data at all times and have invested over many years to ensure that we do so.
- We secure all of our contact areas of our website using ‘https’ security.
- Access to your personal data is always protected with a password and is secured using encryption whilst we store your personal data.
- We do not store any data outside of the UK.
- We regularly monitor our system for possible vulnerabilities and attacks, and we carry out regular penetration testing to identify ways to further strengthen security.
- Our members of staff are regularly trained in the safe handling of data.
How long will we keep your data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
Who do we share your data with?
We do not share data with third parties other than those required in assisting the fulfilment of the requirements of a contract. These may be:
- The originator (Controller) of the debt
- Credit reference and tracing agencies including Experian Ltd, TransUnion International UK Ltd and Equifax Ltd. See links below for their privacy notices:
https://www.experian.co.uk/legal/privacy-statement
https://transunion.co.uk/legal/privacy-centre
https://www.equifax.co.uk/ein.html
- Driver and Vehicle Licencing Agency (DVLA)
- Companies House
- GB Group Plc, Data OD Ltd, UK Search Ltd for tracing, address cleansing and telephone appending
- Cardstream Ltd acting as a credit and debit card processor
- Global Payments and Ingenico for the processing of PDQ payments
- Ecospend for the processing of Open Banking payments
- Adare SEC Ltd for the provision of correspondence and mailing services
Where personal data is passed to any of these organisations, if we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
Locations of processing of your personal data
We do not process any of your personal data outside of the European Economic Area (EEA). All data is processed within the United Kingdom.
What are your rights with regards to your personal data?
You have the right to request:
- To be informed that we are processing your personal data and what it is used for, as detailed above.
- Access to the personal data we hold about you, free of charge in most cases.
- The rectification of your personal data when incorrect, out of date or incomplete.
- The right to object to us processing your personal data and have the right to have it erased or have processing restricted where we use the basis of legitimate interest i.e. when we are recording using body-worn cameras.
- As we process data under the basis of Legal Obligation and Legitimate Interest you do not have the rights to data portability
You have the right to request a copy of any information about you that Rundle & Co Ltd holds at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact:
The Data Protection Officer, Rundle & Co Ltd, 53 Northampton Road, Market Harborough, Leicestershire LE16 9HB or email [email protected]
To request for your information to be updated please call 0800 081 6000 or email [email protected]
If we choose not to action your request we will explain to you the reasons for our refusal.
Contacting the regulator
If you feel that your personal data has not been handled correctly or you are not happy with our responses to any requests you have submitted to us with regards to the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
Their contact details are as follows:
Telephone: 0303 123 1113
Online: https://ico.org.uk/concerns