Using the information that:
- we collect from you about you and your accounts with us
- we have obtained from the previous owner of your account and
- we have obtained from the credit reference agencies and third party data providers
we use a mathematical model to predict, using your personal information and your credit history, how likely you are to pay your balance or respond to any type of communication. This is known as profiling which means that we use our computer systems to help us predict this information about you. This helps us to decide what is likely to be the best way for us to work with you to manage your account.
As we have bought your account, we have a legitimate interest in understanding how likely you are to pay your balance or respond to our communications.
Where we process your information on the basis of our “legitimate interests”, the data protection rules say that we must make sure that our legitimate interests do not override your data protection interests, rights and freedoms. We must do this by carrying out a legitimate interest assessment which we must share with you. This is set out below.
What are the legitimate interests?
- As we have bought your account, it is in our commercial interests to collect the amounts that you owe under the agreements that you have entered into and to understand the best way to do to this.
- We will always deal with your account in the way we believe is in your best interests. This includes agreeing a payment plan which is tailored to your individual circumstances to help you reduce the amount you owe. The profiling we carry out means that we understand more about your personal circumstances so we are better equipped to offer you suitable and affordable repayment plans.
- It is also in the public interest for debts which are properly owed to be repaid. This is important for the economy as it helps to keep the cost of borrowing down and means that people continue to have access to credit.
Why is it necessary?
If we don’t use your information, we can't:
- decide how best to manage your account
- conduct our research activities, serving both public and commercial needs
- tailor our approach to your individual needs
- improve our products andservices
- improve our customer service or
- provide credit management solutions to our clients to help them manage the accounts that you have with them
What is the impact on you?
We collect, use and share your information as set out in this privacy notice, which means that we and the third parties we’ve told you about have access to your information.
However, we are authorised by the Financial Conduct Authority which means that we are required to act fairly, ethically and lawfully.
We also minimise the impact on your data protection rights, interests and freedoms by:
- making sure we comply with the data protection rules including the UK Data Protection Act and GDPR
- only collecting the minimum amount of information we need to carry out our debt collection activities
- having a retention policy to make sure that we don’t keep you information for any longer than we need it
- carrying out data protection impact assessments to make sure that we identify any potential privacy risks and put appropriate measures in place to protect you from those risks
- carrying out due diligence on the third parties we work with and making sure that we have contracts in place with those third parties to protect your personal information
- providing you with this privacy notice which explains how we use your information, what your rights are and how to exercise them and
- putting in place appropriate security measures to protect your information including have an ISO27001 certificate, which means that we meet the internationally recognised standards for managing risks to the security of the information we hold.
You have a right to object to profiling. This means that we will not be able to use your information for profiling unless we can demonstrate that we have compelling legitimate grounds to do so or the profiling is necessary for us to establish or exercise our legal rights.
If you do not repay the amounts you owe us, we may use automated decision-making processes to decide what the most appropriate way to manage your account is, including:
- whether we should take legal action against you, such as instructing solicitors to issue court proceedings or apply for a county court judgment (CCJ) against you and
- what action we should take to enforce any CCJ we obtain against you, such as applying for a warranty, an attachment of earnings or any other enforcement method available to us.
Using our systems in this way helps us to make sure that our decisions are quick, fair, efficient and accurate based on the information that we have about you. We make decisions in this way on the basis that it is necessary for the performance of a contract you are a party to, which means that we need to do this in order for us to collect the amounts you owe but haven’t paid under the agreements you entered into with the original owner of your account.
If we do take legal action against you, you may be asked to provide information to the court, attend court in person or you may incur legal costs. The court may decide in our favour and a CCJ may be entered against you.
We will also report details about the action we have taken to the credit reference agencies and this may have a negative impact on your credit score and your ability to borrow or get credit in the future.
We have processes in place to:
- check that the information that we hold about you and use for making automated decisions is accurate and up to date and
- test the credit scoring methods and the mathematical model we use on a regular basis to make sure that they are fair, effective and unbiased.
You have the right to ask us to review any automated decisions we have made about you.
If you would like to exercise any of your rights, please contact our Data Protection Officer by writing to Data Protection Officer, Lowell Financial Ltd, PO BOX 1411, Northampton, NN2 1BQ.