Consumer Privacy Notice

Lowell Solicitors Limited is a specialist debt recovery law firm which is part of the Lowell group of companies. We act on behalf of other members of the Lowell group to recover outstanding debts including through court and other legal proceedings. Where we use ‘we’, ‘our’ or ‘us’ in this notice, we mean Lowell Solicitors Limited unless we say otherwise.

If you have an account with Lowell Solicitors Limited, this means that Lowell Portfolio I Ltd has bought either your account or the right to collect the amount you owe on your account and they have instructed us to recover the outstanding balance on their behalf.

Where we use ‘our client’ in this notice, we mean Lowell Portfolio I Ltd (and Lowell Financial Ltd who manage accounts on their behalf) or any other member of the Lowell group of companies to which Lowell Portfolio I Ltd may transfer its interest in your account from time to time.

For more information about how Lowell Portfolio I Ltd and Lowell Financial Ltd collect, use and share your personal information, please see www.lowell.co.uk/how-we-use-your-data.

We are a controller of your information which means that we are responsible for looking after it.

For details of the UK companies in the Lowell Group, please see the section Who is the Lowell Group? below.

We collect:

• your name
• your contact details (including your current and previous addresses, telephone numbers and email addresses)
• your gender
• your date of birth
• details about your account with us and your account with our client including your account number and outstanding balance
• financial information about you including your credit score, credit history and payment history, information about defaults and missed payments, credit reference information, information about your dependants, information about your income and expenditure (including your mortgage and any other outstanding loans you may have) and any other details relating to your account with us and your ability to pay the amounts you owe
• recordings of our calls with you

We may regularly check your credit file to ensure the information that we hold about you on our systems is accurate, complete and up to date. This check is called a ‘soft search’ and may leave what is known as a ‘soft footprint’. This means that it is not visible to any other organisations and will not affect your credit score. It can only be seen by you, us and the credit reference agency and will show as account administration on your credit file.

Where you provide us with information about your family, lifestyle and social circumstances, employment status and your work history, we may record and use this information where it affects your account with us.

Where it has or may have an impact on your ability to pay the amounts you owe, we may collect information about your mental and physical health.  For more details about how we use this information, please see the section Special categories of personal data in the Detailed Consumer Privacy Notice.

We may also collect some limited information, including publicly accessible information such as media reports, about any current criminal convictions you have if we have reason to believe that you may be in prison. We will use this for the purposes of updating the information we hold about you and managing your account.  We may also use this information for the purposes of crime and fraud prevention and for complying with our obligations under the anti-money laundering and counter-terrorist financing legislation. Please see the section Information relating to criminal convictions in the Detailed Consumer Privacy Notice for more details.

We may also collect publicly accessible information about you, for example through a Google search, where we have been unable to contact you using the contact details that we hold for you.

If you use our website, including registering for an online account, please see our Website User Privacy Notice and our Cookie Notice for details of the information we collect through our website.

For more details about what information we collect about you, please see the section What information do we collect about you? in our Detailed Consumer Privacy Notice.

We collect some information directly from you, for example the information you give us when we speak to you on the phone or which you send to us by email or by letter or by using our website. 

If you use our website, please see our Website User Privacy Notice and our Cookie Notice for details of the information we collect through our website.

We also obtain information from our client, other companies in the Lowell group, any debt collection agencies, tracing agents, process servers, court advocates and barristers who are instructed to act on behalf of our client as well as debt management companies, law firms and other persons who are authorised to act on your behalf.

We may regularly check your credit file to ensure the information that we hold about you on our systems is accurate, complete and up to date. This check is called a ‘soft search’ and may leave what is known as a ‘soft footprint’. This means that it is not visible to any other organisations and will not affect your credit score. It can only be seen by you, us and the credit reference agency and will show as account administration on your credit file.

We may monitor and/or record calls for the purposes of resolving issues on your account, training and to improve our quality and service standards.

We may combine the information that you give us with the information we collect about you from the other sources from which we obtain information.

For more details about where we collect your information from, please see the Where do we get your information from? section of the Detailed Consumer Privacy Notice.

We need your information to provide our legal services to our client.  This includes locating you, checking your identity and confirming that the information we hold about you is correct, taking legal action (such as issuing court or other legal proceedings) against you and taking action to enforce any judgment we obtain against you.

As we have been instructed by our client to provide them with legal services to recover the outstanding amounts that you owe, we have a legitimate interest in using your information for these purposes including through court and other legal proceedings.

We also use your information to comply with our professional, legal, regulatory and other corporate governance obligations, for example:

• to comply with our professional obligations including those imposed by the Solicitors Regulation Authority and
• to comply with our obligations under the anti-money laundering and counter-terrorist financing and other legislation and for crime and fraud prevention.

Please see the sections Special categories of personal data and Information relating to criminal convictions in our Detailed Consumer Privacy Notice for more details.

If you use our website, please see our Website User Privacy Notice and our Cookie Notice for details of the information we collect through our website.

You do not have to give us any information or confirm that the information we have obtained from the third parties, detailed in the Where do we get your information from? section of our Detailed Consumer Privacy Notice, is correct.

If you do not provide us or the court with relevant information, this may have legal consequences for you, including the court deciding in our favour, a CCJ or similar judgment being entered against you and you incurring legal costs. 

We sometimes need to share some of your information with other organisations.

We will share all information we obtain about you, including call recordings and information relating to any physical and health conditions and criminal convictions which you may have, with our client. We may also share information with other companies in the Lowell group, any debt collection agencies, tracing agents process servers, court advocates and barristers who are instructed to act on behalf of our client as well as debt management companies, law firms and other persons who are authorised to act on your behalf.

Where we take legal action and issue proceedings against you, we will share information about you, including your name, address, date of birth and details of your account with us with the court for the purposes of the legal proceedings.

If fraud, money laundering or any other crime is detected, we may share information with the police and other law enforcement agencies.

We may also share some limited information, including call recordings for quality assurance purposes, with the previous owner of your account.

We use a number of carefully selected third parties to supply us with products and services, such as IT and mailing services. We will only share your information with our suppliers where it is necessary for them to provide us with the services we need.

If we or any member of the Lowell group of companies merges, transfers or sells part or all of its business or assets or all or part of its share capital to a third party, your personal information may be disclosed to that third party and its advisers for the purposes of negotiating and completing the merger, transfer or sale.  If the merger, transfer or sale does complete, that third party may use or disclose your information as set out in this privacy notice.

We may also share your information with our insurers, legal and other professional advisers where necessary.

For more details about who we share your information with, please see the Who do we share your information with? section of our Detailed Consumer Privacy Notice.

Your information is generally stored on servers and filing systems in the UK but from time to time it may be stored in or accessed from countries outside the UK. Where this may happen, we always make sure that there are appropriate safeguards in place, such as the model contract clauses, binding corporate rules or the EU-US Privacy Shield, to guarantee that your information – and your rights – are protected to the same high standard as under UK law.

For more details, please see the Where is your information stored? section of our Detailed Consumer Privacy Notice.

We only keep your information for as long as we need it and we will keep your information for no more than 7 years from the date your account with us is closed.  We keep your information for this long so that we can:

• deal with any issues or concerns that you may have about how we handled your account
• comply with our professional, legal, regulatory and other corporate governance obligations
• answer any questions HM Revenue and Customs may have and
• bring or defend any legal claims.

However, we won’t keep all of your information for so long, and we will delete some information much sooner.

For more details, please see the How long do we keep your information? section of our Detailed Consumer Privacy Notice.

Under the data protection legislation, you have a number of rights in respect of your information which include the right to:

• access your information
• ask us to make changes to the information we hold about you to make sure that it is accurate and up to date
• delete or erase your information (sometimes called the right to be forgotten)
• stop or restrict our processing of your information
• object to our processing your information
• not be subject to automated decision-making and
• request the transfer of some of the information we hold about you (known as data portability).

Some of these rights only apply in certain situations. For more details about how these rights apply to the way we use your information, please see the What rights do you have? section of our Detailed Consumer Privacy Notice.

If you would like to exercise any of your rights, please contact our Data Protection Officer:

• by email at dpo@lowellgroup.co.uk
• in writing to Data Protection Officer, Lowell Solicitors Limited, PO Box 13080, Harlow, CM20 9TF.

Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, query or request relates to, please contact our Data Protection Officer using these contact details.

If you have any questions, concerns or complaints about the way Lowell Solicitors Limited processes your personal information, please contact our Data Protection Officer in the first instance and they will do their very best to help you:

• by email at dpo@lowellgroup.co.uk or
• in writing to Data Protection Officer, Lowell Solicitors Limited, No.1 The Square, Thorpe Park View, Thorpe Park, Leeds, LS15 8GH.

Our Data Protection Officer deals with data protection for all our UK companies, so whichever Lowell company your question, concern or complaint relates to, please contact our Data Protection Officer using these contact details.

If you are not happy with the way we have handled your complaint or are still concerned about our handling of your personal information, you have a right to take your complaint to the Information Commissioner’s Office by post at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF or via the website www.ico.org.uk.

The Lowell group is made up of the following companies incorporated in the UK:

We will regularly review this notice and keep it updated to make sure that the information we provide you with is accurate and up to date.

Any changes to this notice will be highlighted so that you can see what has been changed.  

Where we have made a significant change to the information contained in this notice, we will let you know in the next piece of correspondence that we send you.

This notice was last reviewed and updated in July 2018.