Privacy Policy

Privacy Policy

Who we are?

Debt Help Plan is a trading style of Simmons Providence LTD.
Registered Office Smokehall Lane, Winsford Cheshire, CW7 3BE a company registered in England and Wales under Registration number 09903601, Data protection No: ZA830908

Debt Help Plan trading as Simmons Providence Ltd is committed to preserving the privacy of all visitors on our website www.debthelpplan.co.uk

Simmons Providence Ltd refers it clients to Debts Solved Limited t/a X-debt, Registered Office 95 Chorley Road, Swinton, Manchester, England, M27 4AA a company registered in England and Wales under Registration number 06391280. Angela Canning is authorised in England and Wales to act as an Insolvency Practitioner by the Insolvency Practitioners Association. IP number – 9449

Please read the following privacy policy to understand how we use and protect the information that you provide to us.

Our organisation is committed to protecting the privacy or your personal information and is registered with the Information Commissioners Office (ICO), in order to make transparent our data handling practices and complies with the General Data Protection Regulations (GDPR) effective from May 2018.

Debt Help Plan may choose to amend the content of this policy on any occasion which will be posted on this website. Please visit this policy on a regular basis to make sure you understand what we do with your information. By registering on this site, you consent to the collection, use and transfer of your information
under the terms of this policy.

How we may contact you

Unless you state otherwise Debt Help Plan and our Authorised Debt Advisory Partners including our Insolvency Practitioner Firms may contact you via telephone, email, post, SMS, automated messages, fax and WhatsApp. 

How you contact us

If you contact us by telephone using the specified numbers on our website or advertising/marketing correspondence, your call may be recorded for training, quality and regulatory purposes. If you contact us via email, webchat, WhatsApp or post this information may be held securely by ourselves for training, quality and regulatory purposes.

Personal Information that we collect from you & why?

We may obtain personal information from you through websites, mobile applications or other similar devices, channels or applications operated by or on behalf of any of the .When you visit, register or access services on our website you may be asked to provide certain information about yourself including your name, contact details, email address and telephone number. Note that it is your responsibility to check and ensure that all information, content, material or data you provide on the sites is correct, complete, accurate and not misleading and that you disclose all relevant facts.

Information about other people

If you are providing us with another person’s information you should first ask them to read this Privacy Policy. By giving us information about another person you are confirming that they have given you consent to provide the information to us and that they understand how their details will be used. The data we will collect from you will depend on the service or product you apply for, or the service or product that we provide to you. We will only collect information that we need, or
where we’re required to collect to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.

This is likely to include but not limited to the collection of:
• your personal details (e.g. name, date of birth)
• address details
• contact details (e.g. phone number, email)
• special personal information* (e.g. information that may affect your ability to make
decisions.)
• financial information
• employment information
• information on how you use our website(s) and products and services

Special personal information*
Data protection law defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you. For example, a mental health condition that could affect your ability to make a decision regarding your financial situation or a prolonged illness that may have caused you to fall behind with your regular payments to your creditors.

Where we need to collect and process this type of data about you, by providing this information to us you give your explicit consent for us and any other third party to process this special data as set out in this privacy policy, unless we have a legal obligation to process this type of data. How do we collect your personal information?

We collect your information in various ways.
• When you make an application or enquiry to us either by phone, email, our website, by a third party or by any other means
• Information received from a third party, for example you have been introduced to us by another company
• By adding reviews, comments or interacting with us using social media such as Twitter or Facebook etc
• When you use online platforms, such as Whatsapp, facebook, instagram.
• When we may need to obtain up to date information about you to meet our legal or regulatory obligations
• Where you have given permission for your information to be passed to us

Consent

Consent to Marketing
Where necessary we will only collect and process your personal information if you have given your consent for us to do so, for example, we will only send you certain marketing emails and process any sensitive information about you if we have your consent. By ticking and accepting our privacy policy and terms of business you agree to giving us consent to contact you and carry out any marketing campaigns.

Consent to Process Data
1. By ticking and accepting our privacy policy and terms of business you agree for Debt Help Plan to pass your data to an IP’s Firm to,
> prepare your IVA solution and for the IP to contact you to assist you with your application.
> When the IP’s firm makes contact with you to further your application, then any personal
data that you pass to them will be subject to their privacy policy which you will made aware of.

  1. Legitimate Interests.
    We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws
    there is a concept of “legitimate interests” as a justification for processing your personal information. Our legitimate interests for processing your personal
    information are to:
    • Verify your identity and credit standing to enable us to provide debt counselling.
    • Extract certain information for the purpose of generating statistics for our own internal purposes (including credit and/or behaviour scoring, and market product analysis).
    • Detect, prevent and investigate actual and potential fraud and related activities.
    • Develop, manage and market products and services to meet your needs and to contact you for products and services that may be of interest.
  • Determine your eligibility for different products and services that you may be interested in.
    • Contact you in connection with your enquiry.
    • Update this website to better meet your needs in the future.

Your Right To Opt Out of Future Contact From Us
You can opt out of future contact from Debt Help Plan at any time. All of our marketing messages will provide an opt out link – please allow up to 48 hours for us to process your opt out request. Alternatively you can make this request via our contact form, where your details will be removed from any future marketing campaigns.

From May 2018, you will have a right to object to our use of your personal information for these legitimate interests including where we may use your personal information to create a profile to inform customer demographics. If you raise an objection we will stop processing your personal information unless very exceptional circumstances apply, in which case we will let you know why we are continuing to process your personal information. Please contact our Compliance Team via our contact form, should you wish to exercise this right.

Disclosure of your Information
The information you provide to us will be held on our computers and with your consent may be accessed by or given to third parties and our staff for the purposes set out in this policy or for other purposes approved by you. Those parties process information and provide support services on our behalf.
If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners after we have notified you and received your consent to do so.


Cookies

Cookies are small amounts of information which we store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to the site. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalise the content of the site for you. You may set up the browser on your computer to reject cookies although, in that case, you may not be able to use certain features on our Website. If you do not wish to receive cookies in the future, please let us know.

From May 2018 you will have the following rights:
(i) Right to access: the right to request copies of your personal information from us;
(ii) Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
(iii) Right to erase: the right to request that we delete or remove your personal information from our systems;
(iv) Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it;
(v) Right to data portability: the right to request that we move, copy or transfer your personal information;
(vi) Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling to inform our market research and customer demographics.

To make enquiries, exercise any of your rights set out in this Privacy Policy and/or make a complaint please contact our Compliance Team via our contact form If
you are not satisfied with the way any complaint you make in relation to your personal information is handled by us, then you may be able to refer your complaint to the relevant data protection regulator which in the UK is the Information Commissioner’s Office.

This Privacy Policy shall be governed and construed in all respects in accordance with the laws of England and Wales. We work exclusively with our trusted debt solution providers. If you proceed with one of their solution options, we may receive a fee for introducing you to them.

What Do We Do With Your Personal Information?
We can only use your personal information where it falls into one or more of the following categories:
• it is necessary to enter into or fulfil a contract we have with you;
• you have provided your consent;
• we have a legal or regulatory obligation to do so;

Initial Debt Consultation
Where you make an application or enquiry for debt help or other services we offer we’ll use your information to provide you with appropriate information about any solutions we may be able to offer to you. If you cannot provide this information, it may not be possible to progress with your application or enquiry.
We may also use this information to contact you about and process your application, for example, sending you an email, text message or letter to explain about our services.

After you have made you initial debt advice enquiry, if you then decide to go ahead with any of the products or services that we offer, the sections below explain how we will also process your data when we provide that particular product(s) or service(s).

Websites and marketing
To help us understand you and your situation better and provide you with information about other products which we feel may be suitable and relevant, we will use your personal information to create a profile of you and your circumstances. This allows us to provide more accurate service for you. For example, we may assess your creditors owing and household income and expenditure to determine whether you would be eligible for a debt solution.

However, if you don’t want us to profile your personal information this way, to then better enable us to tailor any marketing communications to you, you can contact us to let us know that you wish for your personal data not to be used in this way. 

Legal or Regulatory Obligation
We are required to by law or regulatory bodies to process your personal information, for example, to adhere to anti-money laundering or our regulatory obligations. 

Reviews
Where we have a copy of your personal information we may contact you to ask you to provide a review about our services and advice.

Complaints
If you make complaint to us, we will be required to use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.

Who Do We Share Your Information With?
In addition to the companies, organisations and other third parties mentioned above, we may also share your personal information with the following organisations or companies:
• IT Service Providers who provide IT platforms or other IT services (e.g our CRM
System providers)
• Our authorised debt help partner
• Communication providers (e.g. telecommunications providers)
• Advertisers and social media companies such as Facebook for our social media
accounts or where we can contact you using your social media account

These companies help us to provide our services and solutions to you. We will have a contract in place with any provider who directly provides us with such direct services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place. We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

Automated Decision-Making Systems
An automated decision is one which we rely on a computer or system to assess the information you provide to us to make a decision about you, for example the CRM System mentioned above provides a full financial assessment, this may include:
• assessing your eligibility for a product or service
• credit searches
• checking identity and residency statuses
If we do make an automated decision about you, in some cases you have the right to ask that we do not make our final decision based solely on the automated decision, and you can also object to the automated decision and ask that someone reviews it. 

Fraud Prevention Agencies
We may on occasion be required to share the personal information we have collected from you with law enforcement agencies and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment.

Keeping You Updated
To help us keep you informed about the products and progress of your application, we may contact you by letter, telephone, email, text message, push notifications, social media or other online messaging platforms as agreed. If an application for a product or service is started, we will attempt to contact to regain contact with you using the above methods if we are unable to complete your application for whatever reason. 

If your preference is not to be contacted in any of the above methods please let us know at your earliest convenience, however if we are providing a service to you, we and third parties mentioned above will need to be able to send you communications. This can often be due to a legal or regulatory requirement.
If your contact details or preferences change at all, it is of paramount importance that you update us as soon as possible. Information Shared Outside The EEA
At present we have no reason to share your information outside of the European Economic Area (EEA) but please be assure if we did, we would only share your personal information outside EEA, where we have your consent.

If we do share your information 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. The protection and security of your personal information is a matter we take very seriously, we will take as many precautions as possible in order to protect your data some of the steps we take but not limited to are listed below:
• company security policies and standards
• staff security awareness & training
• role-based access controls to prevent unauthorised access to the information
• encryption and anonymisation technology
• anti-malware & anti-virus technologies
• security monitoring
• secure archiving and deletion
• compliance with industry regulation and legislation

Your Rights
Access to your personal information If you wish to access personal information that we may hold about you, you are able to do this. This is often called a “Data Subject Access Request”. You can request this information by contacting us using the details below. For your protection we may ask for proof of identity before providing the information you have requested. If your personal information is incorrect If the personal information we hold about you is incorrect you have the right to request that we correct this.

Right to suspend, limit or stop the processing of your data
You may wish that your personal information is deleted or that we stop processing the information, you may also wish for us to temporarily suspend the processing of data we have about you. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations. We will however discuss this with you if you request for your information to be deleted.

Data Portability
In some instances, you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically by you or the other company. If you wish to request this, you’ll need to contact us.

Data Protection Officer
Simmons Providence Ltd
Smokehall Lane
Winsford
Cheshire,
England,
CW7 3BE

If you are not happy with how we process your personal information you should contact us in the first instance. If you’re not happy with how we have dealt with your complaint you have the right to lodge a complaint with the Information Commissioner’s Office. 

You can find their details on their website at https://ico.org.uk

How Long Will We hold Your Personal Information?
If you choose to take out one of our products or services and are referred to one of the Third Parties listed above we will retain your records for a period of 6 years. Telephone calls will be retained for at least 6 years from the date the call was made. (see call recordings section for more details)
If you do not go ahead with any product or service offered by us, your personal information will normally be deleted after 2 years unless we have another reason to keep your data, for example, if you have given your consent to receive marketing or promotional messages from us.

Telephone Calls
We record any telephone calls you make to us or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes. As stated above we may keep a copy of the telephone calls for up to 6 years from the date the telephone call was made.

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