Privacy Notice
We take the privacy of your information very seriously. This notice explains how and for what purposes we use the information collected about you.
CFM looks after the information it holds about you, and respects your privacy. We take appropriate security precautions to prevent your information being lost or falling into the wrong hands. We make sure that the information we hold is as accurate as possible; we do not hold more information than we need; and we do not hold it longer than we need to. We keep records of all personal data that we process ensuring we have identified and documented a legal basis for processing the data. We do not share your data with anyone else without your permission, except when we believe it is the only way to prevent harm to you or other people. This privacy notice details the way in which we will treat your information, your rights in relation to it, and how we will ensure that your data is kept safe, secure and in your control. It will do this for all the ways in which you choose to access our service. If you have any queries about this notice or anything to do with how we treat your data, please get in touch with us by using the contact details at the bottom of this notice.
What Personal Information do we collect?
In order to provide our services under the contractual agreement, we collect ‘Personal Information (data)’ that uniquely identifies you. We explain below the information we collect and why;
– Personal descriptors – e.g. Name, address, age, date of birth, passport/driving licence or other identification documents
We require this to identify you and to communicate with you – You cannot opt out of providing this information.
– Financial information – e.g. Income, expenditure, assets, liabilities, bank details and statements, benefits details, wage slips, tax returns, default history, legal action or county court judgements, previous credit history, credit reference information, correspondence from creditors.
We require this to provide certain services, such as negotiating with creditors on your behalf. Not all of our services require us to collect this information however it is a contractual requirement for services such as an insolvency or debt management solution. You cannot opt out of providing this information.
– Employment information – e.g. Employment status, occupation, pay date, salary details, professional occupational status (e.g. Dr., Company Director, Police officer)
We require this to provide certain services such as to assess your eligibility for debt solutions.
Not all of our services require us to collect this information however it is a contractual requirement for services such as an insolvency or debt management solution. You cannot opt out of providing this information.
– Life information – e.g. Marital status, number of child dependants, dependants’ dates of birth, general household details
We require this to provide certain services, such as assessing what you can afford to pay towards your debts. Not all of our services require us to collect this information however it is a contractual requirement for services such as an insolvency or debt management solution. You cannot opt out of providing this information.
– Health information – e.g. Physical or mental disabilities
We may collect certain special category data to identify if you are potentially vulnerable or require further support.
You can opt out of providing this information.
How do we use your information?
The main lawful basis for processing your information is for the performance of the ‘contract’ as we cannot carry out our contractual obligations without processing your personal information.
On occasions our lawful basis for processing your information may change; for example, if it is necessary for your vital interests (e.g. to protect your life) or where we have a legitimate interest in processing your information (e.g. for statistical data purposes). However, where possible this is usually anonymised to safeguard it.
Our main purpose for processing your personal information is to provide the services you have requested us to provide to you as specified in the terms and conditions/contract. For example; If you require debt advice, an Insolvency or debt management solution we need to collect information to assist you with your financial difficulties. To collect special category information, or process your information for certain purposes (i.e. direct marketing) we require your explicit and informed consent. Where this applies it will be made clear to you.
Transferring and sharing your information
Depending on the service requested we may share your information with other parties (usually your creditors or their appointment agents) as without doing this we cannot carry out the service specified within the contractual agreement.
In accordance with our legal obligations we may be required to share information with the police, other law enforcement, government agencies or regulatory bodies.
You also have the option to appoint someone else to act on your behalf such as a spouse or carer with whom we can share your information. You will need to provide separate explicit consent for us to be able to share your information with them, and you can revoke this consent at any time.
How do we receive your information?
We may receive information directly from you, any third party you appoint to act on your behalf, legal parties, your creditors or their agents, your bank, credit reference agencies or law enforcement. In some cases, we may receive other information about you, such as details of a health condition from your health professional.
Occasionally we receive information from outside sources which are matters of public record regarding recent county court judgments. This information is only retained electronically for one month before being removed from our systems.
Website
If you use our website please be aware that we use cookies, which are text files placed on your computer to collect standard internet log information and visitor behaviour information. This is used to track visitor use of the website and to compile statistical reports on website activity. We may also collect your IP address, browser information, and use plugins that collect your information (e.g. Google Analytics and WordPress).
You can set your browser not to accept cookies and can find out more information in the links below. However, in some cases our website features may not function as a result.
For further information visit www.aboutcookies.org or ico.org.uk/concerns/cookies/
Other websites or services
Our website may contain links to other organisations and websites. This Privacy Notice only applies to Capital Financial Management Ltd. When you visit the websites of other organisations you should read their own Privacy Notice.
Your individual rights
You have the right to access your information at any point and can check what information we hold and process about you by contacting us on the details below. You have the right to copies of the information we hold about you. Contact us on the details below to request this. This will be provided free of charge in most circumstances. If your request is particularly excessive or repetitive, CFM reserves the right to charge an administration fee of £10.00. You should contact us to exercise this right and we will respond within one month.
You have the right to rectify any information you believe is incorrect. CFM regularly refresh and check your information to make sure it is as accurate as possible but if you believe any details are incorrect, you can request this is amended or removed by contacting us and we will respond within one month to confirm the actions taken.
You have the right to be forgotten and request that your information be deleted if you withdraw your consent to CFM processing this information and in other circumstances. You should contact us to exercise this right and we will respond within one month.
Restrict the processing of your data in certain circumstances, for example, if you contest the accuracy of the information, if you object to the processing of the information we hold about you, if you oppose the deletion of the information and instead insist on restricted processing. You should contact us to exercise this right and we will respond within one month.
To withdraw your consent. You cannot remove your consent to some of the information we process without the contract being terminated. However, you can opt out of providing some information i.e. special category data, or request its deletion. In accordance with your terms and conditions you have the right to withdraw from the contract at any time and you can use the contact details below to exercise this right.
How we secure and retain your information
We retain your information for the full duration of our contractual relationship to enable us to provide our service. We keep your information for six years following closure of your account to comply with our legal and regulatory requirements. Any personal information we do not believe is necessary to provide our service, and all information outside of the retention period, is securely destroyed and deleted. We conduct some of our services through computer systems and any paperwork or documents we receive may be scanned to this system. If you need to send us important documents, please make sure you keep a copy.
All personal information we hold is securely stored, and we conduct regular testing of our cyber and physical security procedures to ensure this is maintained. If at any time we believe there has been a breach of your personal data we will notify you immediately. We will also notify the Information Commissioner’s Office (ICO) immediately if we become aware of any data breaches.
If at any time you believe your personal information may have been shared with an unauthorised party you must let us know as soon as possible by contacting our data protection officer by emailing: dataprotection@c-f-m.co.uk.
You are responsible for keeping any personal passwords or similar security information private, including personal information you disclose on social media. If you have any concerns about how we have handled or protected your information, we would hope that you contact us to discuss this. You can also escalate your concerns to the UK’s data protection regulator the Information Commissioner’s Office (ICO), more information can be found at: www.ico.org.uk.
Marketing
CFM collects personal information when you register with us or agree to use our products or services. We will only use this information to provide the services requested. You will receive information routinely from CFM which we refer to as ‘keeping me updated’ that is not marketing but forms part of the service we provide to you such as; Newsletters, updates, regulatory obligations i.e. complaints procedure.
How to contact us
Please contact us if you have any questions about this Privacy Notice or information we hold about you;
Email: dataprotection@c-f-m.co.uk Phone: 0121 585 5810 or 0800 783 1898
Post: For the attention of the Data Protection Officer, Capital Financial Management Ltd, 44 Hagley Road, Halesowen. Birmingham. West Midlands B63 4RH
Changes to our Privacy Notice
If we change how we plan to use your information in the future, we will give you 14 days notice of this. You have the right to refuse any such changes but it may result in the termination of our service if this refusal affects our ability to provide the service to you.