During our activities we will process personal data (which may be held on paper, electronically, or otherwise) about you.  We recognise the need to treat this information in an appropriate and lawful manner. The purpose of this notice is to make you aware of how Factors Direct Ltd will handle your information.

Who are we?

Factors Direct Limited (“we” or “us”) is a privately-owned Scottish company with its registered address being Abercorn House, 79 Renfrew Road, Paisley, Scotland, PA3 4DA and a company number of SC747667 and having its head office address is 34 Gibson Street, Glasgow, G12 8NX.

Factors Direct Ltd take the issue of security and data protection very seriously and strictly adhere to guidelines published in the Data Protection Act of 1998 and the General Data Protection Regulation (EU) 2016/679 which is applicable from 25 May 2018, together with any domestic laws subsequently enacted. We are registered with the Information Commissioners Office, our registration number is 02080003151, with a reference of ZB556515.

Our point of contact for any related GDPR questions is Gemma Waters, Managing Director and Paul Shields, Finance Director, Factors Direct Ltd.

Any questions relating to this notice and our privacy practices should be sent to:

Gemma Waters, Managing Director: gemma@factorsdirect.verticaldev.org and Paul Shields, Finance Director: paul@factorsdirect.verticaldev.org

 

What is personal information?

Personal information is any information that tells us something about you. This includes information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you. Some personal information is classified as special data under data protection legislation.  This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation.  This information is more sensitive, and we need to have further justification for collecting, storing, and using this type of personal information.  There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.

How we collect information about you

We collect information about you when you apply to use our services, complete one of our forms, when you call, write, e-mail, or meet with us, request services/repairs, enter into a management agreement with ourselves. We may collect information when you use our social media sites, websites, or self-service portal or otherwise provide us with your personal details. Our calls may also be recorded for training and monitoring purposes and voicemail recordings.

We may request access to your property’s CCTV / sound recording and / or use photography to acquire information regarding the management of your property for repairs, claimed anti-social behaviour or crime that results in property damage.

We may also take photographs at our events and at properties to use for general marketing and advertising. However, photographs of individuals will only be used for those purposes with your consent.

We may receive information about you from third parties including:

• Your appointed solicitor or a solicitor acting for a seller client.
• Police, welfare, or support organisations dealing with you.
• Councillors, MPs, or other representatives acting on your behalf/instruction.
• Business partners, such as insurers (if applicable) and others who are part of providing services or operating our business.
• From other sources such as publicly available data, debt recovery and / or tracing agents, along with Registers of Scotland.

 

We collect the following information about you

We will collect your full name and contact details such as phone numbers, email addresses and postal addresses from you whenever you engage with us.

In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification such as a passport or driving licence and one form of documentation with proof of your place of residence such as a recent utility bill. We will also collect data relating to your Title Deed, emergency contact information, data about your property including location, value, property type and maintenance history. We may also hold data relating to a client property and account, such as income recovery actions and financial details relating to an account for billing purposes, such as bank details.

If you are a contractor working with us or wish to be added to our contractor database we will collect and process identification and contact information such as your full name, postal address, email address and telephone numbers, insurance and compliance certificates and evidence of industry and service related qualifications.

What do we use your information for?

• Managing your property and services you have with us.
• Managing your account with us.
• Providing you with Data relating to our services.
• Updating our records, tracing your whereabouts, and recovering debt.
• Managing any aspect of the services we provide.
• Monitoring the performance of our services and internal processes.
• To improve the operation of our business and that of our business partners.
• To follow guidance and best practice under the change to rules of government and regulatory bodies.
• For management and auditing of our business operations including accounting.
• To monitor and to keep records of our communication with you and our staff.
• To administer our good governance requirements such as internal reporting and compliance obligations.
• To comply with legal and regulatory obligations, requirements, and guidance.
• To share data as needed with business partners, such as, contractors who provide services to you, debt recovery agent, insurers.
• To share data with other agencies such as the police, for the prevention / detection of crime.

Sharing your information

The information you provide to us will be treated by us as confidential [and will be processed only by our employees within the UK/European Economic Area (EEA)]. We may disclose your information to other third parties who act for us for the purposes set out in this notice or for purposes approved by you, including the following:

• If we enter into a joint venture with or merge with another business entity, your information may be disclosed to our new business partners or owners.
• If we instruct repair or maintenance works, your information may be disclosed to any.
• If we are investigating a complaint, information may be disclosed to Police Scotland, local authority departments, Scottish Fire & Rescue Service and others involved in any complaint, whether investigating the complaint or otherwise
• If we are investigating payments made or otherwise, your information may be disclosed to payment processors, local authority, and the Department for Work & Pensions
• If we are conducting a survey of our products and/or service, your information may be disclosed to third parties assisting in the compilation and analysis of the survey.
• Government or regulatory bodies, such as HMRC, the Financial Conduct Authority, the Information Commissioners Office, and The First Tier Tribunal for Scotland, (Housing and Property Chamber).
• Other organisations and businesses who provide services to us, such as, back up and server hosting providers, IT software and maintenance providers and providers of other back office functions.

Unless required to do so by law, we will not otherwise share, sell, or distribute any of the information you provide to us without your consent.

Transfers outside the UK and Europe

Your information will only be stored within the UK and EEA our systems are secure and our IT Company are Red Mosquito.

Security

When you provide information, we take steps to make sure that your personal information is kept secure and safe.

 

What are the legal grounds for our processing of your Personal Data?

Where it is needed to provide you with our services, such as:

• Where we need information to perform the contract, we have entered into with you.
• Managing the services, we provide to you or the contact data where you have asked us to provide you with our services.
• Updating your account details, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate).
• Sharing your personal data with business partners as required, and service providers. i.e. to provide contractors access details.
• All stages and activities relevant to managing the service including enquiry, administration and managing of accounts.

Where it is in our Legitimate interests to do so such as:

• Managing your services and account, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt, (where appropriate).
• To perform our services and internal processes.
• To follow guidance and best practice of government and regulatory bodies.
• For management and audit of our business operations, including accounting.
• To carry out monitoring and to keep records of our communications with you and our staff.
• To administer our good governance requirements such as internal reporting and compliance obligations.
• Where we need to share your personal Data with people or organisations to run our business or comply with any legal and / or regulatory obligations.
• To comply with our Legal obligations.
• For employment related purposes.

 

With your Consent:

• For some “marketing” communications.

For a Public interest, such as:

• Processing special categories of personal data, such as health or if you are a vulnerable client.

Other uses of your personal information

 

• If we sell any part of our business and/or integrate it with another business, your details may be shared to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be allowed to use your information in the same or similar way as set out in this privacy notice.
• We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
• We will share personal information with third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
• We may share your personal information with any person working within Factors Direct on a need to know basis to ensure we are able to perform our obligations to you.
• We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by us to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.

How and when can you withdraw your consent?

Where we are relying on your consent to process personal data, you can withdraw this at any time. i.e. for some “marketing” communications.

How long we will keep your information?

We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity or agreement / contract, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

Your rights

You have the right at any time to:

• Ask for a copy of the information about you held by us.
• Require us to correct any inaccuracies in your information/data.
• Make a request for Factors Direct to delete personal data we hold about you when this is out with the contract / agreement.
• Ask to restrict or object to processing if not related to the agreement / contract.
• Object to receiving any marketing communications from us.

If you would like to exercise any of your rights above, please contact us at enquiries3@factorsdirect.verticaldev.org  

Should you wish to complain about the use of your information, we would ask that you contact us to resolve this matter in the first instance. You also have the right to complain to the ICO in relation to our use of your information. The ICO’s contact details are:

The Information Commissioner’s Office – Scotland

45 Melville Street,

Edinburgh,

EH3 7HL

Telephone: 0131 244 9001

Email: scotland@ico.org.uk

The accuracy of your information is important to us. Please help us keep our records updated by informing us of any changes to your email address and other contact details.