Hewitt & McLeod Ltd takes your data privacy seriously. We are independent debt recovery partners and focus on working together to deliver improvement to your cashflow. In order to provide you with our services we collect and use personal data which means that we are a ‘Data Controller’ and we are responsible for and committed to complying with Data Protection Laws and the General Data Protection Regulations (GDPR).
In this Privacy Notice, we want to inform you about what information we collect, how we use it and what rights individuals have in relation to the collection and processing of their personal data.
Our Contact Details:
Hewitt & McLeod Ltd
Tel: 0141 266 0163
If you have any questions in respect of this Privacy Notice or how we manage your personal data, please contact:
Hewitt & McLeod Ltd
Contact Details as above
What personal data does Hewitt & McLeod Ltd collect and process?
We collect the following types of data:
- General contact details such as, Name, Address, email address, Telephone number
- Business Activities of the person whose information we are processing
- Details of Goods and Services provided to you
- Contact details of Third Parties such as clients or individual debtors
- Financial Details – such as credit history or payment or bank details
- Financial Details of third parties – Payment, account balance and credit details of parties subject to a debt recover procedure
- Your marketing preferences
Special Categories of Personal Data that we collect:
We do not collect, process or store Special Categories of Personal Data
How we collect your information
In most cases we collect your data directly from you. We collect data and process it when you:
- Complete an online ‘contact us’ form
- Provide information during a meeting on site or virtual
- Speak to us on the telephone to discuss or use our services
- Email or write to us to enquire about or use our services or provide feedback
We also receive your data indirectly from the following sources:
- Social Media Sites including LinkedIn
- Public sources – demographic data, Market Research
- Credit Agencies and publicly available company data
- Or if you are an individual who is or who’s organisation is subject to a debt recovery procedure and your personal data has been provided to us by one of our clients. In such cases, we provide you with access to this privacy notice to ensure that you are provided with our contact details, purpose for processing and categories of personal data which we are processing.
Why do we collect your information?
Where we collect and process personal data, we identify both the purpose and legal basis for doing so. There are 6 possible legal bases which are:
Consent – where we have consent from the individual to the processing of his or her personal data for one or more specific purpose
Contract – where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Legal Obligation – The processing is necessary for compliance with a legal obligation to which we are subject
Vital Interests – Where the processing is necessary in order to protect the vital interests of the data subject or another natural person
Public Interest – Where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
Legitimate Interests – Where the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal date, in particular where the data subject is a child.
Our purpose and legal basis for the information we collect, and process allows us to:
To understand your requirements prior to entering into a contract of service with our customers
The processing is necessary for the performance of an anticipated Contract
To understand your requirements to ensure that any contract of service meets our customer’s needs
The processing is necessary for the performance of a Contract with you
To fulfil our contract with you and provide you with the agreed services therein
The processing is necessary for the performance of our Contract with you
To manage our business operations and comply with any internal policies and procedures
It is in our legitimate interests to use your personal information to ensure that we provide and adapt our services
To trace, pursue and recover debt payments on behalf of our clients in line with our debt recovery service
It is in our legitimate interests to use your personal information to contact you in relation to recovering a debt owed to our client.
To notify our customers of amendments to debtor contact details
It is in our Legitimate interests to notify customers of amendments to contact details of their debtors to support the right of accuracy.
To notify you about changes to our service
It is in our Legitimate Interests to use your personal information to keep you informed about any changes that may affect you
For Marketing of similar services to existing customers
It is in our legitimate interests to use your personal information for marketing purposes where the services being marketed are relevant to you.
For electronic Marketing of services to new customers via personal business email addresses
It is in our Legitimate Interests to use personal business email addresses for marketing purposes where we can support individual’s rights
For electronic Marketing of services to new customers
We rely on Consent for direct marketing to individuals
To comply with our legal obligations, law enforcement, court and regulatory bodies requirements
To comply with our Legal Obligations
To identify and prevent fraud
It is in our Legitimate Interests to act as a responsible business
Where we rely on your consent you have the right to withdraw this consent at any time by contacting our Data Protection Officer.
Legitimate Interests – Where the processing of personal data is based on our Legitimate Interests, it is to deliver and improve on our service and security and maintain accurate records. It is also in an aim to prevent fraud or illegal activity in favour of the wellbeing of our customers.
Who we share your information with?
From time to time we may share your personal information with the following third parties for the purposes set out above:
- Payment Services Providers
- Lawyers and other professional services
- Specialist Experts for example, Marketing Companies, where we have a lawful basis for doing so, Compliance Consultants, Web Service providers
- Cloud storage providers
- Fraud detection Agencies
- Police and Law Enforcement agencies where reasonably necessary for the prevention or detection of crime
- Credit Reference Agencies
- Regulators and governing bodies such as HMRC in respect of employment & Payroll data
- Selected Third Parties in connection with any future sale, transfer or disposal of our business
International data transfers
Some recipients of your personal data can be located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. When transferring personal data to such recipients, we provide appropriate safeguards.
We can use software processors which can share data outside of the EEA including the U.S. We always review our providers to ensure that additional safeguards are in place including Adequacy decisions and where relevant Standard Contract Clauses.
Automated decision-making or Profiling
We do not process personal data for automated decision making or profiling
How Long do we keep personal data for?
The following details the criteria used to establish the retention period set out within our policy.
Where it is still necessary for the provision of our Services
This includes the duration of any contract for services we have with you and for a period of 24 months after the end of any contract with a view to maintaining and improving the performance of our products, keeping our systems secure, and maintaining appropriate business and financial records. Where we process information relating to third parties who are subject to a debt recovery contract, we will retain this information for a period of 12 months after the debt has been settled for internal audit purposes. Most of our retention periods are determined on the basis of this general rule.
Where required by Statutory, contractual or other similar obligations
Corresponding storage obligations may arise, for example, from laws or regulation. It may also be necessary to store personal data regarding pending or future legal disputes. Personal data contained in contracts, notifications and business letters may be subject to statutory storage obligations depending on national law.
Your Rights as a data subject
As a data subject, you have rights in relation to your personal data. These are:
The Right to Access – You have the right to request details of personal information held or processed and to copies of this data. We do not usually charge for this service.
The Right to Rectification – You have the right to request that any information be corrected that you believe is inaccurate or to complete any information that you believe is incomplete.
The Right to Erasure – You have the right to request that we erase your personal information under certain conditions
The Right to Restrict Processing – You have the right to request that we restrict the processing of your personal data under certain circumstances
The Right to Object to Processing – You have the right to object to our processing of your data, under certain conditions.
The Right to Data Portability – You have the right to request that we transfer the data that we have collected to another organisation or directly to you, under certain conditions.
You also have the Right to Withdraw Consent where you have previously provided this at any time.
To exercise any of these rights, or if you have a complaint please contact:
Hewitt & McLeod Ltd
You also have the right to complain to the Supervisory Authority. Where you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office at:
Information Commissioners Office
Helpline: 0303 123 1113
Contractual Obligations and Consequences
In some circumstances, the provision of personal data is partly required by law (for example, tax regulations, employment and legal obligations) or can also result from contractual provisions. This means that it may sometimes be necessary to conclude or fulfil a contract, that the personal data be provided. In those circumstances where the data is not provided or where certain rights are exercised, (Erasure, Object) there is a possible consequence that the contract could not be fulfilled or concluded and may be cancelled.
Cookies & similar technologies
To learn more about how to manage your browser cookie settings in general please see www.allaboutcookies.org
When clicking on external links via our website, or finding us via social media platforms, you are visiting or redirected to the domain of those websites. We have no control over the privacy settings on these websites and the cookies they set, so please bear in mind that you should set your preferences in line with their own policies and cookie controls separately.
We aim to protect your personal data through technical and organisational security measures to minimise risks associated with data loss, misuse, unauthorised access and unauthorised disclosure and alteration.
We store customer records in cloud-based services and data centres which have controlled and restricted access. We operate records management and Information security policies which detail physical security, cloud storage security monitoring, access control and password security measures. We also maintain and use anti-virus and malware software and firewalls.
Changes to our Privacy Notice
Hewitt & McLeod Ltd keep our Privacy Notice under regular review. This Privacy Notice was last updated on 18th August 2020.