Medina Credit Management Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all our debtor account holders and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Medina Credit Management Limited.
Limited and registered in England under company number 5652912
Registered address: Oyster Hill Forge, Clay Lane, Headley, Surrey KT18 6JX
Main trading address: Carlton House, 19 West Street, Epsom, Surrey, KT18 7RL
Data Protection Registration Number: Z9346052
Data Protection Officer: Mrs A Taylor
Email address: email@example.com
Telephone number: 01372 726081
Postal Address: Carlton House, 19 West Street, Epsom, Surrey, KT18 7RL
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is to inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. we do not use your personal data in this way. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We are provided with by our clients or, may collect some or all of the following personal data from you:
- Unique client reference number;
- Date of birth;
- Email address;
- Telephone number(s);
- Details of debt(s) and Payment information;
- Statement of debt;
- Details of or recordings of contact with you
Your personal data is obtained from the following third parties:
- Credit Safe
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with our clients for the recovery of a debt outstanding to them. Because you have consented to the use of your personal data, or because it is our legitimate business interests to use it. Your personal data will be used for the following purposes:
- Recovery of a debt outstanding to our client.
- We will allocate our own unique reference number on receipt of the data from our client.
- Providing and managing your debt account.
- Communicating with you, this may include responding to emails, correspondence or calls from you.
- Supplying you with information by email and/or post about the debt owed. You may elect at any time which of these methods is best for you.
- With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and or telephone and or text message and or post with information about your debt.
- You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
- We will not use your personal data for any marketing or sales.
- We use the following automated systems for carrying out certain kinds of debt recovery processing or decision-making. If at any point you wish to query any action that we take based on this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more using the details in Part 11.
- The following automated decision-making method(s) may be used: o Where you have not responded to debt recovery contact a further letter(s), text or phone call may be made in follow up.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
- Financial information including identifiers, payments made and remitted on accounts to our clients will be held for up to 6 years.
- Accounts on which we have not collected any financial payment information will be held for up to 24 months.
8. How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR. More information is available from the European Commission. Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- Your data is encrypted where transferred as part of our payment processing.
- Clients may provide data in a protected format for controlled access.
- Clients may use third party encryption tools to secure your data and control access to it.
- Provide reporting to our clients to a name individual only.
- Your data will form part of our back up processes.
9. Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception. In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of our client as the data controller to request a copy of it (where any such personal data is held). This is known as a “subject access request”. All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. This request will be passed to our client for action and the data we hold about you will be provided as part of the action taken by them.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding. We will respond to your subject access request within 1 week advising of the client it has been passed to and, in any case, not more than one month of receiving it. Normally, we aim to provide a copy of your personal data to our client within that time.
In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Mrs E Taylor:
Email address: firstname.lastname@example.org
Telephone number: 01372 726081
Postal Address: Medina Credit
19 West Street,
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available at www.medinacredit.com