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 DPP
• Your Income and expenditure – so that we can accurately work out what you can afford to pay towards your DPP
• The people you owe money to – so we can properly administer your DPP
• Personal circumstances – such as your employment, living arrangements, property, assets and financial dependents, to carry out your regular reviews and advise how any change in your situation affects your DPP and whether it is still the right solution for you
• Special personal information – only with your permission and where this is relevant to your financial situation and the administration of your DPP, or where we have a legal right to do so
• Financial details – – if we, trading as Think Link are appointed to be the Payment Distributor for your DPP, to collect the regular payments to your DPP.

This is required to enable a DPP to be entered into 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 and debt collectors who you owe money to so that we can arrange a payment arrangement under your debt arrangement scheme. This is a key part of the services we’ve contractually agreed to provide to you.

We will submit your DPP application to the DAS Administrator for approval.

If your DPP is approved, your details will be published on the publicly accessible DAS Register, maintained by the Accountant in Bankruptcy.

We will pass information about you and your approved Debt Payment Programme to the Payments Distributor appointed to deal with the payments due into your DPP.

If your plan is covered by payment protection insurance or the income safeguard plan, we will tell the Policy Administrator about changes to your level of cover, the premiums you have paid or claims you may make.

Our regulators, such as the DAS Administrator, the Information Commissioner’s 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?

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. Telephone calls will be retained 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.