Privacy Policy

Why have we access to and process your data?

Under the terms of your contract / agreement with the Client, your personal data may be passed to a third party in the event that payments are not made as agreed. In such cases, your personal data may be transferred to Intrum for credit management purposes, which includes debt recovery.

Intrum is instructed to collect debt on behalf of the Client as a data processor. The Client is the owner of the debt and is the data controller. Your personal data is passed to us from the Client with whom you owe money pursuant to a contract / agreement that you entered into with the Client. The transfer of data to us is governed by the terms of the contract / agreement between you and the Client. We will only process your personal data if we have legal grounds to do so in accordance with current data protection legislation. Debt collection is of public interest and the Client and Intrum have a legitimate interest to process your personal data to recover monies you owe.  Pursuant to the instructions of the Client we have the legal right to process your data without your prior consent. In accordance with the Client’s legitimate interest (and where instructed by the Client), we may also undertake tracing activities, scoring to ensure an effective service and compliance with good debt collection practices, enrich the data from legitimate sources e.g. to verify that the data we hold is correct, and share your data with approved third parties such as other public/private collection services, approved suppliers and law enforcement agencies.

The purpose of processing your data is to engage with you to understand your current financial situation, and to recover the outstanding debt by agreeing an affordable and sustainable way for you to repay the amount owed.

If you would like to know more about the legal basis for which we process your data, please refer to the Client’s terms and conditions together with its privacy notice.

Your data will be held securely in compliance with data protection legislation.

What personal data are you processing about me and why?

The Client has provided your data to us and we hold the necessary information to engage with you to recover the outstanding monies owed. To be able to communicate with you and to ensure secure and valid identification, we  may hold financial information such as payment history, default details, information on your debt, income, assets, credit, loans, and payment history. 

To better understand your specific situation and to make a well informed decision on how to administer your case, we may also process your reasons for non-payment, depending on the information you provide to us, e.g. individual or family circumstances, work-related issues, etc.

The personal data we hold may also be needed for us to be able to defend legal claims. We also use your personal data to offer and further develop an effective service and to ensure good debt collection practices e.g. through scoring activities based on historic information/performance, recording of phone conversations to train/audit our employees, and to document your rights. Unless we have legal obligations to keep the records, we will delete them in accordance with the Client’s retention policy or in accordance with data protection legislation.

We have a legal obligation to provide your personal data when we are audited by the authorities and to prevent, monitor and evidence fraud, anti-money laundering and other criminal activities to various law enforcement and government agencies.

Where instructed by the Client we will provide access to or share your personal data with approved third party suppliers.

Unless otherwise agreed with you, or it is necessary for the establishment, exercise or defence of legal claims, we will not include special categories of personal data.

Are you processing any sensitive data regarding me?

Unless otherwise agreed with you or is necessary for the establishment, exercise or defence of legal claims, we will not include special categories of personal information (often known as ‘sensitive personal data’ such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the processing of data concerning health or sex life). 

It may however benefit you to notify us of any health condition, disability and/or personal information relating to your private life that may impact your ability to repay. This will allow us to take reasonable adjustments to accommodate your needs or requirements such as allowing sufficient breaks in your repayment arrangement, providing breathing space to seek free independent debt advice (Money Advice and Budgeting Service), or adjusting your repayment arrangement.

This information will be used by us to assist you and will be kept as long as it is required for this purpose, or until you notify us that you no longer consent to its processing or it is necessary for the establishment, exercise or defence of legal claims.

Please note that even where you withdraw your consent, where we believe it is in your vital interest to do so, we have a legitimate reason to continue processing your personal data.

Do I have to provide you with my personal data?

You do not have to provide us with any personal data. In fact, most (if not all) personal data that we process about you comes from another source other than yourself i.e. the Client instructing us and public registers / databases.

However, you may choose to provide us with additional personal data. Such information helps us handle your case in the most appropriate and empathic manner. For example, you may have a valid reason for why you have not paid your debt (bereavement, ill health, vulnerability or personal circumstances) which you may want to share with us, so we can find the most appropriate solution based on your personal circumstances.

Will you share my personal data with others?

We will share your data with the Client as the data controller. Where instructed by the Client, we may share your personal data with our suppliers that facilitate and/or provide parts of our services, e.g. printer and mail services, call centre services, field collectors, legal representatives / auditors etc. We may also share your personal data with governmental authorities, regulators and law enforcement agencies.

Our employees will have access to the personal data. In such a case, access will be granted only if necessary for the purposes described and only if the employee is bound by an obligation of confidentiality.

Will my personal data be transferred to another country?

As a data processor, Intrum may only transfer your personal data on the instructions of the Client. As we are part of the Intrum Group, we may transfer your data to another country. If we do, we will ensure there are suitable safeguards in place to comply with EU General Data Protection Regulation (GDPR) and Irish Data Protection law. Generally, your personal data will not be transferred outside of the European Economic Area (EEA). However, in the case of international debt collection, your personal data may be transferred to one of our agents working in the relevant country. We also use third-party service providers to store or whom may access your data, which may be located outside of the EEA. We will never transfer your personal data outside of the EEA without ensuring the safety and protection of your personal data. Therefore we make sure that any recipients have signed the EU Standard Model Clauses, to justify the transfer, or that the country guarantees adequate protection of your data under the data protection legislation.  We may disclose information outside of these groups to help prevent fraud, or if required to do so by law.

How long do you store my personal data?

We will retain your data pursuant to the Client’s data retention policy or in compliance with data protection legislation. We will not hold you data longer than is necessary.

Will I be subject to automated decision-making?

Intrum does not undertake automated decision-making where it acts on behalf of the Client.

What rights do I have?

It is important you understand that it is your personal data that we process and that we want you to be comfortable with us doing so. Even if we do not need your permission to process your personal data, you have many rights in relation to the processing of your personal data. The Client can explain these further to you. However, in general, please see the data rights available to you below.

Your rights, and what does it mean?

Right to access
You have the right to obtain a copy of your personal data, as well as other supplementary information, to understand how and why the Client and Intrum are using your personal data, and to check that this is being undertaken lawfully. To request this information, you should write directly to the Client as the data controller, who will arrange for all personal data belonging to you, to be provided, including that being processed by Intrum. On this basis, Intrum, as a data processor, will respond to the Client directly. The Client is responsible for complying with your request within the associated timescales.

As Intrum administer your account on behalf of the Client we are the data processor. The Client remains the data controller and the overall responsibility for your data remains with them, as they determine the purposes for, and the manner in which your personal data is processed regarding your account.

If you write to Intrum requesting your data, we will forward your request to the Client as the data controller, for them to respond to your right of access request.

Please note that both Intrum and the Client reserve the right to request further information from you before a) forwarding your request to the Client and b) before the Client supplies the information to you. This may involve a request to supply information such as evidence of your identity or authorisation (where you have instructed a third party to act on your behalf), and requesting what data you require where your request is non-specific and/or too general. We do this to prevent unauthorised disclosure and to ensure you receive the right information.

Under data protection legislation the Client has one calendar month to provide you with the information requested. Therefore, to avoid delays, all right of access requests should be sent directly to the Client. Intrum as a data processor, cannot accept liability for the Client not processing your request.

Right to correction
It is important that we have the right information about you and urge you to let us know, if any of your personal data is incorrect, e.g. if you have changed your name or moved.

Right to be forgotten
If we process your personal data in an unlawful way, for example if we process your personal data longer than is necessary or for no justifiable reason, you may ask us to delete this information. We will refer your request to the Client.

You may also request that we restrict the processing of your personal data if the processing is unlawful but you do not want us to delete the personal data. We will refer your request to the Client.

Right to objection
If you believe that we do not have the right to process your personal data, you may object to our processing. In such cases, we will refer your request to the Client. The Client is responsible for providing you with compelling / justifying reasons, that out-weigh your interests, rights and freedoms. However, we may continue to process your personal data if it is required for the determination, exercise or defence of legal claims or we consider it to be in your vital interest. Whilst we will refer your request to the Client, debt collection is of the public interest and it is unlikely that this right will apply.

Withdrawal of consent
Intrum and the Client does not base the processing of your data upon consent. However, given that some processing activities must be based on consent (such as special categories of data), you are in your right to withdraw it and we and the Client will consequently stop the processing activities based on this legal ground. 

Please note that even where you withdraw your consent, where we believe it is in your vital interest to do so, we have a legitimate reason to continue processing your personal data.

How to complain about the use of your data or exercise my rights?

If you wish to raise a complaint about how we process your personal data, including in relation to any of the rights outlined above, you can contact the Intrum team, who will investigate your concerns.

Email

dataprotection@ie.intrum.com

Address

Intrum Ireland Ltd, First Floor, Block C, Ashtown Gate, Navan Road, Dublin 15, D15Y3EK, Ireland

You can also raise your complaint with the Client directly. We refer you to the Client’s privacy notice and terms and conditions for further information.

If you are not satisfied with our or the Client’s response, or believe we are processing your data unfairly or unlawfully, you can complain to The Data Protection Commission. You can find further information about The Data Protection Commission and their complaints procedure here Data Protection Comission - Exercising your rights

If you have any further questions on how we process your personal data, you may contact us through dataprotection@ie.intrum.com.