Privacy Policy Online
Your privacy is very important to us. We promise to respect and protect your personal information and try to make sure that your details are accurate and kept up to date. This Privacy Policy sets out details of the information that we may collect from you and how we may use that information. Please take your time to read this Privacy Policy carefully. When using our website, this Privacy Policy should be read alongside the website terms and conditions.
This Privacy policy (“Privacy policy”) applies to the use of the website and products provided by (hereinafter also referred to as “we” or “us”). Our registered address is at Dukes Bailiffs Limited, 7 Newcastle Street, Stone, Staffordshire, ST15 8JT. Registered no.: 4418615.
1.Our processing of your personal information
In this privacy policy, we refer to individuals whom we collect debt from and carry out enforcement action against as “Customers”.
The personal information that we will collect will depend on our relationship with you. For example, we will collect more detailed information about you if you are a Customer than we would if you simply enquired about the services that we offer. Please look in the section below that best describes your relationship with us.
Note: Sometimes we will ask for information relating to your health which is known as ‘special categories of information’. When we are carrying out enforcement activities, we are required to determine whether those subject to enforcement action could be regarded as vulnerable. To make this determination we may ask you for, or you may volunteer to give us, information about your vulnerability.
If you provide personal information to us about other people you must provide them with a copy of this Privacy Policy and obtain any consent where we indicate that it is required for the processing of that person’s information in accordance with this Privacy Policy.
1.1. Website Users
This section will detail what personal information we collect about you and use if you use our website, either browsing or interacting with the website to send us a message or register a complaint.
1.1.1. What personal information we collect
Any information you may share with us when you visit our website via forms, subscriptions etc
Technical information about any visit that you make to our website, including IP address, login information and information about your web browser and operating systems.
1.1.2. How we collect your personal information
Via contact forms and visits to the website.
1.1.3. What we use your personal information for
We may process your information for a number of different purposes. We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:
keeping business records
developing and testing our systems
diagnosing any problems with our website
responding to enquiries
assessing usage of our website
improving the services we offer
sending marketing materials (when you sign up to receive our comms)
1.1.4. Who we share your personal information with
We use third-party analytics services to help understand your usage of our website. Additionally, we may share your personal information with the following third parties:
Yell.com
Our clients who have instructed us to carry out debt collection and enforcement services on you
Squarespace.com who are our website providers
If you would like further information regarding the disclosures of your personal information, please see email dpo@dukeslimited.co.uk
1.2. Individuals who we collect debt from and carry out enforcement action against
This section will detail what personal information we collect about you and use if we have been asked to carry out enforcement action against you and collect debt from you on behalf of our clients.
1.2.1. Personal information we collect
Name (surname, forename, middle name)
Title
Age range
Deceased date (where applicable)
Address
Email address
Phone number
Gender
Identity (NI number, Driving Licence number)
Business or company name
Profession
Job title
Employment status
Employer details (employer name, occupation, office, registered office, start date, salary)
Car registration and keeper details
Visual and audio images of you through our use of body-worn video (BWV), vehicle camera, and audio recording equipment
Council tax band of your address
Credit reference data
The location of your address or vehicle
Financial information such as credit/debit card information
Bank details that you have permitted us to use on your behalf
Date of birth
Information relating to your financial status/solvency
Information relating to your debt
Any information in client’s notes
Details about the property associated with a visit
Personal information collected under the debt collection and enforcement process
Means form information
Information obtained from credit and tracing checks including lifestyle information such as whether you are ex-directory, have active credit, or do online shopping
Information obtained from public sources such as social media profile names
Caller line identification
Recording of telephone calls
Technical information about any visit that you make to our website, including IP address, login information, and information about your web browser and operating systems.
1.2.2. Special categories of information that we collect
Information about your physical and mental health, in particular, information about any disabilities you may have, illnesses or medical conditions, or whether you are pregnant.
1.2.3. How we collect your personal information
From information provided by our clients when they register a new case with us
From third-party Credit Reference and Tracing Agencies
From public sources such as Google
From the DVLA
From specialist third parties whom we liaise with to carry out our services such as hire purchase information providers, removal companies, and auction houses
Where we visit your address, from our agents’ body worn video, vehicle camera and audio recording equipment
Other parties residing or otherwise present at your property when it is attended by enforcement officers
From information you provide when you register an online account or update your profile on our Customer Portal
From our website through the use of cookies.
1.2.4. What we use your personal information for
We may process your information for several different purposes. For each purpose, we have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:
keeping business records
using your personal information to carry out our debt collection and enforcement services
ensuring that we have up to date records
management information
statistical analysis
developing and testing our systems
analysing our business
improving the services we offer
research and statistical projects in which we are involved from time to time
carrying out strategic reviews of our business model.
We are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need:
It is necessary to comply with a legal obligation. For example our obligations under the law to protect vulnerable people.
We have your consent. Your consent is required for us to process personal information provided by you on our Customer Portal, and to share information with the Money and Pensions Service. You do not have to provide your consent and you can withdraw your consent at any time. You do not have the right to withdraw consent where we are not relying on your consent.
When we use your “special categories of personal information” (such as information about your health), we need to have an additional “legal ground” and we will rely on the following “legal grounds”:
That it is in the substantive public interest. Such as where it is necessary under the law in order to protect the interests of vulnerable
Research and statistics. where we partner with a research body/trade industry body, such as the Enforcement Conduct Board (“ECB“), to assist them in carrying out research into the industry, this may involve us sharing anonymised and/or pseudonymised BWV footage with a research company for them to analyse.
1.2.5. Who we share your personal information with
From time to time, we may share your personal information with the following third parties for:
Our clients who have instructed us to carry out debt collection and enforcement services on you
Credit reference and tracing agencies including Experian Ltd, TransUnion International UK Ltd and Equifax Ltd. See links below for their privacy notices:
Ecospend Technologies Ltd for the processing of Open Banking payments
CivicaMail and Fun Asset Ltd for the provision of correspondence and mailing services
Google for the geocoding of addresses
TelSolutions Ltd for the sending of SMS to get in touch with you, to remind you of payments that are due and to provide receipts of payments made
The DVLA
The Police and Courts
Vehicle Recovery and Removal Firms
Auction Houses
Legal advisers
Self-employed enforcement agents to assist in delivery of our debt collection and enforcement services
Other parties residing or otherwise present at your address when it is attended by enforcement agents
Other 3rd parties with whom you have authorised us to discuss your personal circumstances
Money And Pensions Service (MAPS) with your consent
Research companies that have been appointed to view personal information (particularly BWV footage) to undertake research and produce anonymised reports for the ECB (an independent oversight body for the debt collection industry, which Dukes is active in)
If you would like further information regarding the disclosures of your personal information, please email dpo@dukeslimited.co.uk.
1.3. New Occupiers
This section will detail what personal information we collect about you and use if you are a New Occupier of an address that our records indicate was previously occupied by a customer.
1.3.1. Personal information that we collect for new occupiers
Name and address
Evidence that you are the current occupier of the address
Recording of telephone calls and any information contained in notes of the call
Visual and audio images of you through our use of Body Worn Video and audio recording equipment
Photos and any information contained in any notes made by our agents when they visit your property
Technical information about any visit that you make to our website, including IP address, login information and information about your web browser and operating systems
New occupier evidence that you send us via post, website forms or email.
1.3.2. How we collect your personal information
From call recordings and where we visit your address, from our agents’ body worn video and audio recording equipment
From details you provide when sending correspondence or completing a form on our website
From our website through our use of cookies.
1.3.3. What we use your personal information for
We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:
keeping business records
using your personal information to carry out our debt collection and enforcement services
ensuring that we have up-to-date records
management information
statistical analysis
developing and testing our systems
analysing our business
improving the services we offer
carrying out strategic reviews of our business model
When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need.
Your consent is required for us to process new occupier evidence provided by you via post, email or a form on our website. You do not have to provide your consent and you can withdraw your consent at any time. You do not have the right to withdraw consent where we are not relying on your consent.
1.3.4. Who we share your personal information with
From time to time, we may share your personal information with the following third parties for the purposes set out above:
In limited circumstances, with our clients, in order to resolve complaints.
Insurance Companies, in the event of a relevant insurance claim.
If you would like further information regarding the disclosures of your personal information, please see email dpo@dukeslimited.co.uk
1.4. Third Parties
This section details what personal information we collect about you if you are a 3rd party who happens to have been captured by our video and/or audio recording capability.
1.4.1. What personal information we collect
Visual and audio images of you through our use of Body Worn Video, Vehicle Cameras, and audio recording equipment.
1.4.2. How we collect your personal information
Where we visit an address where you are present, from our agents’ Body Worn Video and audio recording equipment.
Our vehicles may be equipped with both internal and external cameras which may capture footage of you.
1.4.3. What we use your personal information for
We may process your information for several different purposes. We have a legitimate business need to use your personal information. Such need will cover all activities required to carry out everyday business activities and will include:
keeping business records
When relying on this legal ground, we are under a duty to assess your rights and to ensure that we do not use your personal information unless we can demonstrate a legitimate business need.
1.4.5. Who we share your personal information with
From time to time, we may share your personal information with the following third parties for the purposes set out above:
In limited circumstances, with our clients, in order to resolve complaints
The Police and Courts
Insurance Companies, in the event of a relevant insurance claim
If you would like further information regarding the disclosures of your personal information, please see email dpo@dukeslimited.co.uk
2. How we protect your personal information when sending it abroad
We do not send your personal information outside of the UK. If this changes, we will notify you.
3. What marketing activities we conduct with your data
When filling out an enquiry form on our website, if you do not tick the box to disregard receiving email updates from Dukes in the future, your email address or postal address may be used for marketing campaigns created by Dukes. You can opt out of this at any time by contacting marketing@dukeslimited.co.uk
4. How long we keep personal information for
We will only keep your personal information for as long as reasonably necessary to fulfil the purposes set out above and to comply with our legal and regulatory obligations.
Our Customers: All customer data in all data stores (except Body Worn Video (BWV) footage) will be scheduled for deletion 6 years after the year in which the customer's last case is returned to the client. This means that customer data older than the 6-year threshold will be retained where there is a live case or there has been a live case within the last 7 years (i.e. 6 years plus the year in which the last customer case was returned).
BWV recordings of visit interactions will be auto-deleted 1 year after the date on which the recording was made unless the case is subject to investigation or complaint at this point. In these circumstances, BWV footage will be deleted 1 year after the year in which the complaint/investigation is closed. This also applies to BWV footage shared with research companies for research purposes outlined above.
Vehicle camera recordings will be deleted after 60 days from the date on which the recording was made unless the case is subject to investigation or complaint at this point. In these circumstances, footage will be deleted 1 year after the year in which the complaint/investigation is closed.
Where we receive vulnerability evidence that contains your personal information, that evidence will be assessed by our back-office team, and all photos or scanned documents will be deleted the next working day.
New Occupiers: where we receive evidence, that contains your personal information, that evidence will be assessed by our back-office team, and all photos or scanned documents will be deleted 2 working days after completion of the assessment.
5. Your rights
You have several data protection rights which entitle you to request information about your personal information, to dictate what we do with it or to stop us using it in certain ways.
If you wish to exercise the rights set out below, please email us at dpo@dukeslimited.co.uk. Please note, that where we use BWV footage for research purposes, some of your rights stated below may not apply to such uses – in particular, where we rely on the research and statistics exemption under the Data Protection Act 2018, as this disapplies such rights.
We respect your rights concerning personal information we hold about you, however, we cannot always comply with your requests. For example, we may not be able to delete your information if we are required by law to keep it for a longer time or if should we delete your information, we would not have the necessary information we need to fulfil the purpose for which it was collected.
Your rights include:
The right to access your personal information
You can request a copy of the personal information we hold about you and certain details of how we use it.
Unless requested otherwise, your personal information will be provided to you by electronic means. If we do not hold an email address the information will be sent by post.
The right to rectification
We make reasonable efforts to keep your personal information where necessary up to date, complete and accurate. We encourage you to ensure that your personal information is accurate so please regularly let us know if you believe that the information we hold about you may be inaccurate or incomplete. We will correct and amend any such personal information and notify any third-party recipients of necessary changes.
The right to erasure
You can request that we delete your personal information. For example, where we no longer need your personal information for the original purpose we collected it. Whilst we will assess every request, this request is subject to legal and regulatory requirements that we are required to comply with.
The right to restriction of processing
Subject to the circumstances in which you exercise this right, you can request that we stop using your personal information, such as when you believe that we no longer need to use your personal information.
The right to data portability
Subject to the circumstances in which you exercise this right, you can request that we port across personal information you have provided to us to a third party in a commonly used and machine-readable format.
The right to object to marketing
We do not carry out any marketing activities using your personal information.
The right to object to processing
In certain circumstances, where we only process your personal data because we have a legitimate business need to do so, you have the right to object to our processing of your personal data.
Rights relating to automated decision-making.
We do not currently carry out any automated decision-making. If this changes, we will notify you and inform you about your rights relating to automated decision-making.
The right to withdraw consent
We do not rely on your consent to process personal information obtained from other sources, for example, our client when they refer your debt to us for collection. If you have provided us with additional information on our Customer Portal you may withdraw your consent for us to process this information at any time.
The right to lodge a complaint with the ICO
You have a right to complain to the Information Commissioner’s Office if you believe that any use of your personal information by us is in breach of applicable data protection laws and/or regulations. More information can be found on the Information Commissioner’s Office website: https://ico.org.uk. This will not affect any other legal rights or remedies that you have.
6. How we protect your information
We will use all reasonable efforts to safeguard your personal data. We have put in place strict physical, electronic, and managerial procedures to safeguard and secure the information we collect. We put in place confidentiality clauses or confidentiality agreements (including data protection obligations) with our third-party service providers.
If you would like more information on how we protect your information please email dpo@dukeslimited.co.uk
7. How we use cookies on this website
We use cookies to compile aggregate data about site traffic and site interaction to offer better site experiences and tools in the future. Cookies are utilised for monitoring visitors and the type of material accessed. For more details, please refer to our Cookie Policy.
Additionally, we may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business. We work in conjunction with a marketing partner HubSpot to sometimes email promotional information and/or contractual information. Accessing promotional information and contractual information is often done via the HubSpot.
8. Contact us
You may contact our data protection officer if you have any questions about how we collect, store or use your personal information:
Data Protection Officer
Dukes Bailiffs Limited
Dukes Court
7 Newcastle Street
Stone, Staffordshire
ST15 8JT
dpo@dukeslimited.co.uk
9. Updates to this Privacy Policy
We may need to make changes to this Privacy Policy periodically, for example, as the result of government regulation, new technologies, or other developments in data protection laws or privacy generally. Our most up-to-date Privacy Policy will always be shown on our website and will be signposted in all of our communications.
This Privacy Policy (version 3) was last updated on: 25 March 2024.