FreshStart Solutions is a intermediary referral business. This Privacy Notice explains how we use the personal information we collect about you when we provide our services to you. Our lawful basis for processing is ‘contractual’ however we also request your consent to record or share special category data, and to carry out marketing of our products and services or the use of third parties.
What Personal Information do we Collect?
In order to provide our services under the contractual agreement, we collect ‘Personal Information (data)’ that uniquely identifies you. The below explains the information we collect and why.
The categories of your personal data we collect include: Why we want the data, and what we will do with it:
Personal Descriptors
e.g. Name, age, date of birth, passport/or driving licence
We require this to identify you and communicate with you.
You cannot opt out of providing this information.
Financial Information
e.g. Income, expenditure, assets, liabilities, bank statements, benefits details, wage slips, tax returns, default history, legal action or county court judgements, previous credit history, credit reference information, bank account and debit card details.
We require this to provide certain services, such as to make payments to creditors on your behalf. Not all of our services require us to collect this information however it is a contractual requirement for services such as an insolvency or debt management solution.
You cannot opt out of providing this information.
Employment Information
e.g. Employment status, Occupation, pay date, salary amount, professional occupational status (e.g. Dr., Company Director, Police officer)
We require this to provide certain services such as to assess your eligibility for debt solutions. Not all of our services require us to collect this information however it is a contractual requirement for services such as an insolvency or debt management solution.
You cannot opt out of providing this information.
Life Information
e.g. Marital status, number of child dependents, approximate ages of child dependents, general household details
We require this to provide certain services, such as assessing what you can afford to pay towards your debts. Not all of our services require us to collect this information however it is a contractual requirement for services such as an insolvency or debt management solution.
You cannot opt out of providing this information.
Health Information
e.g. Physical or mental disabilities
We may collect certain special category data to identify if you are potentially vulnerable or require further support.
You can opt out of providing this information.
Who Collects your Data?
Within the Open Mind Group of companies there are multiple data controllers. In your contractual agreement it should be clear which of the below is your primary data controller.
Registered Data Controllers
Which typical services apply –
FreshStart Solutions, trading as Bailiff Helper Team (ICO Reg: C1204777)
If you receive debt advice or use our ancillary services
How do we (your Data Controllers) receive your Information?
We may receive information directly from you, any third party you appoint to act on your behalf, legal parties, your creditors, your bank, credit reference agencies or law enforcement. In some cases, we may receive other information about you, such as details of a health condition from your health professional.
Website
If you use our website we may collect your IP address, cookies, browser information, and use plugins that collect your information (e.g. Google Analytics, WordPress, and Yoast SEO). Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This is used to track visitor use of the website and to compile statistical reports on website activity.
For further information visit www.aboutcookies.org or ico.org.uk/concerns/cookies/
You can set your browser not to accept cookies and can find out more information in the links above, however in some cases our website features may not function as a result.
Other websites or services that sit outside of FreshStart Solutions
Our websites and communications contain links to other organisations and websites. This Privacy Notice only applies to the Open Mind Group. When you visit the websites of other organisations you should read their own Privacy Notice.
How do we use your Information?
The main lawful basis for processing your information is for the performance of the ‘contract’ namely to collect your information and refer you to a specialist licenced Debt Advice firm to conduct a full assessment of your circumstances. To collect special category information or to process your information for certain purposes (IE Direct Marketing) we require your explicit and informed consent. Where this applies it will be made clear to you.
On occasions our lawful basis for processing your information may change for example, if it is necessary for your vital interests (e.g. to protect your life) or where we have a legitimate interest in processing your information (e.g. for statistical data purposes), however where possible this is usually anonymised to safeguard it.
Our main purpose for processing your personal information is to provide the services you have requested us to provide to you as specified in the terms and conditions/contract. For example; If you require debt advice, an Insolvency or debt management solution we need to collect information to assist you with your financial difficulties. If you require legal services we need to collect information to give you appropriate legal advice. To collect special category information, or process your information for certain purposes (i.e. direct marketing) we require your explicit and informed consent. Where this applies it will be made clear to you.
Transferring and sharing your information
Due to the service we offer we will share your information with other parties as without doing this we (or they) cannot carry out the service specified within the contractual agreement. Namely referring you for specialist Debt Advice. We use a panel of licenced firms to assist you and these are
- ✓ MoneyPlus Advice
In addition, from time to time, we use the services of external consultantsor outsource certain aspects of our processes to other organisations, some of whom may be located outside of the EU (European Union). We keep outsourcing activity to a minimum however on occasion these organisations may assist us such as with quality monitoring, scanning, marketing, identity verification checks, audits, record keeping or printing. All outsourced service providers are carefully vetted and monitored to ensure the safeguarding of your information.
In accordance with our legal obligations we may be required to share information with the police, other law enforcement, government agencies or regulatory bodies.
You also have the option to appoint someone else to act on your behalf such as a spouse or carer with whom we can share your information with. You will need to provide separate explicit consent for us to be able to share your information with them, and you can revoke this consent at any time.
Your Individual Rights:
– You have the right to access your information at any point and can check what information we hold and process about you by contacting us on the details below. You have the right to copies of the information we hold about you. Contact us on the details below to request this. This will be provided free of charge in most circumstances. You should contact us to exercise this right and we will respond within one month.
– You have the right to rectify any information you believe is incorrect. FreshStart Solutions regularly refreshes and check your information to make sure it is as accurate as possible but if you believe any details are incorrect, you can request this is amended or removed by contacting us and we will respond within one month to confirm the actions taken.
You have the right to request the erasure of your information if you withdraw your consent to FreshStart Solutions processing this information and in other circumstances. You should contact us to exercise this right and we will respond within one month.
– Restrict the processing of your data in certain circumstances, for example, if you contest the accuracy of the information, if you object to the processing of the information we hold about you, if you oppose the erasure of the information and instead insist on restricted processing. You should contact us to exercise this right and we will respond within one month.
– Data portability which means that we are able to provide you with your personal information in a structured, commonly used and machine readable form free of charge. This enables other organisations to use your data. If you require, FreshStart Solutions can supply this information directly to another organisation if technically feasible. You should contact us to exercise this right and we will respond within one month. This may be extended to two months if the request is complex and we will notify you if this is the case.
– To understand and control automated decision making including profiling. When providing our services we may use profiling and automated decision making processes e.g. the online annual review process. You can opt out of this process by contacting us. We have additional checks in place to protect any vulnerable groups and oversee the accuracy of decision making systems. The use of automated decision making systems requires the user (you) to input specific information and there are procedures for you to edit this information throughout the process and simple ways to request human intervention or challenge a decision.
– To withdraw your consent. You cannot remove your consent to some of the information we process without the contract being terminated, however you can opt out of providing some information i.e. special category data, or request its erasure. In accordance with your terms and conditions you have the right to withdraw from the contract at any time and you can use the contact details below to exercise this right.
How we secure and retain your Information
We retain your information for the full duration of our contractual relationship to enable us to provide our service. We keep your information for a maximum of six years following closure of your account to comply with our legal and regulatory requirements. Any personal information we do not believe is necessary to provide our service, and all information outside of the retention period, is securely destroyed and deleted. We conduct our services through computer systems and any paperwork or documents we receive may be scanned to this system. If you need to send us important documents, please make sure you keep a copy.
All personal information we hold is securely stored, and we conduct regular testing of our cyber and physical security procedures to ensure this is maintained. If at any time we believe there has been a breach of your personal data we will notify you immediately.
If at any time you believe your personal information may have been shared with an unauthorised party you must let us know as soon as possible.
You are responsible for keeping any personal passwords or similar security information private, including personal information you disclose on social media. If you have any concerns about how we have handled or protected your information, we would hope that you contact us to discuss this. You can also escalate your concerns to the UK’s data protection regulator the Information Commissioner’s Office (ICO), more information can be found at: www.ico.org.uk.
Marketing
FreshStart Solutions collects personal information when you register with us or agree to our products or services. We use this information to provide the services requested, and if you agree, to send you marketing information. You can withdraw your consent for Marketing by contacting us at any time.
We will never share your details with third party companies for marketing unless you have given us your explicit consent. From time to time, we may identify products or services offered by firms within the Open Mind Group that could be of interest to you. Unless you tell us otherwise, we have a legitimate interest to let you know about these services, especially where it could help save you money.
You will receive information routinely from FreshStart Solutions that is not marketing but forms part of the service we provide to you such as; Newsletters, updates, regulatory obligations i.e. complaints procedure.
How to Contact Us
Please contact us if you have any questions about this Privacy Notice or Information we hold about you:
Email: info@bailiffhelperteam.co.uk
Post: For the attention of the Compliance Department, 137 Featherstall Road North, Oldham, England, OL9 6QB
Changes to our Privacy Notice
If we change how we plan to use your information in the future, we will give you 14 days notice of this. You have the right to refuse any such changes but it may result in the termination of our service if this refusal affects our ability to provide the service to you.
Last Publication Date: March 2024