What Information do we collect?

The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or where we’re required to collect the information to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.

This will likely include the collection of:

• your personal details (e.g. name, date of birth)
• address details
• contact details (e.g. phone number, email)
• special personal information* (e.g. health information)
• financial information
• employment information
• information on how you use our website(s) and products and services

Special personal information*

Data protection law defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you. For example, a period of ill health could have been the initial reason that you chose to contact us for advice.

Where we need to collect and process this type of data about you, by providing this information to us you give your explicit consent for us and any other third party to process this special data as set out in this privacy policy, unless we have a legal obligation to process this type of data.

Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.

Information about other people

If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, an interlocking Individual Voluntary Arrangement), your personal information and any information about the service provided to you will be shared with the other person.

We will use the personal information about the other person in the ways as described in this privacy policy.

How do we collect your personal information?

We collect your information in a number of ways.

• When you make an enquiry to us either by phone, email, our website, by a third party or by any other means
• Information received from a third party, for example a creditor providing information about an account you hold with them, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company
• When you participate in market research, competitions and promotions provided by us, or on our behalf
• By adding reviews or interacting with us using social media such as Twitter or Facebook etc
• When you use online platforms, such as an online portal
• When we may need to obtain up to date information about you to meet our legal or regulatory obligations
• Where you have given permission for your information to be provided to us

How we use your personal information?

We can only use your personal information where it falls into one or more of the following categories:

• It is necessary to enter into or fulfil a contract we have with you;
• You have provided your consent;
• We have a legal or regulatory obligation to do so;
• It is necessary to carry out a task which is in the public interest;
• It is necessary to protect your vital interests; or
• It is in our legitimate interest to do so and it is not against your rights.

Initial Advice

Where you make an enquiry for one of our services, we’ll use your information to provide you with appropriate information about any solutions we may be able to offer to you. If you cannot provide this information we may not be able to progress with your enquiry.

We may also use this information to contact you about and process your application, for example, sending you an email, text message or letter to welcome you to our services.

We will process the personal data we collect about you for the purposes set out below at ‘Purposes for Processing your Personal Data‘.

After you have made you initial enquiry, if you also decide to go ahead with any of the services that we offer, the sections below explain how we will also process your data when we provide that particular service(s).

Ongoing Services

Where we are providing you with a service, such as a Creditors Voluntary Liquidation or an Individual Voluntary Arrangement (IVA) we will process your personal information to administer the services we provide. This may include contacting you where we may need further information, or sending you updates on the progress of the services we provide to you.

Where we provide ongoing services, we will normally require you to agree to the terms of engagement of the service. These will set out how we will provide the services to you and where we will be required, under the terms and conditions, to process your personal information. For example, we would need to your share information with your creditors to enable us to set up and administer your IVA.

Please read the section(s) relevant to the specific products and services you receive from us.

Individual Voluntary Arrangement

If you enter into an Individual Voluntary Arrangement (IVA), the table below specifically explains how and why your personal data will be used so that the services can be provided to you.

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 use information from your credit file to confirm certain information, including about your creditors, balances, account numbers, your account, address and insolvency history and details of any county court judgments (CCJ).
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.
	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 – 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.
	After this time, we will delete the information or anonymise the data so that it cannot be linked back to you

Creditors’ Voluntary Liquidation

Who do we share your information with?

In addition to the companies, organisations and other third parties set out in Section 3, we may also share your personal information with the following organisations:

• IT Service Providers who provide IT platforms or other IT services
• Payment Service companies that process transactions for us (e.g. Direct Debits and card transactions)
• Communication providers (e.g. telephone line providers, and email and text service providers)
• Printers who print the letters and information packs which we send to you
• Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account
• Third parties who may have introduced you to our services

These companies help us to provide our services to you. We will have a contract in place with any provider who directly provides us with such direct services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.

We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

• Fraud Prevention Agencies

The personal information we have collected from you may be shared with law enforcement agencies and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information is used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us or email us at

• Social Media

We may use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms you should be aware that:

• The social media web pages are publicly available and you must not provide any personal or sensitive information on our pages that are accessible to the public, such as your account information. We may ask you for your account information via a private message to identify you and to service any request you make; and
• Each social media platform will process any personal information you provide through the platform and will be processed in accordance with its own privacy policy. The privacy policies are available to view on each social media platform.

• Sharing your information outside of the EEA

We will only share your personal information outside the European Economic Area (EEA), where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the EEA.

If we do share your information outside of the EEA we will make sure that it is protected in the same way as if it was being used in the EEA to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as the EEA (this may include defined model clauses), or only share the data to a business partner in a non-EEA country where the privacy laws provide the same protection as within the EEA or where they are part of a Privacy Shield.

More information on this can be found on the European Commission Justice Website.

• Security

We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

• Company security policies and standards
• Staff security awareness
• Role based access controls to prevent unauthorised access to the information
• Encryption and anonymisation technology
• Anti-malware technologoies
• Security monitoring
• Compliance with industry regulation and legislation

How we may contact you about the products and services we provide to you

To help us keep you up to date about the products and services that we provide to you, and to ensure that you’re kept fully informed, we may contact you by letter, telephone, email, text message, push notifications, social media or may send you messages by any online customer platforms or other electronic means.

If you start an enquiry for a service through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason.

If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing a service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.

It is important that you keep us up to date when you change your contact details to ensure that we use your up to date contact information.

Your Rights

Access to your personal information

You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as set out below. Up until 25th May 2018, we may charge you up to £10 to provide you with this information, but after this date we won’t charge you to provide you with this information.

Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it were you have given your agreement.

Right to have your personal information corrected

If the personal information we hold about you is incorrect you have the right to request that we correct this.

Right to stop or limit the processing of the data we carry out

You may request that your personal information is deleted or that we stop processing the information if we’re no longer entitled to process it. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations. We will however discuss this with you if you request for your information to be deleted.

Portability

In some cases you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically by you or the other company. If you want to request this you’ll need to contact us.

How long do we keep your personal information for?

Whilst you continue to be our client, 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 personal information to meet our legal and regulatory obligations. The product specific information above sets out how long your personal information will normally be kept for. If you do not go ahead with any service offered by JT Maxwell Ltd, your personal information will normally be deleted after 2 years unless we have another reason to keep your data, for example, if you have given your consent to receive marketing or promotional messages from us.

How we may contact you about other products or service that we may offer?

If you have provided us with your consent or where we are legally entitled to do so, we may contact you to let you know about other offers, products and services that we provide which we think you may be interested or that may benefit you. We may do this through post, emails, text messages, telephone, push notifications, social media or other electronic means.

You can easily let us know at any time if you would no longer like to receive these messages. You can contact us using the details below, emailing us at info@jtmaxwell.co.uk.

Other types of advertising

When you visit our website or similar websites, Google may use our advertisements promoting our products and services which may appear on other third party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found below.

Cookies

When using this website, some information may be collected automatically using ‘cookies’. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used. Cookies can be temporary or permanent.

Temporary cookies form part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.

Why are cookies used?

They help visitors. Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off – this won’t stop a website from working, but it might mean it won’t work as well as it could, or that you have to do the same thing more than once.

They help website owners. Cookies tell website owners things like: what search engine a visitor used to find the website, how often they’ve visited it, how long they’ve spent on it, and so on.

We’ve set out below the cookies that we may use and those that are set by third parties on our website.

Cookie	Name	Purpose	More Information
Bing Ads	mui(x), _uet(x)	Remarketing script and conversion tracking
Google Analytics	_utm(x), _ga(x), _gid, amp_token	These cookies are used to collect information about how visitors use our website. They keep track of when a visitor enters and leaves the website and any search engines and keywords that are used, including any personal and/or special categories of data.	Click here for more information about google analytics and how to disable this cookie.
Offline Asset	OfflineAsset	These cookies are used to assist in call tracking. This enables us to relate a web site visitor to inbound calls.	Click here for more information about google analytics and how to disable this cookie.

Contact Us

If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer using the address or email below:

DPO
JT Maxwell Limited

Unit 6 Lagan House
1 Sackville Street
Lisburn
BT27 4AB

Email: info@jtmaxwell.co.uk

If you are not happy with how we process your personal information you should contact us in the first instance. If you’re not happy with how we have dealt with your complaint you have the right to lodge a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/