This part of Wolf Enforcement Services Limited privacy notice is for our clients’ and will tell you:
- why we are able to process your information
- what purpose we are processing it for
- whether you have to provide it to us
- how long we store it for
- whether there are other recipients of your personal information
- we do not transfer your personal information to another country
- we do not make automated decision – or conduct profiling.
From time to time Wolf Enforcement Services Limited will act as a data processor on behalf of a data controller (for example, when collecting a debt, in the execution of a writ or exercising a power under CRAR – Commercial Rent Arrears Recovery), Wolf Enforcement Services Limited will signpost you to the applicable privacy notice of that Data Controller that sets out the required information as part of that data processing agreement and your data subject rights.
Wolf Enforcement Services Limited may change this Privacy Notice when only necessary or when we are required by law.
Information we hold about you
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- You have instructed us to act for you
- You have asked us to provide a service
- You have contacted us to make an enquiry or ask for advice
- You have asked for a quotation
Our collection methods are:
- Through engagement (or potential engagement) of our services
- Enquiries via our office, website or agents’
- By communications, including email, telephone, post or social media
- Through engagement of service providers
- Via third parties and/or publicly available resources
As our client, Wolf Enforcement Services Limited will hold the following kind of information about you:
- Your name, identity and contact information
- Information about your personal and business activities
- Information and documents about your matter or enquiries, including communications with you
- Billing and payment information
How we use your data to provide you with a service
Wolf Enforcement Services Limited will use the information we collect and hold about you and your business — both personal and otherwise;
- To give you the best service we can
- To notify you about changes to our service
- To enable us to invoice you for our services, and keep track of payments that you make
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you
(Processing is necessary for the performance of a contract – Basis: Article. 6(b): this is necessary to deliver an effective service to you.)
Legitimate Interest and marketing:
Wolf Enforcement Services Limited may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes for marketing, business development, statistical and management purposes.
If you are an existing client or contact, we may send you information about other products, events and services from time to time that we feel maybe of interest to you. You have the right at anytime to unsubscribe (opt out) from the emails or to contact us to ask us to stop contacting you for marketing purposes.
We will never sell your data to a third party.
(Processing is necessary for the purposes of the legitimate interest – Basis: Article 6(f): this is necessary for the interest pursued by the controller)
Wolf Enforcement Services Limited has put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties who have a business need to process your personal information.
Only authorised employees, agents, contractors and third parties will process your personal data and information on our instructions and they are subject to a duty of confidentiality.
Wolf Enforcement Services Limited have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
If you have particular security requirements, please contact us to discuss how we can support you.
Your data and the EEA
Wolf Enforcement Services Limited does not transfer or process data outside the European Economic Area (EEA) unless the nature of the processing requires it (for example, where we are emailing a party to your matter who is based outside the EEA, or because you have chosen to use an email or other communications service which routes data outside the EEA).
Wolf Enforcement Services Limited will only share personal information with a third party when we are required to use specialist third party service providers (data processors) to support our services to you.
We may also have to pass your data to third party external organisations where we are required by law and where it is necessary to administer the relationship between us. (For example Law Enforcement, HMRC, HMCTS)
We use third party service providers such as certificated Enforcement Agents, vehicle removal / recovery companies, Security Industry Authority licensed security operatives, locate and tracing services and other organisations to help us provide the best services to you.
These services would include:
- High Court Enforcement
- Commercial Rent Arrears Recovery (CRAR)
- Protestor removal
- Residential landlord
- Commercial repossession
- Debt collection
- Trespasser removal
- Driving and Vehicle Licensing Agency (DVLA)
- Companies House
- Process serving
- Forfeiture of a commercial lease
- Residential repossession
- Methods to take payment (Merchants, Receipts)
- Email services
Where personal data is passed to any of these organisations – it is minimised, and if we stop using their services, any of your data held by them will either be deleted, returned or rendered anonymous.
All of our third party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third party service providers to process your personal data for specified purposes and only in accordance with our instructions.
Deletion and retention periods
|Information, data or record||Period for retaining record & accompanying notes|
|Accident books, accident records/reports||3 years from last entry|
|Accounting records||3 years for private companies
6 years for public limited companies
|Income tax and NI returns
Income tax records
|At least 3 years after the end of the financial year to which they relate|
|Records of tests & examinations of control systems and protective equipment under COSHH||5 years from the date of the test|
|Statutory Maternity Pay records, calculations, certificates & related medical evidence||3 years after the end of the tax year in which the maternity period ends|
|Wage/salary records, overtime, bonus & expenses||6 years|
|National minimum wage records||3 years + current year after the end of the pay reference period|
|Application forms and interview notes (for unsuccessful candidates)||1 year from date of interview|
|Personnel files and training records (including recruitment, disciplinary records and working time records)||6 years after date employment ceases|
|Redundancy details, calculations of payments & refunds||6 years from the date of redundancy|
|Statutory Sick Pay records, calculations, certificates & self-certificates||6 years|
|Complaints, records, letters, responses & customer communications received by an FCA regulated firm||5 years for complaints relating to MiFID business or collective portfolio management services
3 years for all other complaints
|Records documenting the firm’s relationships and responsibilities to statutory and/or regulatory bodies and its legal responsibilities||Permanent|
|Business documents, policies, procedures, strategies etc||Superseded + 6 years (then reviewed for archive value purposes)|
|Supplier, business relationship documents, contracts, SLA’s, audits, reviews etc||End of relationship + 6 years|
|Reviews, analysis, compliance monitoring, quality assurance, operational performance etc||5 years +1|
|Marketing, promotion, press releases||2 years after last action|
|Memberships, certification and/or accreditation with professional associations||End of membership/accreditation + 1 year|
|Body worn Camera footage none complaint based||30 Days|
|Body Worn Video Complaint Based||3 Years|
When assessing what retention period is appropriate for your personal data, Wolf Enforcement Services Limited takes into consideration:
- The requirements of our business and the services provided;
- Any statutory or legal obligations;
- The purposes for which we originally collected the personal data;
- The lawful grounds on which we based our processing;
- The types of personal data we have collected;
- The amount and categories of your personal data; and
- Whether the purpose of the processing could reasonably be fulfilled by other means.
Subject Access Requests
Wolf Enforcement Services Limited strives to be as open as we can be in terms of giving people access to their personal data.
A Subject Access Request under the GDPR / Data Protection Act 2018 is your right to request a copy of the information that we hold about you.
Subject Access Requests must be in writing to Wolf Enforcement Services Limited, 20 – 22 Wenlock Road, London, N1 7GU.
If Wolf Enforcement Services Limited does not hold your personal data we will respond in writing without undue delay and within one calendar month of your request (where that request was submitted in accordance with our policy).
The information we supply will:
- Confirm that your data is being processed;
- Verify the lawfulness and the purpose of the processing;
- Confirm the categories of personal data being processed;
- Confirm the type of recipient to whom the personal data have been or will be disclosed, and
- Let you have a copy of the data in an intelligible form.
Please note that you may need to provide identification in order to prove who you are to access your data.
If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.
How to complain
If you are unhappy with how we have used your personal information please contact, the Enforcement Manager Wolf Enforcement Services Limited, 20 – 22 Wenlock Road, London, N1 7GU, and your complaint will be investigated.
Your privacy rights
You have lots of privacy rights in respect of our processing of your personal data.
Click on privacy rights for more detailed information
You also have the right to lodge a complaint about our processing with a supervisory authority — you probably want the UK’s Information Commissioner’s Office
Telephone: 0303 123 1113