If you use our full and final settlement service, it will be provided by Gregory Pennington Limited. The table below specifically explains how and why your personal data will be used so that this service can be provided to you.
What personal data will we need to collect?
To be able to provide you with our full and final settlement service, 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 keep you updated
- The people you owe money to – so we can advise you about settling your debts and to negotiate with and make payments to your creditors
- Personal and financial circumstances – such as your income and expenditure, employment, property, assets, living arrangements and financial dependents, to understand your situation and advise you about settling your debts, and to help us try to agree full and final settlement terms on your behalf
- Special personal information – – only with your permission and where this is relevant to your financial situation and how we administer our services, or where we have a legal right to do so
- Financial details – we need this information to be able to collect your payment.
This is required to enable you to enter our full and final settlement 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 the full and final settlement process. This is a key part of the services we’ve contractually agreed to provide to you.
Our regulators, such as 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.
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.