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Ethica Resolve

Who are we?

Ethica Resolve is a UK debt purchase company specialised in buying non-performing loans in the financial services sector with the primary aim of facilitating the effective rehabilitation of the customers out of financial hardship. Our primary aim is to be open with all our customers, which includes being transparent around how we process their personal data.

Ethica Resolve is the trading name of Ethica Resolve Limited (Company Number 12136094) whose Registered Office is at Central Office, Cobweb Buildings, The Lane, Lyford, Wantage, England, OX12 0EE.

We are authorised and regulated by the Financial Conduct Authority (FCA). We are also registered as a Data Controller as defined under the Data Protection Law with the Information Commissioner’s Office (ICO).

Ethica Resolve operate in partnership with several FCA regulated debt collections companies that are instructed to engage with our customers on our behalf.

Introduction

Ethica Resolve are committed to protecting the personal data we collect and process them solely for the recovery of outstanding debts. This Privacy Notice relates to all personal information collected and processed through the course of our business activities.

This Privacy Notice will be updated regularly to ensure ongoing compliance with associated laws and regulations.

For us to fulfil our business requirements, personal data relating to customers, potential new customers and any individuals who have made previous contact will be processed and retained for a defined period. This Privacy Notice will explain:

  1. The type of information that we hold relating to our customers and other individuals;
  2. How this information is obtained;
  3. Who the information may be shared with;
  4. The reasons behind such processing; and
  5. How long personal information is retained.

Personal information will be kept for no longer than necessary for the purpose by which it was originally provided.

Our Website Users

No personal data will be requested or retained from individuals navigating our website.

Should individuals choose to provide personal information by making an online enquiry, the data provided will be kept for the sole purpose of responding to a query. An enquiry made by a customer will be held within the account notes for the duration the account is live and in line with our defined retention period once the account is closed.

Our Customers

As a debt purchaser, we receive personal data from lenders for the purpose of pricing in accordance with the terms and conditions agreed with the lender. At such stage we will be processing the data under the instruction of the lenders who are the data controllers. Once an agreement to purchase a portfolio from a lender has been reached, Ethica Resolve becomes the data controller and take on the legal rights previously held by the original lender. At this point we instruct several FCA regulated debt collections companies to help to engage with our customers on our behalf.

As a data controller Ethica Resolve must ensure that all personal data is processed lawfully, fairly and in a transparent manner. To achieve this, we rely on a combination of the following lawful bases to process personal data:

  • Legitimate interest
  • Contract
  • Legal obligation
  • Consent

The personal data retained and processed relating to our customers include:

  1. Name;
  2. Address;
  3. Date of Birth;
  4. Telephone Numbers;
  5. Email Address;
  6. Financial and Credit Score Information;
  7. Employment Status;
  8. Payment history in relation to the purchased debt.

There may be instances wherein we process special category or sensitive data as defined under Data Protection Law. We will ensure we receive consent from the customer before we process the information. Customers have the right to withdraw their consent for us to process this information at any time.

Possible categories of sensitive data include:

  1. Physical and Mental Health Information.
  2. Disclosed medical records

The information collected by us may be processed for the following defined reasons:

  1. Verifying the identity of customers and their residential status, and doing our best to ensure this information is accurate and up to date;
  2. Assessing affordability prior to entering a repayment arrangement which ensures payments agreed are sustainable and affordable;
  3. Processing of payment arrangements and ad hoc payments as requested by the customer;
  4. Detecting, preventing, and investigating potential and actual fraud and other such related activities;
  5. Fulfilling all queries and disputes in relation to any agreements or accounts;
  6. Tracing customers and recovering outstanding debts;
  7. Performing statistical analysis to identify and monitor risks and emerging market trends.
  8. Assessing the customers situation to best determine where to sign post the customer for the most appropriate support.

How we collect your personal information

We receive our customers’ personal information directly from the original lender immediately following the successful acquisition of a loan portfolio.

We also use Credit Reference Agencies (including TransUnion, Experian and Equifax) to ensure the data we are processing is accurate and up to date.

How we use your personal information and who we share your them with

Firstly, your data will always be dealt with responsibly and in accordance with the Data Protection Act 2018 and GDPR.

Throughout the course of the debt recovery journey, there may be instances where we disclose our customers’ information to external organisations.

We only disclose information where there is a clearly defined legitimate reason in doing so. For example, to verify a customer’s identity, we will use third party organisations including but not limited to; TransUnion, Equifax and Experian. We do this to ensure that the data we are processing is accurate and up to date. The personal data received from these third parties includes:

  1. Name;
  2. Residential Address;
  3. Residential Status;
  4. Date Of Birth;
  5. Email Address (if applicable);
  6. Contact Telephone Numbers (Home and Mobile).

We will only send communications via email and text where the details have been appropriately verified. Customers can change their contact permissions at any time by contacting us on 03333395840 or emailing help@ethicaresolve.com

Personal information, the status of account, details of payment plans, and any defaulted plans may be shared with Credit Reference Agencies. The identities of the Credit Reference Agencies, and the ways in which they use and share personal information, are explained in more detail in the respective information notices;

  • TransUnion: www.transunion.co.uk/crain
  • Equifax www.equifax.co.uk/crain
  • Experian: www.experian.co.uk/crain

We may from time to time pass personal information of customers onto contracted organisations in the following instances:

  • To process payments on our behalf;
  • To FCA regulated debt collection partners who assist in the recovery of any outstanding debts;
  • Ensure customer credit reports are accurate and up-to-date;
  • When customers have entered into a payment plan with an appointed Debt Management Company or have appointed a 3rd party representative to assist with their debts e.g., insolvency practitioner or carer;
  • To detect, investigate and prevent potential or actual fraud;
  • To meet our regulatory obligations as defined by the Financial Conduct Authority (FCA) and the Information Commissioner’s Office (ICO);
  • To approved Customer Survey partners who conduct satisfaction surveys on our behalf and as per our instruction.

We only disclose the personal data of customers with other organisations once appropriate contractual agreements are in place. Such agreements ensure third parties processing personal data, for which we are responsible, are doing so in accordance with all associated laws, regulations and as per our instructions.

From time to time your personal data may be transferred to organisations that are based in countries outside the European Economic Area. In these circumstances, we will ensure they process your personal data only in accordance with the applicable Data Protection Laws and under strict organisational and contractual controls, specifically standard contractual clauses approved by the EU. For more information about these controls, please visit https://ico.org.uk and search for ‘International transfers’.

How long we keep personal information held by us

We will keep your personal information for as long as you are a customer of Ethica Resolve.

After you stop being a customer, we may keep your data for up to 6 years for one of these reasons:

  1. To respond to any questions or complaints.
  2. To show that we treated you fairly.
  3. 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. If we do, we will make sure that your privacy is protected and only use it for those purposes.

Third Parties

There may be occasions where we process personal information relating to third parties. In these instances, we commit to ensuring ongoing adherence to Data Protection Laws. Information processed will remain proportionate, relevant and not excessive. This includes:

  1. Name;
  2. Email Address;
  3. Address;
  4. Contact Details;
  5. Any other information disclosed by the individual.

Personal information relating to a customer’s appointed third-party representative will be retained for the duration such authority remains valid and for a defined period thereafter.

 

Your rights as data subjects under the UK Data Protection Law

The UK Data Protection Law defines the rights which Data Subjects have in relation to the processing of their personal data, including:

  1. Your right of access – You have the right to ask us for copies of your personal information;
  2. Your right to rectification – You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete;
  3. Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances;
  4. Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances;
  5. Your right to object to processing – You have the right to object to the processing of your personal information in certain circumstances;
  6. Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

Should you wish to express any right as defined under the UK Data Protection Law, the following channels may be used:

Email: help@ethicaresolve.com

All requests submitted are acknowledged to confirm receipt and will be fulfilled within one calendar month, as defined under current Data Protection Law. You will not be required to pay a charge for exercising your rights.

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.

How to complain

Please let us know if you are unhappy with how we have used your personal information. To contact us please call us on 03333395840 or send an email to help@ethicaresolve.com

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office https://ico.org.uk

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