This part of Wolf Enforcement Service Limited privacy notice is for our debtors (or defendants’) 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.
Wolf Enforcement Services Limited may change this Privacy Notice when only necessary or when we are required by law.
Information we hold about you
Wolf Enforcement Services Limited will only process personal data that is necessary, relevant, adequate and lawful to the instruction we have received from a client.
We may hold the following information about you (but not limited to), which is to assist us in carrying out of one of our instructions and duty, in the collection of any debt, to act lawfully, assess vulnerability and ability to pay, to help you, and to follow codes of conduct and national standards of the regulations and associations we have signed up to:
- Your full names including previous
- Home and trade addresses
- Personal and work email addresses
- Telephone numbers (landline, mobile)
- Date of birth
- Description of our interactions
- Social Media (handle, signature, username)
- National Insurance Number
- Employee / Employment status
- Financial Information (Income / benefit claims / expenditure)
- Marital Status
- Housing Status
- Sensitive Data – Special category data (Health, Vulnerability)
- Vehicle Registration Number (VRN)
- Hire Purchase (HPI)
- Information about your business activities
- Information and documents about your matter or enquiries, including communications with you
- Billing and payment information
- Video imagery – Body Worn Video (BWV) cameras maybe worn by Enforcement Agents’. (This may collect personal and special category data).
Most of the personal information we process is provided to us by our clients or the court for one of the following reasons:
- A client has instructed us to act for them (To collect a debt, execute a writ or warrant, exercise our power under CRAR or to remove trespassers)
- A client has asked us to provide a service and your personal information is provided
- A client has contacted us to make an enquiry or ask for advice and has provided your details
- A client has asked for a quotation and included your details
You may provide us personal information to help us assess the case for one of the following reasons:
- Proof of payment / settlement
- Proof of identity
- To provide proof of a vulnerability
- Your ability to pay / not pay / arrangement to pay
- Other reasons to assist you
Our collection methods are:
- Via the courts, a creditor, landlord, land-owner, claimant
- Via a High Court Enforcement Officer
- Through engagement in person
- Enquiries via our office, website or agents’
- By communications, including email, telephone, post or social media
- Face to face
- Through engagement of service or your advice providers
- Via third parties and/or publicly available resources
Using your data
References to the basis of processing are a reference to the article of the General Data Protection Regulation under which we undertake the processing in question.
Wolf Enforcement Services Limited will use personal data that is given to us by you or anybody else such as your creditor, claimant, the court, High Court Enforcement Officer, landlord, land owners, enforcement agency, key worker, debt advice charities and others.
We will process your data:
As necessary to comply with a legal obligation – Article 6(c) eg –
- When you exercise your rights under data protection law and make requests
- For compliance with legal and regulatory requirements and related disclosures
- For establishment and defence of legal rights
- For activities relating to the prevention, detection and investigation of crime
- To verify your identity, fraud prevention and money laundering checks
- To monitor emails, calls, other communications to you and activities about your case
As necessary to perform a contract on behalf of your creditor that you are party to for the relevant service – Article 6(b) eg –
- To manage the performance of the contract
- To manage mediation activities
- To update records
- To trace your whereabouts to contact you regarding your contract and recovery of a debt
As necessary for our own legitimate interests or of those persons and organisations – Article 6(f) eg –
- To protect you and us
- To prevent malicious or fictitious allegations, aggression and assault eg Body Worn Video
- For good governance, accounting, managing and auditing our business operations
- To search credit reference agencies
- To monitor emails, calls, other communications and activities on your case
Body Worn Video (BWV) data is not reviewed unless necessary to assist in identifying a data subject requesting information, to answer a complaint or it is to be provided as evidence to law enforcement following an allegation of crime.
In some instances Wolf Enforcement Services Limited will be acting as a controller of the BWV data being processed and on other occasions defined as a processor as processing on behalf of another controller (eg High Court Enforcement Officer / Enforcement Agency).
Please refer to our Subject Access Request information for more detail. (Deletion and retention is illustrated in a table below).
Based on your (explicit) consent – Article 6(a) and 9(2)(a) eg –
- When you request us to disclose your personal data to other people or organisations such as a debt advice charity, key worker, family member or other handling your case
- When we process special category data of personal data about you at your request to help us assess and make legal and duty bound decisions about your case (eg racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning your health, sex life or sexual orientation)
- When we assess if you are vulnerable, or if you have the capacity to handle your own finances.
You are free at anytime to change your mind and withdraw your consent, but there maybe exceptions if being processed under a legal obligation once disclosed ie If you are vulnerable and we know you are vulnerable and you withdraw your consent, we have a legal obligation to make decisions based on the information you provided – safeguarding.
Wolf Enforcement Services Limited will use such data to make informed decisions on all of the information available to us, our instruction from our clients’ and any legal obligation.
Other uses include;
- We use your information to handle and resolve complaints.
- We use your data to verify who we are speaking to.
- To comply with any contractual or legal obligations, including sharing data with law enforcement if required to.
Click on privacy rights for more detailed information
Wolf Enforcement Services Limited have 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,
contractor and other third parties who have a business need to know.
They will only process your personal data on our instructions and they are subject to
a duty of confidentiality.
We 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 we are processing your personal data on behalf of another, please refer to the applicable Data Controllers privacy notice for more information. (If you are unsure who the Data Controller is, just ask us)
Your data and the EEA
Wolf Enforcement Services Limited does not transfer or process data outside the European Economic Area (EEA) or where 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 when we use specialist third party service providers (data processors) that are required to support our services.
We may also 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 service to our customers and to complete the instruction.
These services would include:
- High Court Enforcement Officers
- Commercial Rent Arrears Recovery (CRAR)
- Protestor removal
- Commercial repossession
- Debt collection
- Trespasser removal
- Driving and Vehicle Licensing Agency (DVLA)
- Hire Purchase (HPI)
- 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, 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, we take into consideration:
- The requirements of our business and the services provided;
- The contractual requirements of data sharing agreements with our clients’
- 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.
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