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Privacy Notice

Privacy Notice

Information applies from the 25th May 2018

Our Privacy Promise to you:

  • We promise to be fair and transparent
  • We treat the security of our customers' data seriously
  • We believe in integrity and respect your privacy

What does this mean for you?

Our privacy notice provides you with information about how we use your personal data, which we are required by law to give you. Each section sets out different information – you can use the following list to choose which sections of our Privacy Notice you want to read:

  • Our identity as a data processor and our contact details
  • Types of personal data we collect and how we collect it
  • The legal basis on which, and the purposes for which, we are processing your personal data
  • How long we keep your personal data for
  • Who we share your personal data with
  • Credit Reference Agencies
  • How you can manage your personal data
  • Cookies
  • How to complain

We set out how your personal data will be used by members of Orbit Debt Collections as a data processor, as advised below. You can contact our Group Data Protection Officer (DPO) at: PO Box 92, Malton, YO17 1BN or alternatively by email at:

[email protected]

Occasionally we will need to tell you how we will process specific information you have provided to us, we will do this by providing a notice at the time we receive or obtain personal data.

1. Who are Orbit Debt Collections?

Orbit is the data processor of your personal data. We work in the Utilities sector on behalf of our Clients.

To find out more about the Orbit Debt Collections including who we work with then visit us at:

http://www.orbitservices.co.uk/

2. What types of personal data do we collect and how do we collect it?

Types of personal data we collect

The types of personal data that we collect are outlined below:

  • Personal Data - Personal data is information that can be used to identify you as an individual such as name, address and contact information, IP address
  • Financial Data - Financial data is information from your credit file, income and expenditure data, account information and any other information relating to your ability to repay your account

Special Categories of personal data:

Some categories of personal data are more sensitive, these are known as special categories of personal data for example:

  • Racial, Ethnic origin
  • Biometric data
  • Religious beliefs
  • Data concerning heath, sexual orientation

If you ever disclose this type of personal data to us we will only keep this on record if it is necessary for the services we are providing. Where we do need to keep this data, we will always request your explicit consent to record and store this information. We will only store this data for as long as it is relevant and will check this with you periodically. You have the right to withdraw your consent and if you do, we will delete the special category data from our records.

If you disclose special category personal data to us without us having the opportunity to obtain explicit consent, for example if you send a letter to us detailing your medical situation, you will have given your consent for us to process that data.

Where we consider it necessary to record the special category personal data you give to us, we will securely record this information and tell you in writing how we will use it and how you can withdraw your consent.

How do we collect your personal data?

We collect your information in the following ways:

  • We obtain data from the owner of your account (the utility provider)
  • We keep records of correspondence between us, including letters, email, SMS, and any social media communications
  • We record phone calls and field visits between you and our staff for training and monitoring purposes and to improve and enhance the service we offer you.
  • When you use our website we collect information concerning your usage of the website, behavioral patterns, which pages you viewed, traffic data and the originating domain name of your internet service provider
  • We operate CCTV at our business premises, if you were to visit one of our offices your image could be captured on CCTV
  • We access third party data sources and combine and process data from those sources with your personal data. Examples of such third party data sources include Credit Reference Agencies (CRAs), registers of court judgments, bankruptcies, postcode lookup databases and telephone number verification databases.

3. How we use your personal data

We use your personal data:

  • To help us service your account
  • To manage our operations and improve our service to you
  • To manage security, risk and crime prevention
  • To meet our regulatory requirements
  • To undertake statistical analysis for business improvement

In order to process your personal data we need to have a justified legal basis, this means that processing your personal data must be necessary for one or more of the following:

  • To comply with a legal obligation
  • Where we have a legitimate interest
  • To perform a contract that you are party to
  • When you give us your consent
  • To protect your vital interests

The table below sets out the lawful bases that we rely on to process your personal data.

Business Process

Our lawful basis for processing

How do we use your data?

Debt recovery

Performance of a contract

Legitimate interests

Compliance with a legal obligation

As a business, our core operation is the recovery of an outstanding balance or to collect data in order to ensure that correct charges are levied to the correct individuals and to support vulnerable customers. As part of our process we would need to perform trace and debt recovery activities; validate your identity, contact you in writing/email/SMS and telephone, agree payment arrangements, process payments and where appropriate take enforcement action.

Management of your account

Compliance with a legal obligation

Legitimate interests

Performance of a contract

As a business, we have an obligation to manage your account.  We have a legitimate interest in understanding your ability to repay the outstanding balance as well as how best to communicate with you; in order to do this at times we will use scoring/statistical analysis and automated processes to make decisions about how best to engage with you.

Training, monitoring and improving our service

Compliance with a legal obligation

Legitimate interest

In order to ensure we provide the best service we can, we use recordings of telephone calls/field visits, which will contain personal data of our customers, to train staff. We may choose to ask another company to contact you to request feedback enabling us to review the service you’ve received and to make improvements where necessary. We monitor your website usage, collecting info to improve our service, business efficiencies and, statistical and analytical activities.

Complying with Legal and

regulatory requirements

Legitimate interests

Performance of a contract

Compliance with a legal obligation

At times we share data with other third parties where we have a legal or regulatory requirement to do.

4. How long we keep your personal data

We will keep your personal data for as long as you have an open account with Orbit.

We will keep your personal data for 6 years and 3 months from when our relationship with you comes to an end, in order to respond to any complaints or queries, comply with legal and regulatory obligations to keep certain records.

5. Who we share your personal data with

At times we will need to share your personal data with other companies:

  • Other companies that may help us to validate that the data we hold is accurate or to obtain new information - for example a new telephone number
  • Your original creditor
  • Suppliers and service providers - for example companies that provide us with an IT, infrastructure or mailing service
  • Any person or company that you instruct us to liaise with - for example, a friend, family member, representative or a Debt Management Company

Whenever we engage with a third party we ensure that the third party has a similar level of safeguards and controls in place before sharing your personal data with them.

6. How can you manage your data?

Managing your account

You can manage your account by speaking to our call center team on 01653 604 434 who are able to look into your account, keep you up to date on any changes and advise you of what data we hold.

Your rights

Object to processing

You have the right to object to us processing your data if the processing itself is an unwarranted interference with your interests or rights. You can find out more about how and why we process your personal data in section 3 ‘How we use your personal data?’

If you still believe that you have a valid and justifiable reason to exercise this right you can contact us on the details below.

Restrict Processing

If you believe we are processing your personal data unlawfully or you believe that we no longer need your personal data you have the right to request that we restrict the processing of your personal data.

Right to be forgotten

Under data protection legislation you have the right to request that we delete your personal data if you believe we no longer have a lawful basis to process it. If you feel that we should not be processing your personal data you can submit a request on the below details.

Email: [email protected]

Right to rectification

Upon obtaining personal data we conduct checks to validate that it is accurate as we are reliant on you and other third parties to provide us with correct information. If you believe that any of the personal data we hold for you is incorrect, it is important that you make us aware as soon as possible, for example if you have a new phone number or have moved address.

Email: [email protected]

Your right to portability

You have the right to request that we transfer personal data you have provided to us either to yourself or to another data controller. You can exercise the right to data portability by contacting us on the below details:

Email: [email protected]k

Writing: PO Box 92, Malton, YO17 1BN

Accessing your data

You have the right to see the personal data relating to you that we hold.

We take the protection of your personal data seriously, so we reserve the right to request proof of your identity before supplying any personal data.

Once we have validated your identity, we will respond to your request within one calendar month. We typically will send your personal data on an encrypted disk, if however you wish to receive it in a different format for example, as a printed document then please let us know.

In order to make this request please contact us on the below details:

Writing: PO Box 92, Malton, YO17 1BN

Email: [email protected]

Call:   01653 609 441

7. Cookies

Our website operates and collects cookies. A cookie is a small file that is placed on your computer’s hard disk which may be placed for several reasons, for example:

  • Google analytics, such as analysing the traffic to the website and to speed up access to the website.
  • Targeted communications that help us to guide you back to specific pages within our website, or reach you via third party websites

We will always ask you on the homepage whether you want us to place a cookie on your computer. The vast majority of web browsers accept cookies, however you can manually change your browser settings so that cookies are not accepted. If you do this, you may lose some of the functionality of our website. For more information about cookies and how to disable them please go to: www.aboutcookies.org

We can confirm that any cookies placed by us shall not store or collect any personally identifiable information.

8. How to complain

If you would like to make a complaint or have a query about how we use your personal data, you can contact us on the below details:

Email: [email protected]

In writing: PO Box 92, Malton, YO17 1BN

If you are unhappy about how we have handled your complaint you have the right to complain to the Information Commissioners Office:

Website: https://ico.org.uk/concerns/

Call: 0303 123 1113

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