Newlyn PLC is registered with the Information Commissioners Office (ICO) as the data controller under registration number Z7559829 and have held this licence since 16 January 2003. Our registered address is Century House, Wargrave Road, Henley-On-Thames, Oxfordshire, RG9 2LT.
Newlyn PLC are committed to safeguarding the privacy of all data obtained for the collection of outstanding debts such as Council Tax, Non-Domestic Rates and Parking contraventions.
2. About this Notice
This Privacy Notice explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.
This notice applies where Newlyn PLC are acting as the ‘data controller’ with respect to the personal data of its employees; where Newlyn PLC determines the purposes and means of the processing of that personal data.
This notice also applies where Newlyn PLC act as either the ‘data processor’ and/or ‘data controller’ with respect to the personal data of ‘data subjects’; where the Data Controller determines the purposes and means of the processing of that personal data.
3. Personal data we obtain from others or collect from you
We obtain or collect your personal information through various means, such as from:
Other data is collected through email or other electronic correspondence, by telephone, by direct contact, or if you voluntarily submit it. We only collect information that is relevant to our services and necessary to identify you.
The information we collect is listed below:
Newlyn also obtain additional personal or ‘sensitive’ personal data throughout the processes and procedures for collecting outstanding debts. Additional ‘sensitive’ personal data which has not already been supplied by the data controller but obtained by Newlyn PLC as the data processor such as; Physical or Mental Health Conditions, Criminal Proceedings, outcomes and sentences.
We are required to understand whether the people that we deal with could be regarded as vulnerable and this may involve collecting and using sensitive personal data. We will ask you for some sensitive details or you may voluntarily give such personal data to us and we will only use this information for debt collection purposes. We will obtain your consent to process this data and on occasions will be required to share the sensitive personal data with the client (local authority) to ensure your case is managed appropriately.
Any such data will be obtained for regulatory compliance, self-regulatory practices, crime prevention and detection, for quality control and staff training justified by our legitimate interests or legal obligations.
4. Personal information collected via online forms (from you, the Data Subject)
Our policy is to respect and protect the privacy of anyone who visits the Newlyn website. Where we ask you for personal information via an online form, this information will only be used for the purpose indicated and will be held in a secure manner. It will not be used for any other purpose without your permission and will not be kept for longer than necessary (see section 10).
5. How we use your personal data
All personal information is stored securely and in accordance with the principles of the Data Protection Act 2018 and the EU General Data Protection Regulation.
Newlyn PLC use your data to provide the best possible services to you and to fulfil their legal obligation to staff and enforcement agents acting on their behalf. This includes:
6. Purposes for processing your personal data
We will process your data as necessary to manage and maintain your account until the outstanding debt has been paid.
The credit reference agencies (CRAs), in conjunction with the ICO and major financial services trade associations, developed a common form of privacy notice. The aim of this notice (known as CRAIN) was to ensure that the data sharing and the CRAs’ processing activities are transparent to consumers, in line with the GDPR’s requirements.
Each CRA has produced its own version of this notice.
The notice developed by TransUnion is available at the following URL https://www.transunion.co.uk/legal/consumer-centre
7. Legal basis for Processing your personal data
We will process your personal information as necessary to manage and perform a contract with local authorities:
We will process your personal information for legitimate interests, a legitimate interest is when we have a business or commercial reason to use your data, such as:
We will process your personal information based on legal obligation:
We will process your personal information based on consent:
You are free to change your mind and withdraw your consent to points K and l above at any time.
8. Data Sharing
Newlyn PLC will share your personal data with your consent or as necessary to recover the outstanding debt;
If our business is to be integrated with another business or sold, your details would be shared with our advisors and any prospective purchaser’s advisers. Your information will be passed to the new owners and you would be notified.
9. Cookies and IP addresses
We collect IP addresses only for the purposes of system administration and to audit the use of our site. 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.
10. Data Retention
We keep your data to enable us to fulfil our contract with the UK local authorities, where required by law or to protect legal rights. For example, we will keep your personal data for a minimum of 6 years from the date of account closure for legal purposes and will keep financial records for a minimum of 7 years for accounting and tax purposes.
11. Your rights under the GDPR
Under the Data Protection legislation, data subjects have the following rights with regards to their personal information:
Some rights however, may be limited. We may be obliged by law or regulation to keep information. We must also respect other people’s privacy which means we may need to redact or remove information where it includes personal information about someone else, even if it is connected to you and your information. On occasion there may be a compelling legitimate reason to keep processing data.
If you have any queries regarding your rights, wish to object to how we use your data, or ask us to delete or restrict how we use your information, please contact the DPO as detailed in section 12.
If you wish to make a request for a copy of the personal information we hold about you, please send your ‘Subject Access Request’ to Newlyn PLC, PO BOX 933, Northampton, NN1 9DX or email email@example.com.
To process a request from you, we may need to confirm your identity to ensure we are accessing the right data.
12. How to complain if you are unhappy about the use of your personal data
Should you have any queries relating to this privacy notice, please contact the Data Protection Officer (DPO) via email: firstname.lastname@example.org or in writing to: DPO, Newlyn PLC, PO Box 933, Northampton, NN1 9DX.
Should you remain not satisfied with our data processing purposes and procedures, you have the right to complain to the data protection Supervisory Authority of the UK who is the Information Commissioners Office (ICO). You can contact them at the details below:
Information Commissioner’s Office
0303 123 111313
13. Changes to this Notice
We will update, change or add to this privacy notice in the future so please ensure you check back from time to time so that you remain happy with the changes and the way in which we process your personal data.
This notice was last updated and published on 07.01.2022.