Privacy Notice

Last updated: November 2019

Your information will be held by Jarvis Insolvency Limited (“Jarvis”).

In this privacy notice, “We” “Our”, “Us” and “They” is Jarvis.

How we use your personal information

This privacy notice is to let you know how we promise to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a client, and the choices you give us about what marketing you want us to send you.

This notice explains how we do this and tells you about your privacy rights and how the law protects you, in accordance with the General Data Protection Regulation (GDPR).

Our Privacy Promise

We promise:

  • To keep your data safe and private.
  • Not to sell your data.
  • To give you ways to manage and review your marketing choices at any time.

Who we are

Jarvis is an insolvency practice which provides debt counselling, debt adjusting and credit information services to consumers.

If you have any questions or want more details about how we use your personal information, you can call us on 0800 047 8680.

Who collects your data

Jarvis is a “data controller”. This means they are responsible for how they hold and use personal information about you.

Jarvis’s Data Protection registration number is ZA528025 and as described above, they provide debt advice and are an insolvency practice.

How the law protects you

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection law says that we can use personal information only if we have a proper reason to do so. This includes sharing it outside Jarvis. The law says we must have one or more of these reasons:

  • To fulfil a contract we have with you, or
  • When it is our legal duty, or
  • When it is in our legitimate interest, or
  • When you consent to it.

We are obliged to process personal data to comply with the law and therefore have a legal duty to use your personal information.

We rely on our legal obligation under the Insolvency Act 1986 and its subordinated legislation including any rules, regulations or orders, as from time to time re-enacted or amended, the Insolvency (Northern Ireland) Order 1989 and its subordinate legislation.

For what purpose do we use your personal information

Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so.

What we use your personal information forOur reasonsOur legitimate interests
To provide debt counselling, debt adjusting and credit information services to you.
To propose an Individual Voluntary Arrangement.
To manage our relationship with you.
To develop new ways to meet our customers’ needs and to grow our business.
To develop and carry out marketing activities.
To study how our customers use our products and services.
To provide advice or guidance about our products and services.
Fulfilling contracts
Our legal duty
Our legitimate interests
Your consent
Keeping our records up to date, working out which of our products and services may interest you and telling you about them.
To provide debt counselling, debt adjusting and credit information services to you.
To propose an Individual Voluntary Arrangement.
Developing products and services, and what we charge for them.
Seeking your consent when we need it to contact you.
Being efficient about how we fulfil our legal duties.
To develop and manage our brand, products and services.
To manage how we work with other companies that provide services to us and our customers.
Fulfilling contracts
Our legal duty
Our legitimate interests
Developing products and services, and what we charge for them.
Being efficient about how we fulfil our legal and contractual duties.
To deliver our products and services.
To manage fees and charges.
To exercise our rights set out in agreements or contracts.
Fulfilling contracts
Our legal duty
Our legitimate interests
Being efficient about how we fulfil our legal and contractual duties.
Complying with regulations that apply to us.
To detect, investigate, report, and seek to prevent financial crime.
To manage risk for us and our customers.
To obey laws and regulations that apply to us.
To respond to complaints and seek to resolve them.
Fulfilling contracts
Our legal duty
Our legitimate interests
Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect.
Complying with regulations that apply to us.
Being efficient about how we fulfil our legal and contractual duties.
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.Our legal duty
Our legitimate interests
Complying with regulations that apply to us.
Being efficient about how we fulfil our legal and contractual duties.

Groups of Personal Information

To provide our services, we collect ‘Personal Information (data)’ that uniquely identifies you. The following table explains the different kinds of personal information we collect and why.

Type of personal informationDescription including examples:Why we want the data, and what we will do with it:
Personal descriptorsYour name, age, date of birth, passport or driving licence.We require this to identify you and communicate with you.
You cannot opt out of providing this information.
ContactWhere you live and how to contact you.We require this to identify you and communicate with you.
You cannot opt out of providing this information.
FinancialThis includes your income, expenditure, assets, benefits details, wage slips, tax returns, default history, legal action, county court judgements, previous credit history, credit reference information, bank account and debit card details.We require this to provide certain services, such as to assess your eligibility for debt solutions or to establish your creditor information on your behalf.
It is a contractual requirement for insolvency services.
You cannot opt out of providing this information.
Employment informationThis includes your employment status, occupation, pay date, salary amount, professional occupational status (e.g. Company Director, Police Officer).We require this to assess your eligibility for debt solutions. It is a contractual requirement for insolvency services.
You cannot opt out of providing this information.
Life informationThis includes your marital status, number of children and/or dependents, general household details.We require this to assess your eligibility for debt solutions. It is a contractual requirement for insolvency services.
You cannot opt out of providing this information.
Dependents descriptorsThis includes the number of dependent’s.
If a dependent is a child, this includes their date of birth.
We require this to assess your eligibility for debt solutions. You can opt out of providing this data.
Health informationThis includes physical or mental disabilities.
For example, if you complete the Debt and Mental Health Evidence Form.
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.
ContractualDetails about the products or services we provide to you.It is a contractual requirement for insolvency services.
You cannot opt out of providing this information.
BehaviouralDetails about how you use our products and services.Marketing may record the details and Management Information may be generated using this information.
You can opt out of providing this information.
TechnicalDetails on the devices and technology you use.Marketing may record the details and Management Information may be generated using this information.
You can opt out of providing this information.
CommunicationsWhat we learn about you from letters, emails, and conversations between us.These are essential communications, deemed necessary to fulfil our contractual and legal obligations.
You cannot opt out of providing this information.
Electronic signatureWe can send documents to you by email which you will need to review, consider and where you decide to proceed, sign using an electronic signature. You may be required to provide personal information to electronically sign the document.
We will also collect information such as your name, the date and time of the event, the IP address and other information about the browser or device used to send, sign, approve or take other actions with respect to the document.
All this information is recorded as part of an audit trail that is linked to the electronically signed document.
You cannot opt out of providing this information, however, you can opt out of using the electronic signature service and receive a hard copy of the documents by post.
Open Data and Public RecordsDetails about you that are in public records such as the Electoral Register or Insolvency Register and information about you that is openly available on the internet.We may require this to assess your eligibility for debt solutions. Checking you are not listed on the Insolvency Register is a contractual requirement for insolvency services.
You cannot opt out of providing this information.
Documentary DataDetails about you that are stored in documents in different formats, or copies of them. This could include things like your passport, driving licence or birth certificate.We require this to provide certain services, such as to assess your eligibility for debt solutions. We require this to identify you.
You cannot opt out of providing this information.
ConsentsAny permissions, consents, or preferences that you give us. This includes things like how you want us to contact you.We require your consent to act on your behalf. This is deemed necessary to fulfil our contractual and legal obligations.
You cannot opt out of providing this information.
National IdentifierA number or code given to you by a government to identify who you are, such as a National Insurance number.We require this to provide certain services, such as to assess your eligibility for debt solutions.
You can opt out of providing this information.
Consumer feedbackThis includes information that you voluntarily share with us about your experience in using our products and services, such as personal stories or complaints.We use this information for marketing purposes and may collect and publish consumer-generated content.
This information is used to evaluate and develop our products and services. It may be shared with regulators and auditors.
You can opt out of providing this information.

If you wish to opt out of providing information

Please email [email protected].

Where we collect personal information from

We may collect personal information about you from data you give to us, data we collect when you use our services and from third parties we work with.

Data you give to us:

  • When you apply for our products and services
  • When you talk to us on the phone
  • When you use our websites or mobile device apps
  • In emails and letters
  • In customer surveys

Data we collect when you use our services. This includes the amount, frequency, type, location, origin and recipients:

  • Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.

Data from third parties we work with:

  • Companies that introduce you to us
  • Financial advisers
  • Creditors
  • Credit reference agencies
  • Social networks
  • Fraud prevention agencies
  • Payroll service providers
  • Public information sources such as Companies House
  • Agents working on our behalf
  • Market researchers
  • Medical practitioners*
  • Government and law enforcement agencies

*If the Debt and Mental Health Evidence Form is appropriate to your circumstances and you request your doctor to complete this form and return it to us, we may hold special category data on you.

Transferring and sharing your information

We may share your information with other parties as without doing this we (or they) cannot carry out our legal duty.

In addition, from time to time, we use the services of external consultants, legal specialists, or outsource certain aspect of our processes to other organisations, some of whom may be located outside of the European Economic Area. We keep outsourcing activity to a minimum however on occasion these organisations may assist us with quality monitoring, marketing, identity verification, audits, record keeping or printing. All outsourced service providers are carefully vetted and monitored to ensure the safeguarding of your information.

We use the services of credit reference agencies for verifying your identity this usually will leave a ‘soft search’ on your credit file. We will share your personal information with credit reference agency and they will give us information about you. The data we exchange can include:

  • Name, address and date of birth
  • Details of any shared credit
  • Financial situation and history
  • Public information, from sources such as the electoral register and Companies House

We may share your data with Equifax. Equifax is one of the largest credit reference agencies in the UK. They already hold data on you. Equifax may send to us details of who you owe money to and how much you owe. We’ll use this to:

  • Make sure what you’ve told us is true and correct
  • Help detect and prevent financial crime
  • Propose your IVA
  • Trace debts and creditors

In turn, we will then upload this data our system. When they send us your data they will record this on your credit file as a soft search i.e. it will not affect your credit score. Equifax will not use your data for any other purpose.

For more information about this visit www.equifax.co.uk

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, family member or carer with whom we can share your information with. You will need to provide separate consent for us to be able to share your information with them, and you can revoke this consent at any time.

Who we share your personal information with

We may share your personal information with these organisations:

  • Your creditors
  • The Insolvency Service
  • HM Revenue & Customs, regulators and other authorities
  • Credit reference agencies
  • Fraud prevention agencies
  • Insurers including Kerr Henderson (General Insurance Services) Ltd and Marsh Ltd
  • Any party linked with your product or service
  • Companies we have a joint venture or agreement to co-operate with
  • Organisations that introduce you to us
  • IT Companies – we use third party software companies to help manage your data and provide our product and services to you. These include:
    • HubSolv Ltd, a case management system
    • Signable Ltd, technology provider that allows a person to electronically affix a signature to an online contract
    • Connex One Ltd, a telephony company
    • Total Processing Ltd, a payment processor
    • ActionPoint Ltd, an IT support and services company
  • Companies that we introduce you to. These include:
    • Grant Thornton UK LLP
    • Debt Consultancy Service C.I.C.
    • Debt Support Service Ltd
    • Pacific Financial Solutions Ltd
    • icount Money Limited Ltd
    • Credit Reporting Agency Ltd
    • APS Financial Limited
    • Forestking Insolvency Ltd
    • Debt Compare Ltd
    • The Insolvency Practice Ltd
    • UK Debt Advisors Ltd
    • Basik Money Ltd
    • Moriarty Financial Services Ltd
  • Market researchers
  • Independent Financial Advisors
  • Solicitors
  • External Auditors
  • Price comparison websites and similar companies that offer ways to research and apply for financial products and services
  • Companies you ask us to share your data with
  • Institute of Chartered Accountants in England and Wales
  • Information Commissioners Office
  • External compliance advisors including Nova Consultants Limited
  • Anti-money laundering verification services including Smart Credit Limited trading as SmartSearch

We may need to share your personal information with other organisations to provide you with the product or service you have chosen.

We may also share your personal information if the make-up of Jarvis changes in the future:

  • We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may seek to acquire other businesses or merge with them.
  • During any such process, we may share your data with other parties. We’ll only do this if they agree to keep your data safe and private.
  • If the change to Jarvis happens, then other parties may use your data in the same way as set out in this notice.

Fraud Prevention Agencies

We will need to confirm your identity before we provide products or services to you. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.

Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for.

We will use the information to:

  • Confirm identities
  • Help prevent fraud and money-laundering
  • Fulfil any contracts you or your business has with us

We or a fraud prevention agency may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.

If we, or a fraud prevention agency, decide there is a risk of fraud, we may stop activity on your case and the fraud prevention agency will also keep a record of the risk that you, or your business, may pose.

Fraud prevention agencies can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

Fraud prevention agencies may send personal information to countries outside the European Economic Area (EEA). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

Automated decisions for fraud prevention

We may use automated decision making in processing your personal information in relation to fraud prevention. If you disagree with the outcome of an automated decision you can request a manual review of the accuracy of an automated decision.

Sending data outside of the EEA

We will only send your data outside of the European Economic Area (EEA) to:

  • Follow your instructions
  • Comply with a legal duty
  • Work with our agents and advisers who we use to propose your IVA

If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:

Websites

If you use our website we may collect your IP address, cookies, browser information, and use plugins that collect your information (e.g. Google Analytics). Cookies are text files places 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.

For further information visit www.aboutcookies.org or www.ICO.org.uk/concerns/cookies/

You can set your browser not to accept cookies and can find out more information in the links above, however in some cases our website features may not function as a result.

Our website and communications contain links to other organisations and websites. This privacy notice only applies to Jarvis.

Temporary cookies form part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.

Why are cookies used?

They help visitors. Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off – this won’t stop a website from working, but it might mean it won’t work as well as it could, or that you have to do the same thing more than once.

They help website owners. Cookies tell website owners things like: what search engine a visitor used to find the website, how often they’ve visited it, how long they’ve spent on it, and so on.

We’ve set out below the cookies that we may use and those that are set by third parties on our website.

Google AnalyticsOn site behaviour tracking
HotjarHeatmaps and screen recording
Visual Website OptimiserA/B testing and heatmaps
FacebookRetargeting and tracking conversions
AdWordsTrack Conversions

Except for essential cookies, all cookies will expire after 10 years.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

You can ask us to stop sending you marketing messages by contacting us at any time.

Whatever you choose, you’ll still receive other important, and legally required, information and documents.

We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can update your choices at any time by contacting us.

Security

We will use all reasonable efforts to safeguard the information we collect about you by having security and organisational procedures in place.

All personal information we hold is securely stored, and we conduct regular testing on 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.

You are responsible for keeping any personal passwords or similar security information private, including personal information you disclose on social media.

If you choose not to give personal information

We may need to collect personal information by law, or under the terms of a contract we have with you.

If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services required to propose your IVA. It could mean that we cancel a product or service you have with us. Any data collection that is optional would be made clear at the point of collection.

Letting us know if your personal information is incorrect

You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.

What if you want to restrict the processing of your data

In certain circumstances you may want to restrict the processing of your data, for example, if you contest accuracy of the information, if you object to the processing of the information we hold about you, if you oppose the erasure of the information and instead insist on restricted processing. You should contact us if you want to do this and we will respond within one month.

What if you want us to stop using your personal information

You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted. You can ask us to restrict the use of your personal information if:

  • It is not accurate.
  • It has been used unlawfully but you don’t want us to delete it.
  • It not relevant any more, but you want us to keep it for use in legal claims.
  • You have already asked us to stop using your data but you are waiting for us to tell you if we can keep on using it.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.

How to withdraw your consent

You can withdraw your consent at any time. Please contact us if you want to do so. If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

How long we keep your personal information

We will keep your personal information for as long as you are a customer of Jarvis. After you stop being a customer, we will keep your data for 6 years for one of these reasons:

  • This is a legal requirement of an IVA.
  • To respond to any questions or complaints.
  • To show that we treated you fairly.
  • To maintain records according to rules that apply to us.

We may keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

Data portability

Data portability means that we can provide you with your personal information in a structured, commonly used and machine-readable form free of charge. This enables other organisations to use your data. If you require, we can supply this information directly to another organisation if technically feasible. You should contact us to exercise this right and we will respond within one month. This may be extended to two months if the request is complex and we will notify you if this is the case.

How to get a copy of your personal information

You can access your personal information we hold by contacting us via telephone, email or writing to us at this address:

Jarvis Insolvency Limited
3rd Floor Marsland House
Marsland Road
Sale
Cheshire
M33 3AQ

Phone: 0800 047 8680

This will be provided free of charge and we will respond within one month.

How to complain

Please let us know if you are unhappy with how we have used your personal information, please contact us using one of the following methods:

by phone on:

0800 047 8681

by email to:

[email protected]

by post to:

Complaints Officer
Jarvis Insolvency Limited
3rd Floor Marsland House
Marsland Road
Sale
Cheshire
M33 3AQ

You also have the right to complain to the Information Commissioner’s Office. Find out on their website how to report a concern: www.ico.org.uk.

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 the refusal affects our ability to provide the service to you.