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Privacy policy 

Your privacy is very important to us. We promise to respect and protect your personal information and try to make sure that your details are accurate and kept up to date. This Privacy Policy sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this Privacy Policy carefully. When using our website, this Privacy Policy should be read alongside the website terms and conditions.

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This Privacy policy (“Privacy policy”) applies to the use of the website and products provided by (hereinafter also referred to as “we” or “us”). Our registered address is at Dukes Bailiffs Limited, 7 Newcastle Street, Stone, Staffordshire, ST15 8JT. Registered no.: 4418615.

 
  1. Our processing of your personal information

In this privacy policy, we refer to individuals whom we collect debt from and carry out enforcement action against as “Customers”.

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The personal information that we will collect will depend on our relationship with you. For example, we will collect more detailed information about you if you are a Customer than we would if you simply enquired about the services that we offer. Please look in the section below that best describes your relationship with us.

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Note: Sometimes we will ask for information relating to your health which is known as ‘special categories of information’. When we are carrying out enforcement activities, we are required to determine whether those subject to enforcement action could be regarded as vulnerable. To make this determination we may ask you for, or you may volunteer to give us, information about your vulnerability.

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If you provide personal information to us about other people you must provide them with a copy of this Privacy Policy and obtain any consent where we indicate that it is required for the processing of that person’s information in accordance with this Privacy Policy.

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1.1. Individuals who we collect debt from and carry out enforcement action against

This section will detail what personal information we collect about you and use if we have been asked to carry out enforcement action against you and collect debt from you on behalf of our clients.

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1.1.1. Personal information we collect

  • Name (surname, forename, middle name)

  • Title

  • Age range

  • Deceased date (where applicable)

  • Address

  • Email address

  • Phone number

  • Gender

  • Identity (NI number, Driving Licence number)

  • Business or company name

  • Profession

  • Job title

  • Employment status

  • Employer details (employer name, occupation, office, registered office, start date, salary)

  • Car registration and keeper details

  • Visual and audio images of you through our use of body-worn video (BWV), vehicle camera, and audio recording equipment

  • Council tax band of your address

  • Credit reference data

  • The location of your address or vehicle

  • Financial information such as credit/debit card information

  • Bank details that you have permitted us to use on your behalf

  • Date of birth

  • Information relating to your financial status/solvency

  • Information relating to your debt

  • Any information in client’s notes

  • Details about the property associated with a visit

  • Personal information collected under the debt collection and enforcement process

  • Means form information

  • Information obtained from credit and tracing checks including lifestyle information such as whether you are ex-directory, have active credit, or do online shopping

  • Information obtained from public sources such as social media profile names

  • Caller line identification

  • Recording of telephone calls

  • Technical information about any visit that you make to our website, including IP address, login information, and information about your web browser and operating systems.

 

1.1.2. Special categories of information that we collect

  • Information about your physical and mental health, in particular, information about any disabilities you may have, illnesses or medical conditions, or whether you are pregnant.

 

1.1.3. How we collect your personal information

  • From information provided by our clients when they register a new case with us

  • From third-party Credit Reference and Tracing Agencies

  • From public sources such as Google

  • From the DVLA

  • From specialist third parties whom we liaise with to carry out our services such as hire purchase information providers, removal companies, and auction houses

  • Where we visit your address, from our agents’ body worn video, vehicle camera and audio recording equipment

  • Other parties residing or otherwise present at your property when it is attended by enforcement officers

  • From information you provide when you register an online account or update your profile on our Customer Portal

  • From our website through the use of cookies.

 

1.1.4. What we use your personal information for

We may process your information for several different purposes. For each purpose, we must have a legal ground for such processing and we will rely on the following legal grounds:

  • We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:

    • keeping business records

    • using your personal information to carry out our debt collection and enforcement services

    • ensuring that we have up to date records

    • management information

    • statistical analysis

    • developing and testing our systems

    • analysing our business

    • improving the services we offer

    • research and statistical projects in which we are involved from time to time

    • carrying out strategic reviews of our business model.
       

When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need. For example:

  • It is necessary to comply with a legal obligation. For example our obligations under the law to protect vulnerable people.

  • We have your consent. Your consent is required for us to process personal information provided by you on our Customer Portal, and to share information with the Money and Pensions Service. You do not have to provide your consent and you can withdraw your consent at any time. You do not have the right to withdraw consent where we are not relying on your consent.

 

When we use your “special categories of personal information” (such as information about your health), we need to have an additional “legal ground” and we will rely on the following “legal grounds”:

  • That it is in the substantive public interest. Such as where it is necessary under the law in order to protect the interests of vulnerable

  • Research and statistics. where we partner with a research body/trade industry body, such as the Enforcement Conduct Board (“ECB“), to assist them in carrying out research into the industry, this may involve us sharing anonymised and/or pseudonymised BWV footage with a research company for them to analyse.
     

1.1.5. Who we share your personal information with

From time to time, we may share your personal information with the following third parties for:

  • Our clients who have instructed us to carry out debt collection and enforcement services on you

  • Credit reference and tracing agencies including Experian Ltd, TransUnion International UK Ltd and Equifax Ltd. See links below for their privacy notices:

  • Ecospend Technologies Ltd for the processing of Open Banking payments

  • CivicaMail and Fun Asset Ltd for the provision of correspondence and mailing services

  • Google for the geocoding of addresses

  • TelSolutions Ltd for the sending of SMS to get in touch with you, to remind you of payments that are due and to provide receipts of payments made

  • The DVLA

  • The Police and Courts

  • Vehicle Recovery and Removal Firms

  • Auction Houses

  • Legal advisers

  • Self-employed enforcement agents to assist in delivery of our debt collection and enforcement services

  • Other parties residing or otherwise present at your address when it is attended by enforcement agents

  • Other 3rd parties with whom you have authorised us to discuss your personal circumstances

  • Money And Pensions Service (MAPS) with your consent

  • Research companies that have been appointed to view personal information (particularly BWV footage) to undertake research and produce anonymised reports for the ECB (an independent oversight body for the debt collection industry, which Dukes is active in)
     

If you would like further information regarding the disclosures of your personal information, please email dpo@dukeslimited.co.uk.

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1.2. New Occupiers

This section will detail what personal information we collect about you and use if you are a New Occupier of an address that our records indicate was previously occupied by a customer.

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1.2.1. Personal information that we collect for new occupiers

  • Name and address

  • Evidence that you are the current occupier of the address

  • Recording of telephone calls and any information contained in notes of the call

  • Visual and audio images of you through our use of Body Worn Video and audio recording equipment

  • Photos and any information contained in any notes made by our agents when they visit your property

  • Technical information about any visit that you make to our website, including IP address, login information and information about your web browser and operating systems

  • New occupier evidence that you send us via post, website forms or email.

 

1.2.2. How we collect your personal information

  • From call recordings and where we visit your address, from our agents’ body worn video and audio recording equipment

  • From details you provide when sending correspondence or completing a form on our website

  • From our website through our use of cookies.
     

1.2.3. What we use your personal information for

We may process your information for several different purposes. For each purpose, we must have a legal ground for such processing and we will rely on the following legal grounds:

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  • We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:

    • keeping business records

    • using your personal information to carry out our debt collection and enforcement services

    • ensuring that we have up-to-date records

    • management information

    • statistical analysis

    • developing and testing our systems

    • analysing our business

    • improving the services we offer

    • carrying out strategic reviews of our business model
       

When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need.

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  • Your consent is required for us to process new occupier evidence provided by you via post, email or a form on our website. You do not have to provide your consent and you can withdraw your consent at any time. You do not have the right to withdraw consent where we are not relying on your consent.

 

1.2.4. Who we share your personal information with

From time to time, we may share your personal information with the following third parties for the purposes set out above:

  • In limited circumstances, with our clients, in order to resolve complaints.

  • Insurance Companies, in the event of a relevant insurance claim.

 

If you would like further information regarding the disclosures of your personal information, please see email dpo@dukeslimited.co.uk

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1.3. Website Users

This section will detail what personal information we collect about you and use if you use our website, either browsing or interacting with the website to send us a message or register a complaint.
 

1.3.1. What personal information we collect

  • Any information you may share with us when you visit our website

  • Technical information about any visit that you make to our website, including IP address, login information and information about your web browser and operating systems.

 

1.3.2. How we collect your personal information

Via contact forms, conversations on LiveChat and visits to the website.

 

1.3.3. What we use your personal information for

We may process your information for a number of different purposes. We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:

  • keeping business records

  • developing and testing our systems

  • diagnosing any problems with our website

  • responding to enquiries

  • assessing usage of our website

  • improving the services we offer
     

When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need.

 

1.3.4. Who we share your personal information with

We use third-party analytics services to help understand your usage of our website. Additionally, we may share your personal information with the following third parties:

When you fill out a form on our website, your data may be stored through Wix.com data storage, databases, and the general Wix.com applications. They store your data on secure servers behind a firewall.

 

If you would like further information regarding the disclosures of your personal information, please see email dpo@dukeslimited.co.uk

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1.4. Third Parties

This section details what personal information we collect about you if you are a 3rd party who happens to have been captured by our video and/or audio recording capability.
 

1.4.1. What personal information we collect

Visual and audio images of you through our use of Body Worn Video, Vehicle Cameras, and audio recording equipment.
 

1.4.2. How we collect your personal information

  • Where we visit an address where you are present, from our agents’ Body Worn Video and audio recording equipment.

  • Our vehicles may be equipped with both internal and external cameras which may capture footage of you.

 

1.4.3. What we use your personal information for

We may process your information for several different purposes. We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:

  • keeping business records
     

When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need.

 

1.4.5. Who we share your personal information with

From time to time, we may share your personal information with the following third parties for the purposes set out above:

  • In limited circumstances, with our clients, in order to resolve complaints

  • The Police and Courts

  • Insurance Companies, in the event of a relevant insurance claim

 

If you would like further information regarding the disclosures of your personal information, please see email dpo@dukeslimited.co.uk

 

2. How we protect your personal information when sending it abroad

We do not send your personal information outside of the UK. If this changes, we will notify you.

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3. What marketing activities we conduct with your data

We do not perform any marketing activities on dukesdebtonline.co.uk that use your personal information.

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4. How long we keep personal information for

We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out above and to comply with our legal and regulatory obligations.

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Our Customers: All customer data in all data stores (except Body Worn Video (BWV) footage) will be scheduled for deletion 6 years after the year in which the customer's last case is returned to the client. This means that customer data older than the 6-year threshold will be retained where there is a live case or there has been a live case within the last 7 years (i.e. 6 years plus the year in which the last customer case was returned).

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BWV recordings of visit interactions will be auto-deleted 1 year after the date on which the recording was made unless the case is subject to investigation or complaint at this point. In these circumstances, BWV footage will be deleted 1 year after the year in which the complaint/investigation is closed.  This also applies to BWV footage shared with research companies for research purposes outlined above.

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Vehicle camera recordings will be deleted after 60 days from the date on which the recording was made unless the case is subject to investigation or complaint at this point. In these circumstances, footage will be deleted 1 year after the year in which the complaint/investigation is closed.

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Where we receive vulnerability evidence that contains your personal information, that evidence will be assessed by our back-office team, and all photos or scanned documents will be deleted the next working day.

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New Occupiers: where we receive evidence, that contains your personal information, that evidence will be assessed by our back-office team, and all photos or scanned documents will be deleted 2 working days after completion of the assessment.

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5. Your rights

You have several data protection rights which entitle you to request information about your personal information, to dictate what we do with it or to stop us using it in certain ways.

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If you wish to exercise the rights set out below, please email us at dpo@dukeslimited.co.uk. Please note, that where we use BWV footage for research purposes, some of your rights stated below may not apply to such uses – in particular, where we rely on the research and statistics exemption under the Data Protection Act 2018, as this disapplies such rights.

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We respect your rights concerning personal information we hold about you, however, we cannot always comply with your requests. For example, we may not be able to delete your information if we are required by law to keep it for a longer time or if should we delete your information, we would not have the necessary information we need to fulfil the purpose for which it was collected.

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Your rights include:

  • The right to access your personal information

You can request a copy of the personal information we hold about you and certain details of how we use it.

Unless requested otherwise, your personal information will be provided to you by electronic means. If we do not hold an email address the information will be sent by post.

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  • The right to rectification

We make reasonable efforts to keep your personal information where necessary up to date, complete and accurate. We encourage you to ensure that your personal information is accurate so please regularly let us know if you believe that the information we hold about you may be inaccurate or incomplete. We will correct and amend any such personal information and notify any third-party recipients of necessary changes.

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  • The right to erasure

You can request that we delete your personal information. For example, where we no longer need your personal information for the original purpose we collected it. Whilst we will assess every request, this request is subject to legal and regulatory requirements that we are required to comply with.

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  • The right to restriction of processing

Subject to the circumstances in which you exercise this right, you can request that we stop using your personal information, such as when you believe that we no longer need to use your personal information.

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  • The right to data portability

Subject to the circumstances in which you exercise this right, you can request that we port across personal information you have provided to us to a third party in a commonly used and machine-readable format.

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  • The right to object to marketing

We do not carry out any marketing activities using your personal information.

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  • The right to object to processing

In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data.

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  • Rights relating to automated decision-making.

We do not currently carry out any automated decision-making. If this changes, we will notify you and inform you about your rights relating to automated decision-making.

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  • The right to withdraw consent

We do not rely on your consent to process personal information obtained from other sources, for example, our client when they refer your debt to us for collection. If you have provided us with additional information on our Customer Portal you may withdraw your consent for us to process this information at any time.

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  • The right to lodge a complaint with the ICO

You have a right to complain to the Information Commissioner’s Office if you believe that any use of your personal information by us is in breach of applicable data protection laws and/or regulations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk. This will not affect any other legal rights or remedies that you have.

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6. How we protect your information

We will use all reasonable efforts to safeguard your personal data. We have put in place strict physical, electronic, and managerial procedures to safeguard and secure the information we collect. We put in place confidentiality clauses or confidentiality agreements (including data protection obligations) with our third-party service providers.

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If you would like more information on how we protect your information please email dpo@dukeslimited.co.uk

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7. Contact us

You may contact our data protection officer if you have any questions about how we collect, store or use your personal information:

Data Protection Officer
Dukes Bailiffs Limited
Dukes Court
7 Newcastle Street
Stone, Staffordshire
ST15 8JT
dpo@dukeslimited.co.uk

 

8. Updates to this Privacy Policy

We may need to make changes to this Privacy Policy periodically, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. Our most up-to-date Privacy Policy will always be shown on our website and will be signposted in all of our communications.

 

This Privacy Policy (version 3) was last updated on: 25 March 2024.

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