What personal data will we need to collect?

To be able to provide you with Breathing Space we need to collect certain categories of personal data. This will include:

• Contact details – so that we can contact you where we need to and update you about your Breathing Space.
• Your Income and expenditure – to evidence that you are eligible for Breathing Space and so that we can process your Breathing Space.
• The people you owe money to – so we can properly set up and process your Breathing Space application.
• Personal circumstances – such as your employment, living arrangements, property, assets and financial dependents, to process your Breathing Space and to give you advice about your next steps.
• Special personal information – only with your permission and where this is relevant to your financial situation and to process your Breathing Space, or where we have a legal right to do so.

This is required to enable you to enter into a period of Breathing Space 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 TransUnion International UK 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 the Insolvency Service and your lenders who you owe money to so that we can process your application and arrange for your Breathing Space. This is a key part of the services we’ve agreed to provide to you.

Our regulators, such as the Insolvency Service, the Financial Conduct Authority, the Information Commissioner’s Office or any other regulatory body or authority may request certain information as part of supervising us. We 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.

We may share your personal information with the Money Advice and Pensions Service to meet our obligations to you in relation to the services we provide.

We will share your personal information with other companies whose services we need to use so we can provide our services to you. This will include IT service providers, professional advisers and insurers, communication service providers, printers, advertisers and social media platforms. We’ll only share your information with them if they’ve agreed to keep it confidential.

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; Equifax; and Experian.

How long will your data be stored for?

Whilst you continue to be our customer, we will keep a record of your personal data to ensure that we provide you with the best service possible and where we’re required to keep your personal information 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. We will retain telephone calls for at least 6 years from the date the call was made.

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