FJCM PRIVACY POLICY

This privacy policy sets out how Franklin James Credit Management (FJCM) Ltd uses and protects any information that you give us when you use this website.

FJCM is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

FJCM may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 24th April 2018

Legislation we abide by

Fjcm.co.uk follows the guidelines and legislation of the following bodies:

  • The UK Data Protection Act 1998
  • The EU General Data Protection Regulation (GDPR) 2018
  • The Information Commissioners Office – Registration No: ZA258479

What we collect

Franklin James Credit Management Ltd collects various kinds of information, depending on the service that we provide to you. In this section we tell you what information we collect, why we collect it, how long we store it for and where we store it.

Browser Tracking:

We may collect the following information from our site:

  • name and job title
  • contact information including email address
  • demographic information such as postcode, preferences and interests
  • other information relevant to customer surveys and/or offers

Using Google Analytics (3rd Party Provider) we will track what site you from to get to our website fjcm.co.uk, how you flowed through our website, your geographical location, what keywords you may have typed and what operating system you use.

This helps us to understand who is visiting our website and how you navigate around, so that we can use this information to make improvements on our website. It also provides us with the number of visits to our website, or content on our website that we receive daily. It helps us improve our site and our service. This information does not directly identify you as a person. Although Google may record your IP address, however we are not able to access that information.

This data is normally retained for 2 years. Due to the data not being “personally identifying” there is no way that we can remove data in relation to your visits to our website, as we do not know what part of this data is attributed to you.

Contact Form Submissions via fjcm.co.uk

When you fill out a contact form on our website, we will ask you for: Your full name, contact number, email address and your message (which is optional) for contacting us. We will also receive the date and time that you submitted the form.

We will store these details, so that we can contact you as per your request. We will store this information for a period of 3 years to comply with UK law.

This information is stored on our internal software and sometimes hubspot, so that we can keep record and look after your needs. We also store information securely on our web hosting account, (Go Daddy) – Third party provider.

Debt Submission Form Via our Website:

When you fill out the debt submission form on our website, we will ask you for: Your full name, contact number, email, your address, details of the amount owed to you and why. We will also request details of the debtor, including their name, email, telephone number and address. We will also request details surrounding the debt. Any supporting evidence such as invoices provided by yourself, or documents to support your claim are requested too.

The lawful basis for allowing us access to the data you provide for debt recovery comes under contractual and legal obligation. Meaning it is necessary for you to provide us with this information so that we may recover your monies for you. Compliance with a legal obligation is almost identical to the old condition for processing in paragraph 3 of Schedule 2 of the 1998 Act.

We store this information securely on our internal computers only, which are secured with multiple level passwords, Anti-virus and Firewall security. All employees sign Non-Disclosure Agreements for additional verbal and written confidentiality for our clients. All employees are fully trained in the rules and regulations to which we abide under GDPR and Data Protection regulations. All hard copy files are in secure locations in our offices under lock and key.

We store this information for up to 3 years, in accordance with UK law.

Third parties that we may share the information you provide on yourself and debtor with include:

High Court & County Court Enforcement Bailiffs

HMRC

Companies House

Affiliate Solicitor – Curzon Green

Goddards Accountants

Myersons Accountants

Credit Safe

You will be required to outline our guidelines and responsibilities as data processors to define what we can and cannot do with data provided on your clients when we are instructed for outsourced credit control.

Telephone calls

Should you call our offices, we will ask for your name, telephone number, email address and the nature of your enquiry. We may write this information down, so that we can continue to effectively provide you with the services you require, or so that members of our team can contact you if requested. This information is shredded and recycled once your enquiry has been dealt with. This information is only stored on paper in our offices, no documentation of this sort are removed.

Emails to FJCM

We use Microsoft Outlook for email sending, receiving and storage of emails, hosted by Go Daddy. All of our emails contain privacy and protection notices. The data if no longer required, is deleted after 3 years. Our host takes daily backups of our emails and site data, which is stored remotely by them (3rd party services). Backups are taken for recovery purposes, should our site, emails or hardware become damaged or deleted accidentally resulting in data loss.

Old backups are deleted every 7 days and replaced with the new.

Overall: What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and for the following reasons:

  • Internal record keeping.
  • We may use the information to improve our products and services.
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided, if you have opted in for us to do so.
  • If you are already a customer with us, we will send you information regarding your account and opportunities available to you.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone (text/call), or post. We may use the information to customise the website according to your interests

Security & Where we store your data

We are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Your Account data

We store this information securely on password protected office computers.

Payment & Financial details

We store this information securely on our office computers and within our business bank accounts. See third-party providers.

Computer Back ups

We store this information securely on an external hard drive, which is held under lock and key and is secured under password protection. Cloud backups are also taken and deleted every 7 days, replaced with the new back up.

Third Party Providers

Some of the services we use which are third parties may store or have access to your data to help us run our service effectively for you. We have no control over their processing or data storage. The third-party companies that we do use are first vetted by us. The companies we use are as follows:

  • Hubspot
  • Internet Innovators
  • Paypal
  • Google
  • Natwest Bank
  • Credit Safe
  • Sage
  • QuickBooks
  • Kashflow
  • OneDrive
  • Drop Box
  • Peninsula
  • High Court Enforcement
  • Curzon Green Solicitors
  • Myersons Accountants
  • Goddards Accountants
  • BT

Please visit the company sites to view their privacy policies on the 3rd parties we use.

How We protect your Data:

  • Data Stored on our site is encrypted and secured by SSL certificated issued for fjcm.co.uk. Our web hosting with Internet Innovations (Third Party provider) have regular security checks by their administration team. HTTPS is also enabled on our websites, to help prevent intruders from tampering with the communications between our website and your users’ browsers. Intruders include intentionally malicious attackers, and legitimate but intrusive companies, such as ISPs or hotels that inject ads into pages.
  • Data Stored on all office computers is password protected within multiple areas of each software. Computers are also protected with anti-viral and firewall security.
  • Cloud Phone systems provided by BT are protected by secure voice:
  • Transport Layer Security (TLS) is a cryptographic protocol that provides encryption on the SIP signalling data in the application layer. This protocol secures the SIP signalling communication between supported endpoint devices and the BT Cloud Phone servers.
  • Secure Real-time Transport Protocol (sRTP) is a profile of the Real-time Transport Protocol (RTP) that provides encryption, message authentication and integrity, as well as replay protection to the RTP packet stream that is transported between supported endpoint devices and the BT Cloud Phone servers.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Data Breaches

We will report any unlawful data breach of Franklin James Credit Management Ltd and it’s third party data processors to the ICO in the UK. The report will be submitted within 72 hours once we establish that personal data was accessed or stolen. In the event that personal data was accessed and in accordance with the GDPR rules we may also inform the data subject (you).

Name & Address of the Controller

The controller for the purposes of the General Data Protection Regulation (GDPR) And The UK Data Protection Act (DPA) is:

Paula Bolton – Harpers, Horsleys Green, High Wycombe, HP14 3UU

TEL: 01494 422742 E: info@fj-creditmanagement.co.uk

Controlling your personal information & your rights

GDPR and DPA give you the following rights to do with the data we store on you.

The Right to be Informed

You have the right to ask our data controller why we store your information and what we use it for, which is as discussed in the above text.

The Right of Access

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable of £10.00. If you would like a copy of the information held on you please email info@fj-creditmanagement and request the information we hold about you.

The Right to Rectification

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

The Right to be forgotten

You have the right to have all data we have on you erased. This would mean you terminating your professional relationship with us including the cancellation of any services provided, as without that basic data we cannot provide our services.

There is some data that can’t be erased even on request, as we are required to keep it by statutory law in the UK, for example financial transactions and invoices which we are legally obliged to store for five years after the end of the financial year they occur in.

Emails we are legally obliged to store for a period of three years.

Statutory law trumps any privacy law in most countries.

Please contact our data controller if you would like to exercise your right to be forgotten. We will need to verify your identity before we edit any of your information.

The Right to restrict processing

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, you would specifically be asked to “opt in” for future marketing purposes. We will not automatically add you to our marketing database without your consent.
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at info@fj-creditmanagement.co.uk

We do not share personal information with third parties for marketing or sales targeting. We share personal information with third parties, as laid out above, where necessary to carry out our business, your requests or as required by law or other legal processes. We will never sell your personal information to third parties.

If you choose to opt in to receive marketing, newsletters, updates and information from FJCM, we may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

The Right to portability

The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services.
It allows you to move, copy or transfer personal data easily from FJCM to another company in a safe and secure way, without hindrance to usability.

The Right to object

You also have the right to complain to the Information Commissioner’s Office (ICO) if you believe there has been a problem with the way in which we have been handling your data.

Rights in relation to automated decision making and profiling.
Franklin James Credit Management Ltd does NOT employ automated profiling in any way.

Lawful Basis for the processing of your data

We need to process your personal data to offer our services as a company in the UK. Your legal name and legal address are required to comply with UK tax laws which supersede data protection laws. Your contact details such as email or telephone numbers are required to be able to provide our contractual services to you whether those contracts be verbal or written

Changes to this policy

This privacy policy was created by Franklin James Credit Management Ltd on 24th April 2018. We may change this policy at any time. It is your responsibility to check this privacy policy regularly for changes.