Privacy Policy
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Addresses
· Occupation
· Payment details (including card or bank information for transfers and direct debits)
· Usage data (including information about how you interact with and use our website, products and services)
· Information relating to compliments or complaints
· Video recordings
· Records of meetings and decisions
· Account access information
· Website user information
We collect or use the following personal information for the operation of client or customer accounts:
· Names and contact details
· Addresses
· Account information, including registration details
· Marketing preferences
· Technical data, including information about browser and operating systems
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We collect or use the following personal information for information updates or marketing purposes:
· Names and contact details
· Marketing preferences
· Website and app user journey information
· IP addresses
We collect or use the following personal information for research or archiving purposes:
· Names and contact details
· Addresses
· Purchase or client account history
· Website and app user journey information
· IP addresses
We collect or use the following personal information for recruitment purposes:
· Contact details (eg name, address, telephone number or personal email address)
· Date of birth
· National Insurance number
· Copies of passports or other photo ID
· Employment history (eg job application, employment references or secondary employment)
· Education history (eg qualifications)
· Right to work information
· Details of any criminal convictions (eg Disclosure Barring Service (DBS), Access NI or Disclosure Scotland checks )
· Security clearance details (eg basic checks and higher security clearance)
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Address
· Customer or client accounts and records
· Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
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Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
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Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
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Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
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Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
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Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
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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. You can read more about this right here.
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Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us at contact@starrecovery.co.uk.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
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Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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Information is processed for the purposes of marketing, with this information collected with the express consent and in accordance with the rights of the data subject.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
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Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
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Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
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Information is processed for the purposes of marketing, with this information collected with the express consent and in accordance with the rights of the data subject.
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Our lawful bases for collecting or using personal information for research or archiving purposes:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
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Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Our lawful bases for collecting or using personal information for recruitment purposes are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
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Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Any information we collect or store we obtain from you.
How long we keep information
Retention Schedule
For the purposes of completion of our organisational duties and responsibilities, we collect and process personal data from a variety of sources. This personal information is collected in several ways and can include emails, employment records, documents, statements, images, transcriptions and recordings, operations records and analytics. The personal data is stored in the majority electronically, though some may be stored as a hard copy.
Aims of the policy
Star Recovery will ensure that any and all personal data that we hold is handled, maintained and stored securely in accordance with the General Data Protection (GDPR) regulations of the Data Protection Act 2018. As such, data we store and manage will not be held for periods which are longer than is necessary for the purposes for which it is being processed. In addition, we will retain the minimum amount of information to fulfil our statutory obligations and the provision of our services and organisational activities.
Retention
This retention policy and schedule is used to assist decision making on the retention or disposal of data we collect and store in recognition of the manner of which data is processed within our business practices. Decisions around retention and disposal are to be taken in accordance with this policy.
As and when the retention period for a specific document has expired, a review is always to be carried out prior to the disposal of the document. Careful consideration of the storage, retention and disposal of any data should be taken.
Marketing Data Management
Data collected for the purposes of marketing will be stored for a period of one year from the last correspondence. Your data will only be collected for the purposes of marketing with your express consent. You have the right to withdraw your consent at any time and can do so by selecting ‘Unsubscribe’ from any email marketing, or by contacting contact@starrecovery.co.uk.
Disposal
Our business must ensure that personal data is securely disposed of when it is no longer needed. This will reduce the risk that it will become inaccurate, out of date or irrelevant.
The methods of disposal are to be appropriate to the nature and sensitivity of the documents concerned and include:
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Non-Confidential records
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Confidential records
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Deletion of Computer Record
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Transmission of records to an external body
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Cloud storage
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us via contact@starrecovery.co.uk.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113