What personal data will we need to collect?

To be able to provide our services we will need to collect certain categories of personal data. This will include:

• Contact details – so that we can regularly contact you where we need to and update you about your IVA
• Your Income and expenditure – – so that we can accurately work out what you need to pay into your IVA
• The people you owe money to and your property and assets – so we can properly supervise your IVA and advise you what you need to do to complete your arrangement
• Personal circumstances – such as your employment, living arrangements and financial dependents, so that we can understand how any change in your situation affects your IVA
• Special personal information – only with your permission and where this is relevant to your financial situation and the administration of your IVA, or where we have a legal right to do so
• Financial details –we need this information to be able to collect your regular payments for your IVA.

This is required to enable you to enter into an IVA and to fulfil our contractual obligations with you, and to fulfil our legal and regulatory obligations.

With your permission, we may obtain and use information from your credit file to confirm certain information, including about your lenders, balances, account numbers, your account, address and insolvency history and details of judgments made against you (e.g. CCJs). Your credit file data will be provided by Callcredit Limited (trading as TransUnion), subject to passing their authentication process. For more information about how TransUnion uses and shares your credit file information, please click here.

Who will the data be shared with?

Your personal information will be shared with creditors, debt collectors and voting agents dealing with the debts included within your IVA. This is a key part of the services we’ve contractually agreed to provide to you.

If your IVA is accepted, information about you and your IVA will be shared with the Insolvency Service and will appear in the publicly accessible Individual Insolvency Register maintained by the Insolvency Service.

We will share your information with a claims management company, HD Law, to assess whether there are any other potential assets that could be made available to your creditors. HD Law will not act for you as a claims management company unless you instruct them and will provide a report to your Supervisor after they have completed the review.

If your payments to the IVA are covered by payment protection insurance or the Income Safeguard Plan, or your IVA is included in our IVA Cover life policy, we will tell the Policy Administrator, as relevant, about changes affecting your level of cover, the premiums payable or claims you or we may make.

Our regulators, such as the Insolvency Practitioners Association, the Information Commissioners Office or any other regulatory body or authority may request certain information as part of supervising us. We would have a legal or regulatory obligation to provide this.

Your personal data may be shared with tracing agents where we have a legitimate interest to obtain up to date contact information to help us to continue to provide the services to you.

If you have provided your authority or we have a legitimate interest to do so, or where we may be legally entitled to, we will share information with credit reference agencies (CRAs) to obtain information about your financial history or your credit commitments.

For further information on how CRAs may use your personal information you can view the Credit Reference Agency Information Notice here or from the three main CRAs – TransUnion (formerly Callcredit); Equifax; and Experian.

How long will your data be stored for?

If you continue to be our customer and we give you advice, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your data to meet our legal and regulatory obligations. This will normally be kept for at least 6 years, starting from the date when we are no longer providing you with a service. Telephone calls will be retained for at least 6 years from the date the call was made.

If you do not go ahead with any product or service offered by the Group, your personal information will normally be deleted after 2 years (except for any recorded telephone calls) unless we have another reason to keep your personal information, for example, if you have given your consent to receive marketing or promotional messages from us.

After this time, we will delete the information or anonymise the data so that it cannot be linked back to you.