We are required to comply with the provisions of the EU General Data Protection Regulation (GDPR) and the United Kingdom’s Data Protection Bill.
• ‘Personal data’ means any information relating to an identifiable person.
• ‘Processing’ means any operation which is performed on personal data, or on sets of personal data, including accessing, collection, recording, storing or destruction.
• A ‘controller’ is a person or firm which determines the purposes and means of the processing of personal data.
• A ‘processor’ is a person or firm which processes personal data on behalf of the controller.
The Zinc Group Limited are a credit control, recoveries management and business process outsourcing company; Zinc Recoveries and BPO Services are part of The Zinc Group. Complete Credit Consultancy Limited (part of The Zinc Group Limited) are regulated by the Financial Conduct Authority.
The Zinc Group undertakes collection management of accounts on behalf of our clients / your creditor. The client who has passed your account data to us has been informed to you under separate cover. Your account data is assigned to The Zinc Group, however, our clients / your creditor remain the controllers of your data.
The Zinc Group are the data processor. The Zinc Group Limited’s company registration number is 06771789 and our registered address is: Kings House, 4 Elm Court, Stratford-upon-Avon, Warwickshire, England, CV37 6PA.
We only hold data that is necessary for us to be able to undertake the management of your account. Usually, this means that we will hold your details in our records, and this will include your name, address, date of birth, e-mail address and/or telephone number, address history, credit history and payment history.
Where you are a representative of a customer, we will usually hold your contact details, which will include your name, address, email address and telephone number.
Note that we also retain records of all communication with the Zinc Group Ltd including phone recordings and all written communication.
To enable us to manage your account, the information mentioned above is transferred to The Zinc Group Limited from our clients. Because this data is transferred to us from our clients/your creditor, we will hold this data or information that they have provided us, from both your credit application and from the course of your account with them.
Where you are a representative of a customer, we have only obtained your data from either you or the customer you are representing.
We need to process your data in order to ensure the performance of the contract you entered into with our client/your creditor.
Where you are a representative of a customer we will only process your data to fulfil the contract that was entered into by the customer.
This means that we will use your data to be able to manage the account and recover any debt outstanding on the account. In addition, and in line with your contractual obligations to our client, we may also use the information for statistical analysis, auditing and fraud prevention purposes. We may also be required to share the information with Credit Reference Agencies.
All the personal data we hold will be processed by our staff in the United Kingdom. We may need to share data with third parties such as the Printing Company, Credit Reference Agencies, Identity Management Companies, legal representatives and land registry. Data will only be shared with organisations based within the EU, or with organisations that can evidence that an adequate level of protection exists. Please be aware, however, that your information may be stored on a cloud-based system whose servers are located within the European Union.
The Zinc Group Limited take all reasonable steps to ensure that personal data is processed securely. We maintain administrative, technical and physical safeguards to protect against loss, misuse or unauthorised access, disclosure alteration or destruction of the personal information that has been provided.
In addition to the data we hold, it may be beneficial to notify us of health conditions or disabilities so that we are aware of any conditions and how they may affect your ability to manage your account, communicate with us or make repayments. This will allow us to take any reasonable steps to accommodate your specific needs or requirements. This type of information is known as ‘special category information’ (also known as sensitive personal data’) and we require your explicit consent to process this information.
This kind of information will only be collected from you and used by The Zinc Group Ltd to assist you. It will not be shared with any third parties unless you have provided consent to share it with the originating client/your creditor and will only be kept as long as it is required for this purpose, or until you notify us that you no longer consent to its processing.
You do not have to provide us with consent to process such data, and you have the right to withdraw consent to our processing of your sensitive personal data at any time.
You have the right to withdraw consent to our processing of the sensitive personal data at any time. If you wish to withdraw consent then you can inform us of this, in either verbal or written form at any time.
We will generally keep your personal data for a period of seven years after the account has been closed. After this period, any data we hold on you will either be destroyed or will be anonymised if it is no longer required for the lawful purpose for which it was obtained.
We need to retain your data for seven years in order to comply with certain legal obligations under the Consumer Credit Act 1974, financial crime legislation and regulatory obligations as set out by the Financial Conduct Authority.
Under data protection legislation, you have several rights regarding the use of your personal data, as follows:
If at any point you wish to either confirm whether your personal data is being processed and/or access the data we hold on you, you can request to see this information, usually free of charge, and we will respond to this request within 30 calendar days.
You also have the right for certain data you have provided The Zinc Group with to be provided to you in a structured and commonly used electronic format (for example, a Microsoft Excel file), so that you can move, copy or transfer this data easily to another data controller. You may also request that we transmit this data directly to another organisation where it is practical for us to do so.
You are entitled to have data corrected if it is inaccurate or incomplete.
You are entitled to have data deleted if it is no longer needed or there is no longer a legitimate reason for the processing, or if the data in question has otherwise unlawfully been processed. Whilst you have the right to ask for sensitive personal data to be deleted, you should note that data obtained which is necessary for the performance of the contract with the client cannot be deleted until after a reasonable period of time following full payment or settlement of the debt.
You have the right to object to the processing of your personal data (note that this only provides you with the right to raise your objections, not a blanket right to have any and all processing cease).
You have the right to restrict the processing of your personal data under certain circumstances, including if you have contested its accuracy and while this is being verified by the Zinc Group, or if you have objected to its processing and while the Zinc Group is considering whether it has legitimate grounds to continue to do so. Where we identify ourselves as the processor of your data we will send your request to your creditor, the data controller.
If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact firstname.lastname@example.org and they will investigate your concerns.
If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). You can find further information about the ICO and their complaints procedure here: https://ico.org.uk/concerns/.