2019 PRIVACY NOTICE
This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulation (GDPR) which is EU wide and far more extensive, seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.
Paladin Commercial is pleased to provide the following GDPR information:
Who we are
Paladin Commercial are a credit management company based in Watford, Hertfordshire, and deal with the collection of consumer and commercial debt, including regulated and non-regulated accounts.
Paladin uses the information collected from you to provide quotations, make telephone contact and to email you. In you making initial contact you consent to Paladin using your data for the purpose of which it was gathered. Paladin also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Paladin will be acting on the instruction of its client and will work hard to ensure that the client is fully GDPR compliant.
Any information Paladin holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers.
Paladin will only collect the information needed so that it can provide you with required services, we do not sell or broker your data, although there may be times when your information could be contained in data that Paladin has purchased from a third-party, on behalf of a client.
Legal basis for processing any personal data
- To meet Paladin’ contractual obligations to clients and customers.
- Legitimate interests pursued by Paladin and/or its clients
- The collection of outstanding regulated and un-regulated debts.
Through agreeing to this privacy notice you are consenting to Paladin processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing email@example.com or by phoning +44 1923 800397 or writing to us, see last section for full contact details.
Paladin may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Paladin requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Paladin do not broker or pass on information gained from your engagement with the agency without your consent. However, Paladin may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Paladin, its clients and/or the wider community.
Paladin will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted. Our full data retention policy outlines this detail and can be requested at any time.
Data is held in the United Kingdom using different (multiple) servers.. Paladin does not store personal data outside the EEA. Data is backed up on a cloud-based system called Backup Pro, by Redstor St James’ Wharf | 99-105 Kings Road | Reading | Berkshire | RG1 3DD Data is password protected and can only be accessed by the Paladin IT administrator.
Your rights as a data subject
At any point whilst Paladin is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Paladin refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Paladin at your request can confirm what information it holds about you and how it is processed
You can request the following information:
- Identity and the contact details of the person or organisation (Paladin) that has determined how and why to process your data.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Paladin or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what personal data is held, identification will be required
Paladin will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Paladin is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to firstname.lastname@example.org or by phoning 44 1923 800 397or writing to us at the address further below.
34 Clarendon Road
+44 1923 800 397
0303 123 1113