Data protection statement - EOS in United Kingdom

Privacy Notice

Who controls the data that you are holding about me?

If you have received a letter from us please refer to the back of the letter and the section Data Protection & Processing this will give you the name and contact details of the data controller and their data protection officer.
Failing that, if you do not have a letter from us or you cannot locate it, please contact us at:

Anthony Jenks
Data Protection Officer

EOS Solutions UK Plc
Lytham House
Kelvin Close
Birchwood
Warrington
WA3 7PB
United Kingdom

Email: dpo@eos-solutions.uk.com

We will be able to tell you the contact details for the data controller and their data protection officer if it isn’t us.

What right do you have to hold data about me and why wasn’t I asked if it was okay for you to be sent my data?

The data controller has given us the data about you to help them collect a debt that is owed under a contract to them.  This gives them a right to send data to third parties such as EOS because there is a legitimate interest in us helping them to collect the debt.  This is allowed for under Article 6 (1) f of the GDPR.

They will have attempted to inform you of our involvement before your details were transferred to us and they will be able to give you more information if you contact them at the address on the reverse of the letter(s) we have sent to you.

Do you collect data about me?

Yes, whenever you communicate with us we will retain a record of the contact and details of what was said.  This information can be recorded because we have a legitimate interest in collecting the debt.  This is allowed for under Article 6 (1) f of the GDPR.

If you share with us details about your health we will ask you for consent to record this special category data; although we will only record information that is relevant to the data controller making a decision about how to handle your case.

Cookies

Like most websites, we use cookies when you access and browse our website in order to make your visit as comfortable and effective as possible. Cookies are small files that are created by the website and are automatically stored in the browser of your device (laptop, tablet, smartphone, or similar). Cookies do not harm your device and do not contain any viruses, Trojans, or other malicious software. Information yielded in connection with the specific device used is stored in the cookie. However, this does not mean that we directly receive knowledge of your identity through this.

Use of cookies serves, for one thing, to make use of our offering more pleasant for you. For example, we use so-called session cookies to recognize that you have already visited individual pages on our website. These are automatically deleted after you leave our website. Likewise, to optimize the user-friendliness, we also use temporary cookies, which are saved on your device for a specific defined period of time. If you visit our website again to use our services, it will automatically be recognized that you already visited us and the entries and settings you made will automatically be recognized so that you do not have to enter them again.

Cookies are divided up into the four categories of “Necessary,” “Statistics,” “Comfort,” and “Marketing.”

Necessary cookies are required for the operation and the basic functions of our website. They enable the security-relevant functioning of this website.

Statistical cookies are used for improving our offering and ensuring a needs-based design and the continuous optimization of our website. For this, we collect anonymized data for statistics and analytics, for example, to determine site traffic, page view statistics, user behavior, and to adapt and improve our content and the website experience.

Comfort cookies are used for facilitating the use of our website. If you visit this website again to use our service, it will automatically be recognized that you were on our website and the entries and settings you made will automatically be recognized so that you do not have to enter them again. For example, through this, you will not have to reenter your user data every time, but rather you can access the data already entered when you visit the website again.

We use marketing cookies so that we can provide you with relevant and interest-based content when you visit our website.

The data processed through necessary cookies are for the stated purposes for safeguarding our legitimate interests pursuant to Article 6 para. 1 sent. 1 lit. f of the GDPR, such as the proper functioning of the site.

The data collected and processed through comfort, statistical and marketing cookies is done under your given consent, in accordance with Article 6 para. 1 sent. 1 lit. a of the GDPR for the purposes of  serving personalized content, for statistical purposes that aim to improve the user experience and marketing purposes. For these you can change/withdraw your consent, by clicking on the Change Cookies settings on the bottom of the website.

Cookie Management

Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a notification message always appears before a new cookie is placed. Each browser differs depending on how it manages cookie settings. This is described in the Help menu of each browser, which explains how to change your cookie settings. Follow the links below depending on the browser you are using:

Complete deactivation of cookies, however, may lead to you not being able to use all of the features of our website.

We use the following cookies:
necessary

Name Java Session Cookie
Provider Owner of this website
Purpose This cookie is used by the application server. It is essential for proper
working of the application software. It stores no personal data. 
Cookie Name jsessionid
Cookie Duration Session cookie - deleted after you quit your browser.
Name cookieconsent_status
Provider Owner of this website
Purpose Necessary cookie to save that the cookie banner was confirmed.
Cookie Name cookieconsent_status
Cookie Duration 60 days
comfort

Name VISITOR
Provider Owner of this website
Purpose We use this cookie to serve personalized content. 
Cookie Name VISITOR
Cookie Duration Session cookie - deleted after you quit your browser.
Name NEW_Visitor
Provider Owner of this website
Purpose We use this cookie to serve personalized content.
Cookie Name new_visitor
Cookie Duration 1 day
statistical

Name nmstat
Provider Siteimprove GmbH
Purpose This cookie is used to help record the visitor’s use of the website.
It is used to collect statistics about site usage such as when the visitor last visited the site.
This information is then used to improve the user experience on the website.
This Siteimprove Analytics cookie contains a randomly generated ID used to recognize the browser when a visitor reads a page. The cookie contains no personal information and is used only for web analytics.
Cookie Name nmstat
Cookie Duration Persistent – expires after 400 days
Name AWSELB
Provider Siteimprove GmbH
Purpose The AWSELB cookie ensures that all page views for the same visit (user session) are sent to the same endpoint. This enables us to determine the sequence of a user's page views needed for features like Behavior Tracking and Funnels.
Cookie Name AWSELB
Cookie Duration Session cookie - deleted after you quit your browser.
marketing

Name siteimproveses
Provider Siteimprove GmbH
Purpose This cookie is used purely to track the sequence of pages a visitor looks at during a visit to the site.
This information can be used to create User Journeys and enable visitors to find relevant information more quickly.
Cookie Name siteimproveses
Cookie Duration Session cookie - deleted after you quit your browser.

What do you do with my data?

We use the data to attempt to contact you and to negotiate repayment of the outstanding debt.  We do not do anything else with your data, it is not given or sold to third parties; it is only ever used to collect the outstanding debt that has been passed to us by the data controller.

It is only ever the data controller (if that isn’t us) that we provide updates on our progress to; so if you talk to us or write to us the details of what you tell us will only ever be shared with the data controller or an advisor who you have authorised to help or work on your behalf.

Who do you share my data with?

If your details are out of date, we will attempt to get current contact details for you to allow us to start the discussion.  To do this we may share your name, address, date of birth and contact details with one or more of the Credit Reference Agencies who will sell us any new telephone numbers or contact emails that they have for you.  If you want to know more about how they process your data please read the Credit Reference Agency Information Notice (CRAIN) which we have provided here.

We do not however share any information with the Credit Reference Agencies that is not needed by them to give us updated information.

Where we have purchased a debt we will share information with the Credit Reference Agencies that identifies us as the debt owner, the default balance and the current state of the default; it will either be recorded as an outstanding default, paid in full, or partially settled.

All movement of your data between us and a third party is made by a secure method and encryption is used so that it remains safe at all times; no communications containing any personal data are ever exchanged by email or in the post.  

Do you send my data outside of the E.U.?

Only rarely if the case is one of the very small number of cases that we deal with each year where you now reside in a country outside of the E.U.  

In that instance we would send your data to a partner company, selected and approved by EOS Group, to contact you locally.  The EOS Group data protection standards would have to be met though and they are set at the same level as they are here in the U.K. and across the E.U.

What happens when you have finished using my data?

We have an agreement with the data controller as to how long we will hold the full data before we start the process of wiping the data so that it cannot be linked to you.  There is also a set date at which point even the partially wiped data will be completely removed from our records.  

If you want to get more information from the data controller, you should contact them at the address on the reverse of the letter(s) we have sent to you and they will be able to tell you more.  The time periods have been agreed between us to allow for any future requests from you to see the data, without us keeping it any longer than we have to.

Do I have a right to withdraw my consent for you to use my data?

Consent for us to use and process your data is not always required and whilst any data subject can withdraw consent at any time, this can only be done where consent needs to be given to use the data.

However, as we have said in the What right do you have to hold data about me and why wasn’t I asked if it was okay for you to be sent my data?  Section above, the reason we are holding your data is for a legitimate interest in the collection of a debt.  Using your data for this reason does not need your consent and so you may not have any right to withdraw consent.

If you have given us consent to record some information about your health that is having an impact on your ability to repay the debt, you can choose to withdraw that consent and both us and the data controller will remove that data.  If the data controller has made a decision on how to handle your case based on that data they will let you know how this change will impact on the collection of the debt.

You have the following rights under Articles 15 to 22 of the GDPR: the right to information, correction, and deletion, restriction of processing and data portability.  To get more information on your rights and for details of any use of your data that has to be consented by you, please contact the data controller at the address on the reverse of the letter(s) we have sent to you and they will be able to tell you more.

Do I have a right to alter or restrict the processing of my data?

The right to restrict processing or alter the data that we have processed about you does exist, but as with the right to withdraw consent, this is only possible in some circumstances.

You have the following rights under Articles 15 to 22 of the GDPR: the right to information, correction, and deletion, restriction of processing and data portability.  To get more information on your rights and for details of any opportunity you have to alter or restrict the processing of your data, please contact the data controller at the address on the reverse of the letter(s) we have sent to you and they will be able to tell you more.

Do you ever use my data in automated decision making?

Some of our processes are automated, such as the sending of letters and the scheduling of calls; but only up to the point that contact is made with you.  Once we have made contact with you, the automation stops and will not resume without warning from us first.

We do not automate any decisions on taking further, or more severe action; these are only ever taken by an employee with sufficient knowledge of the process to make sure the action is appropriate.

Certain administration tasks such as closing a case and returning it to the data controller are automated, but these decisions are straightforward and do not need to be looked at by an employee. 

Who do I talk to if I want to lodge a complaint?

You should first raise your complaint with the data controller whose details are on the reverse of any letters that we have sent to you.  Alternatively contact us at:

Anthony Jenks
Data Protection Officer

EOS Solutions UK Plc
Lytham House
Kelvin Close
Birchwood
Warrington
WA3 7PB
United Kingdom

Email: dpo@eos-solutions.uk.com

We will then refer the complaint to the data controller where that is not us and they will contact you directly.  


Article 77 of the GDPR say that you have the right to complain to our supervisory authority if you think there are valid reasons or indications that the processing we are undertaking is not lawful. If you feel that we have not dealt with your complaint satisfactorily, you can contact the Information Commissioner’s Office at:

https://ico.org.uk/make-a-complaint/

If we change our policy, we will post the changes to this page so please check the website regularly for any changes to this policy. Where required by law we will obtain your consent to make changes to this policy.

July 2020