Privacy Policy

1. Privacy Notice

At Wilson & Roe, we take your privacy very seriously. This policy outlines how we will hold, process and properly safeguard any personal data that we collect from you or that you provide to us. It contains important information about what to expect when we collect personal information via all platforms, including when you visit our website, when you subscribe to our marketing communications or during the performance of our business activities as High Court Enforcement Officers. It further explains the specific ways in which we use and disclose that information. It also identifies what to do if you have any questions, queries or concerns.

In accordance with the UK General Data Protection Regulation (GDPR), this policy applies to information we collect in regards to:

Visitors to our website
Persons that subscribe to our communications; i.e. newsletters
Debtors
Clients

For the purpose of the GDPR, where information is collected directly by us or provided directly to us by you, Wilson & Roe (we/us/our) is the Data Controller of your personal information.

Wilson & Roe High Court Enforcement is a company registered in England and Wales under company number 13460661. Our registered office is 26 Missouri Avenue, Salford M50 2NP. We will observe all obligations under the GDPR in relation to any personal data that is held by us.

We take all necessary steps to comply with our obligations under the GDPR and all relevant legislation. We are required to collect personal information fairly and to identify how we will use the data and to confirm if we pass information onto a third party. We will comply with all Articles set out in the GDPR and will ensure all personal data supplied to and processed by us is held securely. We will continuously review our policies and procedures in line with the relevant legislation and regulation updates to ensure continued compliance.

2. The information we collect about you

We may collect and process the following personal information about you through our website or during the course of our business activities:

Information that you provide by filling in forms on our website. This includes information provided at the time of submitting forms or requesting further services;
Information received in correspondence that you send to us;
Information received during telephone calls;
Information received during the course of the execution of a High Court Writ, or our business generally as High Court Enforcement Officers.

We may also collect information about you in other ways, for example:

If you provide us with your business card;
If you are a client of ours – during the course of that relationship;
If you are a customer of one of our clients, and we are instructed to carry out services on your behalf;
Indirectly, through one of our staff, a client or a third party;
If you supply services to us.

Some or all of the following data may be collected about you:

Name;
Date of birth;
Gender;
Business or company name;
Job title or profession;
Home or business address;
Contact information such as email addresses and telephone number;
Financial information;
Debit card, credit card or bank details for payment purposes only;
Sensitive personal data arising from the debt collection or enforcement process, such as information relating to your physical, mental health or well-being;
Any personal details of incidents occurring during the debt collection or enforcement process;
Vehicle registration keeper details;
Property ownership details;
Visual and audio recordings of you through our use of Body Worn Video equipment;
Details of your visits to our website including, but not limited to, traffic data, location data, weblogs, operating system, browser usage and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

If you wish to notify us that any of the information which we hold about you is incorrect or misleading, we will have the information corrected in a timely manner. You may do this by sending an e-mail to our Data Protection officer at wr@wilsonandroe.com.

3. Sensitive personal data

GDPR defines certain sensitive personal data as special category data, including; data regarding physical or mental health, ethnic origin, religious beliefs or political views etc. We will make every attempt to understand whether the people that we deal with could be regarded as vulnerable. This may involve collecting and using sensitive personal data, during the course of our business activities. We may request sensitive personal data or you may volunteer this information to us, however, we will only use this information for debt collection or enforcement purposes and we will obtain your consent to process this data. We may share your sensitive personal data with our client to ensure your case is dealt with in an appropriate manner. Any sharing of your sensitive personal data will be on the basis that we have your explicit consent or if we are required or permitted to do so under the GDPR.

4. Call recording and body-worn camera footage

Personal data

Whether or not we record calls, obtain images, or capture audio data via our body cameras as part of enforcement will depend upon the nature of your relationship with us.

We operate a dedicated telephone line which debtors/defendants can use to make enquiries regarding payment of debt or in respect of property services. Calls to this line may be recorded.

When calls are recorded, we collect:

Audio recording of the conversation
The caller's phone number

Our body worn cameras record and collect:

Images and video footage
Audio recordings

Body-worn cameras also have the potential to collect sensitive (special category) personal data that may be visible in the images or audio recorded.

Purpose

Call recordings will be used to:

To meet our regulatory requirements
Assist in quality monitoring of staff
Investigate and resolve complaints
Support the detection, investigation, and prevention of crime, including fraud
Ensure staff are acting ethically and within the powers of the relevant Writ
Assist in staff training
Provide feedback to clients

Body-worn cameras are used:

To meet our regulatory requirements
As part of our enforcement activities
To provide an open and transparent service
For the safety and security of officers, customers, debtors, and other affected parties
As a deterrent to acts of aggression including verbal and/or physical abuse towards our officers
To assist the training of staff

Legal basis

The legal basis upon which we process and record telephone calls and use body-worn cameras is that it is necessary in the legitimate interests of our business to do so.

If the personal data amounts to special category data, such as health-related data, then this is processed this on the lawful basis of the legal claim against you on behalf of our client.

Sharing of personal data

We may share, or be asked to share, with our clients a telephone call recording, body-worn camera footage, or information we have gathered. This is to enable them to respond to a complaint or provide us with instructions.

We may also need to share this data with the Enforcement Conduct Board to meet our regulatory requirements.

Your personal data will only be shared with any person or organisation not listed above when we have your prior consent to do this.

Under Data Protection legislation, we may be required or permitted, to disclose your personal data without your explicit consent, for example, if we have a legal obligation to do so for reasons such as:

Law enforcement
Fraud investigations
Regulation and licensing
Criminal prosecutions
Court proceedings

You may request that your call isn't recorded. In this situation, you will normally be advised to contact us either in writing or via email.

In exceptional circumstances you may be transferred to a non-recorded phone. This decision will be made by a director in situations where, for example, it is determined that not doing so could cause harm or distress to the caller.

It is our policy that any enforcement agent wearing a body worn camera should activate it only when appropriate in the proper performance of their official duties and where making recordings is consistent with this policy and the law.

We do not permit enforcement agents to use any recording devices without the knowledge of the third party. We process personal data to include images and audio recording as well as the potential to collect sensitive (special category) personal data to the extent that it is visible in the images or audio recorded.

Our calls are recorded and stored securely in the cloud for three months, after which they will be automatically destroyed. If a complaint is raised, the call will be stored for six months or until the complaint is resolved, whichever date is later. In the event that a call is requested under a subject access request (SAR) by a law enforcement agency such as the police or our regulator, the call will be downloaded and retained until such time as it is no longer necessary, for example, the conclusion of a police investigation.

If we wish to use your call recording (or any personal data acquired during a call with us) for a new purpose not covered by this privacy notice, we will provide you with a new notice.

The new notice will:

Explain the new usage before we begin the process
Set out the relevant purposes and processing conditions

Where necessary, we will seek your consent to the new processing.

5. How we will use information collected about you

The way we process your information varies depending on our relationship with you. We will use some of the personal information supplied by you to; ensure that we keep you up to date with what's happening in our business and the industry we work in, to keep a record of the services you have shown an interest in, to notify you about changes to our services or to deliver services you may have requested. We may use some of your personal information to contact you as part of the services we are providing or to inform you of events or new products or services that we think may be of interest to you.

If you have provided us with your contact details, we may contact you by email, telephone or by post. We will not contact you for direct marketing purposes if you have told us that you do not want us to use your personal data for this purpose. We will not share your personal information with third parties for marketing purposes.

You can change your communication preferences at any time by emailing us at wr@wilsonandroe.com.

We may disclose your personal data to third parties if we are under a duty to disclose or share your personal data in order to comply with a legal obligation, our customers, or others or if it is in the public interest.

6. Legal basis for processing

We will only process personal data where there is a lawful reason for doing so. We may process data;

During the performance of a contract or service;
By reason of legitimate interest;
By way of consent;
As a result of a legal obligation for compliance purposes.

7. Retention of your personal data

We do not retain personal data for longer than is necessary, unless required to do so by law. We retain all data for a maximum period of six years and only for as long as is reasonably necessary for the purpose for which the data was obtained. Data is retained and destroyed securely in accordance with our legal obligations.

8. Protecting your information

Data security is of the upmost importance to our business and we have worked hard to ensure we have suitable and sufficient physical, electronic and procedural safeguards in place to protect all data we collect. Where possible all data is stored on our secure internal servers. Where paper copies are required as part of a legal process, these are stored securely prior to being shredded securely by a third party provider.

Where data is collected for marketing purposes, we will also hold your data on MailChimp servers which are located in the United States, so your information may be transferred to, stored, or processed in the United States. MailChimp participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. To learn more about how your data will be stored through MailChimp, you can view their privacy policy online www.mailchimp.com/legal/privacy.

Although we will do our best to ensure we protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent any unauthorised access.

9. Accessing, updating and correcting your information – your rights

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email wr@wilsonandroe.com, or write to our Data Protection Officer at; Wilson & Roe High Court Enforcement, 26 Missouri Avenue, Salford, M50 2NP.

We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to us changes, for example if you change your email address or name, please let us know the correct details by sending an email to wr@wilsonandroe.com and we will ensure it is updated.

10. Links to other websites

Our website may contain links to other websites. This Privacy policy applies only to the Wilson & Roe website so when you access links to other websites you should also read their own privacy policies.

If you have any questions, comments or concerns about our privacy policy, or if you simply want to update, delete, or change any Personal Information that we hold about you then please email us directly at wr@wilsonandroe.com. We aim to respond to you within 48 hours.

11. Changes to privacy policy

Updating our privacy policy helps to improve your experience with us and helps to protect both you and ourselves. We therefore reserve the right to alter this privacy policy without notifying users of the changes made. Any updates to the privacy policy will be done so on our website and will be in effect immediately after posting.

This policy was last updated: April 2024