Andrew James Enforcement Limited (“AJE”, “we”, “our”, “us”) is a registered data controller with the Information Commissioners Office (“ICO”). Our registration number is Z8092126 and our registered address is Latheron Chambers, 41 Mansel Street, Swansea, SA1 5SW.
AJE is committed to safeguarding the privacy of all data and we manage and process personal information in a lawful manner. We protect your privacy in accordance with the Data Protection Act 2018 (“DPA”) and the General Data Protection Regulation (“GDPR”) which regulates the storage, processing and use of personal data.
When we accept instructions from our Clients we process the data that they provide and for this purpose we are a Data Processor. In the provision of our Services to our Clients we collect data about you and for this purpose we are a Data Controller. You, as a natural person, are the Data Subject.
About This Notice
This Privacy Notice explains how we use and disclose any personal information that we collect about you, the Data Subject, when providing professional services to our clients. Our clients may include local authorities; courts; government agencies; corporate bodies; limited companies; private individuals (“Clients”). Our services include the execution of magistrates’ liability orders; warrants of control; arrest warrants and collection of general debt (“Services”).
This Privacy Notice applies when AJE act as either the Data Processor and/or Data Controller in respect of the personal data of all Data Subjects.
Personal Data We May Collect From You and/or Other Parties
AJE will collect your personal data from:
· Our Clients;
· Information that you provide to us during our interaction with you;
· Credit reference companies;
· Tracing companies;
· Social media;
· Information that a third party provides to us on your behalf;
· Our products and services used in the provision of our Services
AJE will process some or all of the following data information about you:
· Your full name;
· Alternative names that you may use or be known by;
· Your date of birth;
· Your address history;
· Landline telephone number(s);
· Mobile telephone number(s);
· Email address(es);
· IP Address(es);
· Employment status;
· Job title;
· Business, company or trading name;
· Financial information (i.e. debit or credit card details that you provided to us when making payment);
· Your bank details (i.e. account details that you have provided to us when making payment);
· Information in respect of your financial status and circumstances;
· Information from credit reference companies, electoral roll, court records of judgments and bankruptcies and other sources available publicly;
· Personal data of any discuss with/third parties acting on your behalf to verify who they are; name, address, relationship to you;
· Visual and audio images of you captured through any use of body worn video cameras and/or audio recording equipment;
· Personal data collected arising from debt collection and enforcement processes, some of which may include sensitive personal data relating to health (physical and/or mental); criminal proceedings;
· Data in connection with a visit or visits that have been made by an AJE employee or representative;
· Facebook, Twitter, LinkedIn, Instagram and/or other social media sites;
· Complainants and other individual’s information in relation to a judicial service complaint or enquiry;
· Details of your vehicle which may be captured on Automatic Number Plate Recognition (ANPR) technology;
· HPI (Hire Purchase) data check;
· Vehicle registration keeper details recorded by the DVLA.
Purpose For Processing Your Personal Data
AJE will process and use your data to:
· Provide our Services to our Clients;
· Maintain accurate records of you and to verify your identity;
· To respond to enquiries and communications from you, your representatives and from our Clients;
· To process and allocate payments to your account(s) in line wine PCI DSS guidelines;
· To instruct where necessary with credit reference companies and tracing companies to locate your whereabouts;
· To rely on and use in evidence as necessary in any legal proceedings instituted against or by AJE.
Legal Basis for Processing Your Personal Data
AJE is legally entitled to process data about you as our Services are carried out under judicial process and/or in the public interest.
Sharing Your Personal Data
AJE will treat all personal data that we process or collect about you as strictly confidential. Notwithstanding this we may contract or employ third parties to facilitate services to assist you in your dealings with AJE. These may include on-line or automated payments processing and mailing services. Access to some/all of your data may be necessary and in such circumstances AJE will act responsibly to ensure that your data is handled lawfully and securely by us and the relevant third party.
AJE may also instruct or contract the professional services of consultants, accountants, auditors, solicitors and other members of the legal profession. Access to some/all of your data may be necessary and in such circumstances we will act responsibly to ensure that your data is handled lawfully and securely by AJE and the relevant third party.
AJE may in some circumstances also be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. This may be to combat illegal activities such as fraud, money laundering and other crimes. The use of personal data in these circumstances will be restricted to data in connect with the Services that we provide and necessary to identify you. We do not require any consent from you to share your data in such circumstances and will comply, as required, with any legally binding request that is made of us.
Transfer of Data Abroad
We do not transfer any of your personal data outside of the European Economic Area.
Cookies and IP Addresses
We collect IP addresses only for the purposes of system administration and to audit the use of our website. We do not link IP addresses to anything personally identifiable, which means that while your user session will be logged you will remain anonymous to us.
Retention of Data
In accordance with GDPR principles and our processes we will retain your personal data no longer than is reasonably necessary. Ordinarily this would be seven years from the time that your dealings with us are concluded. This period affords sufficient time for us to respond to any queries that may be raised by you, your representative or relevant authorities such as HMRC in respect of issues pertaining to your accounts. It also affords for us to be able to respond to legal challenges which we can be instigated up to six years after events have occurred.
Our Services are carried out under statutory legislation, codes of conduct, and contracts. We do not make automated decisions.
Changes to Our Privacy Notice
From time to time AJE may make changes to this Privacy Notice to ensure that it is accurate and up to date and to reflect any changes in the law and the way that we process your data. This policy was last updated on 25 May 2018.
Changes to Processing
If our Services or business model changes and we wish to use your personal data for a new purpose not covered by this Privacy Notice then we will produce a new notice prior to the changes. We will set out the relevant purposes and processing conditions within the new notice before processing any data in connection with the changes to our Services or business model.
Your Rights Under the GDPR
The GDPR provides you with the following individual rights:
· The right to be informed about the processing of your personal data;
· The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
· The right to object to the processing of your personal data;
· The right to restrict processing of your personal data;
· The right to have your personal data erased (right to be forgotten);
· The right to request access to your personal data and how it is processed;
· The right to move copy or transfer your personal data (data portability).
AJE may be obliged by law or regulation to retain your data information so some of your rights may be limited. On occasion there may be a compelling legitimate reason for us to keep processing your data. We must also respect the privacy of other people. Accordingly, we may need to redact or remove data where it includes personal information about someone else, even if it is connected to you and your data.
You may wish to make a request in respect of the personal data that we hold about you. You should send a Subject Access Request (“SAR”) to Andrew James Enforcement Limited, Latheron Chambers, 41 Mansel Street, Swansea, SA1 5SW or email email@example.com To process your SAR, we may need to confirm your identity to ensure we are accessing the correct data.
If you are not satisfied with our response you can make a complaint to the ICO which is the United Kingdom regulator in respect of data privacy. The ICO’s address is Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. More information in respect of the lawful processing of data can be found on the ICO’s website www.ico.org.uk