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INKSMOOR CREDIT MANAGEMENT LIMITED – PRIVACY NOTICE – CLIENTS

We are committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you during the course of our relationship with you, in accordance with data protection law.

WHO ARE WE AND HOW TO CONTACT US

“We”, “our” or “us” means Inksmoor Credit Management Limited trading as Think Outsource. Our registered office is at Hornyold House, Blackmore Park, Hanley Swan, Worcester, WR8 0EF. We are the controller of your personal information. We are required under data protection law to notify you of the information contained in this privacy notice.

This privacy notice provides an overview of what personal information we collect and store and how we use the personal information of our individuals within our customer companies (including their directors, shareholders, company officers and employees) as well as sole traders and partnerships. This privacy notice also tells you what your rights are over your personal information and how to exercise those rights. 

If you have any questions or concerns about the information contained in this notice, or about our handling of personal information more generally, or if you would like more detailed information on a particular point, you should contact our Managing Director Sarah Radley who can be contacted at privacy@inksmoor.co.uk .

NAVIGATION

This privacy notice answers the following:

• How we use your personal information that we collect from your use of our website, when you contact us by phone or email and our legal basis for that?
• How we use your personal information when you become a customer of Inksmoor?
• Will we change the way we use your personal information?
• What happens if you don’t provide the personal information we have asked for?
• Do we use your personal information to make automated decisions?
• How long will we keep your personal information?
• Who will we share your personal information with?
• Will we transfer your personal information outside the EEA?
• How do we ensure that your personal information is secure?
• What rights do you have over your personal information?
• How will we tell you about changes to this privacy notice?
• How you can contact us?

HOW WE USE YOUR PERSONAL INFORMATION THAT WE COLLECT FROM YOUR USE OF OUR WEBSITE, WHEN YOU CONTACT US BY PHONE OR EMAIL AND OUR LEGAL BASIS FOR THAT

1. What personal information do we collect and how do we use it?

Information you give us: If you fill in the ask a question or call back form on our website, request information through an application or contact us via email, telephone or social media channels, either on behalf of a company you work for or on your own behalf, we will collect the information you include on the form or which you provide to us when you contact us, such as your name and contact details. We will use this information to:

• send you the information you have requested, for example about our products and services; and
• respond to any query you have raised.

Information we collect about you from browsing our website: We use cookies on our website. If you would like details about what cookies we use please see our cookie policy which can be accessed here.

1. What is our legal basis for using your personal information?

Under data protection law we must have a legal basis to use your personal information. We have set these out below.

Information you give us: When you fill in our ask a question or call back form on our website, request information via an application or contact us via email, telephone or social media channels, the legal basis for this use (regardless of whether you are contacting us on behalf of a company you work for or on your own behalf) is that it is in our legitimate interests as a business to be able to respond to enquiries that we get. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use is proportionate because we will only use the information we get from you to respond to your enquiry and it is in your reasonable expectations that we would need to use your personal information to be able to respond to you.

Information we collect about you from your use of our website: Where we collect personal information through cookies we will use your personal information as per our cookie policy which can be accessed here.

HOW WE USE YOUR PERSONAL INFORMATION WHEN YOU BECOME A CUSTOMER OF INKSMOOR

1. What personal information do we collect and how do we use it?

Information you give us: If you become a client of Inksmoor and would like to appoint us to provide you (or the company you work for) with credit management and/or back office services, we will collect information from you. Where you are a sole trader or partnership we will collect your name, home address, telephone number, email address, DOB, business bank account details such as the name of your bank, your account number and sort code. Where you are an employee of a company we will collect your name, job title, business email address, business telephone number and business address. We will use this information to:

• set you (or the company you work for) up as a customer on our systems;
• negotiate and conclude our contracts for our credit management services and/or back office services with you (or the company you work for);
• fulfil our obligations under our contract with you (or the company your work for);
• manage the contract which we have with you (or the company you work for);
• carry out any enforcement action against you (or the company you work for) where necessary;
• take payment from you (or the company you work for) for our services; and
• market our services to you where you have consented to this.

Information we receive from other sources: We will carry out financial due diligence on our customers which will involve us carrying out anti-money laundering checks. Where you are a sole trader or partnership this may reveal information about you and your financial history. Please note where the company is our client, these checks may reveal personal information about company officers, directors and/or owners of organisations who are our customers or prospective customers. 

We will also carry out a due diligence process, for all our new clients where you are a sole trader or partnership this will involve us carrying out consumer reports which may reveal personal information about you.

Please note that where the company is our client, these reports may reveal personal information about company officers, directors and/or owners of organisations who are our customers or prospective customers.    

When we obtain information about you from a credit reference agency, they will keep a record of our enquiry against your name. More information about the credit reference agencies we share your personal information with, how they use your personal information and how long they will keep it is available in the credit reference agencies’ privacy notices. In the UK, these privacy notices can be found at: https://www.creditsafe.com/gb/en/legal/privacy-policy.html

1. What is our legal basis for using your personal information?

Under data protection law we must have a legal basis to use your personal information. We have set these out below.

Information you/your organisation gives us when negotiating, concluding or performing our obligations under our contract: Where you are a sole trader or partnership our legal basis for using the personal information you give us when entering into negotiations, concluding or performing our obligations under our contract with you is that it is necessary for the performance (or taking steps to enter into) of our contract with you. Where you are employed on behalf of a company, our legal basis for using your personal information is that it is in our legitimate interests as a business to be able to contact you to negotiate, conclude or discuss the ongoing performance of our contract with your company. We consider that personal information we obtain (during the negotiating, concluding or performing our obligations under our contract with your company) is within your reasonable expectations, taking into account the value of the contract or potential contract being entered into, and the information is limited to the business context.

Information you/your organisation gives us when we set them up as a new client on our systems: Where you are a sole trader or partnership our legal basis for using the personal information you give us when we set you up as a client on our system is that it is necessary for the performance (or taking steps to enter into) of our contract with you. Where you are employed on behalf of a company, our legal basis for using your personal information is that it is in our legitimate interests as a business to be able to use your personal information in order to set the company you work for up as a client on our systems. We consider that using your personal information in this manner is proportionate because it is within your reasonable expectations, taking into account that we need your contact details in order to discuss details of the account of the company you work for with you, and the information is limited to the business context.

Information you give to us or which we get from other sources to perform financial due diligence:  Where you are a sole trader or partnership our legal basis for using the personal information you give to us or which we get from other sources to perform financial due diligence is that it is in our legitimate interests as a business to check the financial standing and credit of our customers in order to safeguard our finances and reputation. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that carrying out due diligence is proportionate because it is within your reasonable expectations, taking into account the value of the contract or potential contract being entered into, and the information is limited to the business context. Where you are a company officer, director and/or owner of the organisation who is our customer or prospective customer these checks may reveal financial information about you, and our legal basis for using your personal information is that it is in our legitimate interests as a business to check the financial standing and credit of our customers in order to safeguard our finances and reputation. We consider that carrying out due diligence is proportionate because it is within your reasonable expectations, taking into account the value of the contract or potential contract being entered into, and the information is limited to the business context.

Information we will use in order to enforce our contract with you (or the company you work for): Where you are a sole trader or partnership our legal basis for using your personal information to enforce our contracts with you is that it is necessary for performance of our contract with you. Where you are employed on behalf of a company, our legal basis for using your personal information is that it is in our legitimate interests as a business to enforce our contracts with the company you work for. We consider that using your personal information in this manner is proportional because it is within your reasonable expectation as a company employee that we will use your personal information to contact you, for example in order to seek to enforce our contracts where it is necessary for us to do so.

Information we use to carry out enforcement action against you (or the company you work for): Where you are a sole trader or partnership our legal basis for using the personal information you give to us to carry out enforcement action against you is that it is in our legitimate interests as a business to undertake appropriate action to recover the debts owed to us. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that using debt collection agencies or other enforcement action is acceptable on the basis that it is in your reasonable expectations that should you fail to pay the debts owed to us we should be able to seek recovery of these. Where you are a company officer, director and/or owner of the organisation who is our customer, our legal basis for using your personal information is that it is in our legitimate interests as a business to recover outstanding debts owed to us. We consider that carrying out enforcement action when necessary is proportionate because it is within your reasonable expectations, taking into account that it is a normal course of action for businesses to be able to recover money owed to them.

Information we use where you have agreed that we can market to you: Under data protection law we must have a legal basis to use your personal information. Where we use your personal information for marketing, we do this on the basis that [you have consented to us sending you marketing. You have the right to change your mind about this at any time.] There will be unsubscribe links in all the marketing emails that we send you, and you can also contact us at any time to ask us to stop sending marketing to you. If you wish to do this, please fill in our form on our website. We will refresh the consent you have given us by contacting you at least every two years.

WILL WE CHANGE THE WAY WE USE YOUR PERSONAL INFORMATION?

We will only use your personal information for the purpose we have set out in this notice. We can only change the purpose we use it for without telling you where we need to use it for another reason if that reason is compatible with those set out in this notice. If we need to use your personal information for any other purpose, we will notify you and we will explain the legal basis which allows us to do so in a similar way to how we have done it in this notice.

WHAT HAPPENS IF YOU DON’T PROVIDE THE PERSONAL INFORMATION WE HAVE ASKED FOR?

If you don’t provide the personal information we need when we ask for it, we may not be able to contact you in relation to a contract we have entered into with you or the company you work for or conclude or perform our obligations under that contract. Where we process your personal information on consent you have the right to withdraw your consent at any time. If you have any concerns about whether you need to provide the personal information requested, please contact our Managing Director Sarah Radley (see contact details above).

DO WE USE YOUR PERSONAL INFORMATION TO MAKE AUTOMATED DECISIONS?

We will not use your personal information to make decisions that will have a significant impact on you based solely on automated decision making (i.e. one without human intervention).

HOW LONG WILL WE KEEP YOUR PERSONAL INFORMATION?

We will not keep your personal information for longer than we need it for the purposes we have explained in this privacy notice. We will retain all personal information set out in this privacy notice for a period of six years from the initial date of contact.

Please contact our Managing Director (see contact details above) if you would like any further information about our retention periods. If a dispute arises between us, we will keep your personal information for the purposes of responding to and dealing with this dispute and this may mean that we keep your personal information for longer than six years.

WHO WILL WE SHARE YOUR PERSONAL INFORMATION WITH?

We will only share the personal information that you give us with the following third parties and for the following reasons:

• Group companies: We will share your personal information with our group companies which are Inksmoor Selective Finance Limited, Inksmoor Capital Limited and Inksmoor Finance Group Limited. This is because they provide us with assistance in managing customer accounts, orders, sales and marketing, technical support and payment. We consider the use of your personal information in this way is in our legitimate interests. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this is proportionate because we will only pass on the information that is necessary and we enter into data sharing agreements with our group companies.
• With organisations for the purposes of carrying out financial due diligence: Where we carry out financial due diligence in relation to our customer organisations or prospective customers the results may reveal your personal information. We share your personal information in this way as it is in our legitimate interests as a business to ensure we are contracting with customers and companies who can honour their contracts with us. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this use of personal information is proportionate because we will only pass the information to reputable organisations and we have a contract with them.
• With companies who provide us with or support our IT systems (including our CRM system and our applications) and website: We use reputable third parties to provide us with our IT systems and the applications and website and support for them. They may access your personal information to the extent that they need to in order to provide their services. We consider it is in our legitimate interests to be able to use reputable third party providers to provide these services. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this is a proportionate use of your personal information because we only share the information that is necessary to enable our suppliers to provide their services and we have a contract with them.
• With a company that we merge with or transfer our business assets to: In the event that we sell all or part of our business, or merge with another company, we may transfer personal information that we have collected as described in this notice, along with our other business assets, to the company that we are selling to or merging with. We do this on the basis of our legitimate interests in being able to merge or sell our business. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this is a proportionate use of your personal information because we would only share what was necessary in order to allow the other entity to consider entering into the transaction and we would enter into a contract with them which required them to observe your rights in relation to data protection.
• With entities, companies or individuals outside our group for legal reasons: We will (where appropriate) share your personal information with entities, companies or individuals outside our group where this is necessary to: comply with any law, rule, regulation, legal procedure or governmental request that is applicable to us. The legal basis for this is that sharing your personal information in this way is necessary in order for us to comply with our legal obligations.
• With entities, companies or individuals outside our group to obtain advice: We may (where appropriate) also share your personal information with external professional advisors such as lawyers or accountants in order to take advice or enforce the terms of our agreements. The legal basis for this is that it is in our legitimate interests as a business to be able to obtain professional advice from our external advisors about issues that may arise within our business such as how to enforce our contracts. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that this is a proportionate use of your personal information because it is in your reasonable expectations that we would need to share your personal information with our professional advisors, we would only share what was necessary in order to allow our advisors to advise us, enforce our contracts and for the purposes of legal proceedings and we enter into contracts with our advisors.
• With organisations to recover any outstanding debts owed: We may (if appropriate) also share your personal information with external debt recovery agencies, and/or other enforcement organisations such as insolvency practitioners, lawyers, and bailiffs whom we instruct to recover the debt(s) owed to us. Our legal basis for using the personal information to recover any debt(s) owed to us by you is that it is in our legitimate interests as a business to recover our debts. We have considered our legitimate interests carefully and have balanced our legitimate interests against your rights under data protection law. We consider that employing external debt recovery agencies and/or other enforcement organisations is proportional because it is within your reasonable expectations that, as a business, we will seek to recover any debt(s) owed to us.

WILL WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE THE EEA?

At the present time we store your personal information in the United Kingdom or in countries within the EEA (i.e. EU Member countries together with Iceland, Liechtenstein and Norway). We will only transfer your personal information outside the EEA to third party service providers who have support or management services located outside the EEA or host personal information outside the EEA.

We only transfer your personal information outside the EEA where we have a legal basis for doing so and where we require that your personal information is protected to the same standard as it would be protected in the EEA. We do this by checking whether the country or territory we are transferring the personal information to has been awarded a finding of adequacy by the EU Commission or by entering into data sharing agreements with the recipients of your personal information based outside the EEA which comply with the EU Commission’s standard clauses for the transfer of personal information.

If you would like further details about our transfer of your personal information outside the EEA or details of the safeguards put in place in relation to your personal information please contact our Managing Director Sarah Radley.

HOW DO WE ENSURE THAT YOUR PERSONAL INFORMATION IS SECURE?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information 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.

WHAT RIGHTS DO YOU HAVE OVER YOUR PERSONAL INFORMATION?

You have the right to make a complaint at any time to your local regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the regulator and so, if you are happy to do so, please contact our Managing Director Sarah Radley (see above for contact details) in the first instance and we will try to resolve your issues.

You also have a number of additional rights over your personal information, which are:

• the right to ask us what personal information we have about you and to have a copy of your personal information from us;
• the right to ask us to correct any errors in your personal information;
• the right to ask us to review and explain our legitimate interests to you;
• the right to ask us to delete your personal information where: (i) we don’t need your personal information anymore; (ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information; (iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing; (iv) our use of your personal information is illegal; (v) we have to delete your personal information to comply with our legal obligations;
• the right to ask us to restrict the use that we are making of your personal information where: (i) you don’t think the personal information we have about you is correct, so that we can check if it is correct; (ii) what we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it; (iii) we don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights; and (iv) you have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing; and
• the right to ask us to transfer your personal information in certain circumstances.

If you want to exercise the rights set out above please contact our Managing Director Sarah Radley (see above for contact details).

HOW WILL WE TELL YOU ABOUT CHANGES TO THIS PRIVACY NOTICE?

We keep our privacy notice under regular review. Any changes we make to our privacy notice in the future will be posted on this page and if the changes will have an effect on you or the way we use your personal information we will bring them to your attention by email where appropriate (e.g. if we have your email address as a contact at one of our customers).

HOW YOU CAN CONTACT US

If you have any questions about this privacy notice or about the ways we use your personal information, please contact our Managing Director Sarah Radley (see above for contact details).