Privacy Policy

Here at Gregory Pennington Limited, we understand that protecting your personal information is of utmost importance. This privacy policy explains how we collect, use and store your personal information and how we ensure it is secure.

This privacy policy applies to you if you provide your personal information to us, even if you decide not to go ahead with any product or service we offer. It is also used by all the companies within our Group who provide debt solutions, including Freeman Jones Limited and Wilson Andrews Limited. Information may also be shared with think2claim to enable them to offer claims management services. Within this privacy policy we have set out how each of these companies will use your personal data to provide their product or service to you. You can find this easily by clicking on the links below:



If you have any questions about how we may use your personal information you can contact us on the details below.

If you click on a link that takes you to a third party website that is not ours we will not be responsible for how they use your personal data. You should read its own privacy policy to understand how they may use your personal data.

Date last updated: 24/10/2018

  • 1. What personal information do we collect?

    The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or where we’re required to collect the information to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.

    This will likely include the collection of:

    • • your personal details (e.g. name, date of birth)

    • • address details

    • • contact details (e.g. phone number, email)

    • • special personal information* (e.g. health information)

    • • financial information

    • • employment information

    • • information on how you use our website(s) and products and services

    Special personal information*

    Data protection law defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual orientation, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you. For example, a period of ill health could have caused you to fall behind with your regular payments to your creditors.

    Where we need to collect and process this type of data about you, by providing this information to us you give your explicit consent for us and any other third party to process this special data as set out in this privacy policy, unless we have a legal obligation to process this type of data.

    Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.

    Information about other people

    If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, a joint Debt Management Plan), your personal information and any information about the service provided to you will be shared with the other person.

    We will use the personal information about the other person in the ways as described in this privacy policy.

  • 2. How do we collect your personal information?

    We collect your information in a number of ways.

    • • When you make an application or enquiry to us either by phone, email, our website, by a third party or by any other means

    • • Information received from a third party, for example a creditor providing information about an account you hold with them, or where you have previously agreed for your information to be shared with us, for example, if you have been introduced to us by another company

    • • When you participate in market research, competitions and promotions provided by us, or on our behalf

    • • By adding reviews or interacting with us using social media such as Twitter or Facebook etc

    • • When you use online platforms, such as an online portal

    • • When we may need to obtain up to date information about you to meet our legal or regulatory obligations

    • • Where you have given permission for your information to be provided to us

  • 3. How we use your personal information?

    We can only use your personal information where it falls into one or more of the following categories:

    • 1. it is necessary to enter into or fulfil a contract we have with you;

    • 2. you have provided your consent;

    • 3. we have a legal or regulatory obligation to do so;

    • 4. it is necessary to carry out a task which is in the public interest;

    • 5. it is necessary to protect your vital interests; or

    • 6. it is in our legitimate interest to do so and it is not against your rights.

    Initial Application/Advice

    Where you make an application or enquiry for one of our products or services we’ll use your information to provide you with appropriate information about any solutions we may be able to offer to you. If you cannot provide this information we may not be able to progress with your application or enquiry.

    We may also use this information to contact you about and process your application, for example, sending you an email, text message or letter to welcome you to our services.

    We will process the personal data we collect about you for the purposes set out below at Purposes for Processing your Personal Data .

    After you have made you initial application/enquiry, if you also decide to go ahead with any of the products or services that we offer, the sections below explain how we will also process your data when we provide that particular product(s) or service(s).

    Ongoing Services

    Where we are providing you with a debt solution, such as a Debt Management Plan, Debt Arrangement Scheme (DAS), Individual Voluntary Arrangement (IVA); Trust Deed, Sequestration/Minimal Asset Process (MAP), Debt Relief Order (DRO) or with claims management services or any other financial services solution, we will process your personal information to administer the services we provide. This may include contacting you where we may need further information, or sending you updates on the progress of the services we provide to you.

    Where we provide ongoing services, we will normally require you to agree to the terms and conditions of the debt solution or service. These will set out how we will provide the services to you and where we will be required, under the terms and conditions, to process your personal information. For example, we would need to your share information with your creditors to enable us to set up and administer a Debt Management Plan.

    Please read the section(s) relevant to the specific products and services you receive from us.

    • Debt Advice

      If we give you Debt Advice, this will be provided by Gregory Pennington Limited. The table below specifically explains how and why your personal data will be used so that the services can be provided to you. When providing you with debt advice we collect and use your personal information under the lawful basis of our legitimate interest and is necessary to enable us to provide you with the best advice possible.

    • Debt Management

      If you enter into a Debt Management Plan, this will be provided by Gregory Pennington Limited. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.

    • Debt Settlement

      If you use our full and final settlement service, it will be provided by Gregory Pennington Limited. The table below specifically explains how and why your personal data will be used so that this service can be provided to you.

    • Individual Voluntary Arrangement

      If you enter into an Individual Voluntary Arrangement (IVA), it will be provided by Freeman Jones Limited. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.

    • Trust Deed

      If you enter into a Trust Deed, it will be provided by Wilson Andrews Limited. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.

    • Sequestration (including Minimal Asset Process)

      If sequestration is the solution you decide on, Wilson Andrews Limited will collect and process your personal data to help you with your application. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.

    • Debt Relief Order

      If a Debt Relief Order (DRO) is the solution you decide on, Gregory Pennington Limited will collect and process your personal data to help you with your application. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.

    • Debt Arrangement Scheme

      If a Debt Payment Programme (DPP) under the Debt Arrangement Scheme is the solution you decide on, Gregory Pennington Limited will collect and process your personal data to help you with your application and administer your DPP. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.

    • Claims Management Services

      If you require claims management services this will be provided by think2claim. The table below specifically explains how and why your personal data will be used so that the services can be provided to you.


    + Other Purposes for processing your Personal Data

    Websites and marketing

    To help us understand you better and provide you with information about other products which may be suitable and relevant, we will use your personal information to create a profile of you and your circumstances. This allows us to provide more relevant, accurate and tailored services to you. For example, we may assess your income and expenditure to determine whether you would be eligible for a debt solution through us. We believe we have a legitimate interest to do this and that it is not against your rights.

    However, if you don’t want us to profile your personal information this way, to then better enable us to tailor any marketing communications to you, you can contact us to let us know that you wish for your personal data not to be used in this way.



    Reviews and Market Research

    Where we have a copy of your personal information we may contact you to ask you to provide a review about the services you’ve received or where we are carrying out market research which may help us design future products and services or to help improve our current services. Although this information would really help us, you wouldn’t be required to provide us with this information unless you were happy to. We consider that this is in our legitimate interests to contact you in this way for market research purposes.



    Legal or Regulatory Obligation

    We are required to process your personal information where we have a legal or regulatory obligation to do so, for example, to adhere to anti-money laundering or our regulatory obligations.



    Responding to complaints or enquiries

    If you make an enquiry or complaint with us, we will use your personal information to investigate the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with your complaint appropriately.



    Internal Analysis

    As part of our legitimate interest to develop our business and our products we will use your personal information to assess our performance as a business and for statistical analysis. We will use your personal information to assess our performance as a business and for statistical analysis. We will use as little personal data as we can to achieve this. We may also share this analysis with third parties who provide us with services and where we have a contractual obligation to do so.

  • 4. Automated Decision Making

    An automated decision is one which we rely on a computer or system to assess the information you provide to us to make a decision about you. This may include:

    • • assessing your eligibility for a product or service

    • • detecting any fraudulent activity which may be taking place, or there is a risk that it could take place

    • • checking identity and residency statuses

    If we do make an automated decision about you, in some cases you have the right to ask that we do not make our final decision based solely on the automated decision, and you can also object to the automated decision and ask that someone reviews it. If you want to do this you’d need to contact us, or use the contact information which will be provided to you once you’ve received the automated decision.

  • 5. Who do we share your information with?

    In addition to the companies, organisations and other third parties set out in Section 3, we may also share your personal information with the following organisations:

    • • IT Service Providers who provide IT platforms or other IT services

    • Payment Service companies that process transactions for us (e.g. Direct Debits and card transactions)

    • Communication providers (e.g. telephone line providers, and email and text service providers)

    • Printers who print the letters and information packs which we send to you

    • Advertisers and social media companies such as Facebook, Google and Twitter for our social media accounts or where we can contact you using your social media account

    • Third parties who may have introduced you to our services

    These companies help us to provide our services to you. We will have a contract in place with any provider who directly provides us with such direct services to ensure that they comply with their data protection obligations and ensure that they have appropriate security measures in place.

    We may also share your personal information where we have your consent to do so or where we’re required to do so under a legal or regulatory obligation or court order, such as the police, local authorities or the courts.

  • 6. Fraud Prevention Agencies

    The personal information we have collected from you may be shared with law enforcement agencies and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist financing and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. Further details of how your information is used by us and these fraud prevention agencies, and your data protection rights, can be found by contacting us or email us at [email protected]

  • 7. Social Media

    We use publicly available social media platforms to promote our services, to provide updates and to share any news and promotional updates. We may collect personal information from these social media platforms, for example, if you post a message on our Facebook page. By providing any of your information to us through these platforms you should be aware that:

    • • the social media web pages are publicly available and you must not provide any personal or sensitive information on our pages that are accessible to the public, such as your account information. We may ask you for your account information via a private message to identify you and to service any request you make; and

    • • each social media platform will process any personal information you provide through the platform and will be processed in accordance with its own privacy policy. The privacy policies are available to view on each social media platform.

  • 8. Sharing your information outside of the EEA

    We will only share your personal information outside the European Economic Area (EEA), where we have your consent; to comply with a legal obligation; or where we work with a business partner to enable us to provide you with our services, and they process information outside of the EEA.

    If we do share your information outside of the EEA we will make sure that it is protected in the same way as if it was being used in the EEA to ensure appropriate safeguards are in place. This may include putting in place a contract with the business partner that means they must protect the personal data to the same standards as the EEA (this may include defined model clauses), or only share the data to a business partner in a non-EEA country where the privacy laws provide the same protection as within the EEA or where they are part of a Privacy Shield.

    More information on this can be found on the European Commission Justice Website.

  • 9. Security

    We take the protection of personal information very seriously and we will maintain appropriate measures to maintain the confidentiality, integrity and availability of the information you have provided. Such measures include:

    • • Company security policies and standards

    • • staff security awareness

    • • role based access controls to prevent unauthorised access to the information

    • • encryption and anonymisation technology

    • • anti-malware technologies

    • • security monitoring

    • • security testing

    • • secure archiving and deletion

    • • compliance with industry regulation and legislation

  • 10. How we may contact you about the products and services we provide to you

    To help us keep you up to date about the products and services that we provide to you, and to ensure that you’re kept fully informed, we may contact you by letter, telephone, email, text message, push notifications, social media or may send you messages by any online customer platforms or other electronic means.

    If you start an application for a product or service through us we will attempt to contact you shortly after if you were unable to complete your application for whatever reason.

    If you do not want to be contacted in a particular way then you can request this at any time, but if we are providing a service to you, we do need to be able to send you communications. This can often be due to a legal or regulatory requirement.

    It is important that you keep us up to date when you change your contact details to ensure that we use your up to date contact information.

  • 11. Your Rights

    Access to your personal information

    You have the right to request from us a copy of the personal information that we may hold about you. This is often called a “Data Subject Access Request”. You can request this information by contacting us as set out below. Up until 25th May 2018, we may charge you up to £10 to provide you with this information, but after this date we won’t charge you to provide you with this information.

    Before providing this information to you or to another person or company where you have requested this personal information to be sent to, we may ask for proof of identity or ask sufficient questions to enable us to locate the information and ensure that we’re only providing it were you have given your agreement.

    Right to have your personal information corrected

    If the personal information we hold about you is incorrect you have the right to request that we correct this.

    Right to stop or limit the processing of the data we carry out

    You may request that your personal information is deleted or that we stop processing the information if we’re no longer entitled to process it. There may be occasions where we are unable to delete the data due to our legal or regulatory obligations. We will however discuss this with you if you request for your information to be deleted.

    Portability

    In some cases you may be able to request for your information to be provided to you or to another company in a format that can be processed electronically by you or the other company. If you want to request this you’ll need to contact us.

  • 12. How long do we keep your personal information for?

    Whilst you continue to be our customer, we will keep a record of your personal information to ensure that we provide you with the best service possible and where we’re required to keep your personal information to meet our legal and regulatory obligations. The product specific information above sets out how long your personal information will normally be kept for. Telephone calls will be retained for at least 6 years from the date the call was made.

    If you do not go ahead with any product or service offered by the Group, your personal information will normally be deleted after 2 years unless we have another reason to keep your data, for example, if you have given your consent to receive marketing or promotional messages from us.

  • 13. How we may contact you about other products or service that we may offer

    If you have provided us with your consent or where we are legally entitled to do so, we may contact you to let you know about other offers, products and services that we provide which we think you may be interested or that may benefit you. We may do this through post, emails, text messages, telephone, push notifications, social media or other electronic means.

    You can easily let us know at any time if you would no longer like to receive these messages. You can contact us using the details below, emailing us at [email protected] or unsubscribing using the link or information within the message.

  • 14. Other types of advertising

    When you visit our website or similar websites Google may use our advertisements promoting our products and services which may appear on other third party websites you visit across the internet for remarketing purposes, including cross-device remarketing. Google and other third parties will use cookies to tailor advertisements for website users based on their previous visit to our website. More information about cookies can be found below.

    We do not have any control over the advertisements you see on other third party websites however you can request to opt out or customise these advertisements by using the Google Ads Preference Manager.

  • 15. Recording Calls

    We record any telephone calls you make to us or we make to you or any other third party. This is for training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some telephone calls may be observed by staff for training and development purposes.

    We may keep a copy of the telephone calls for up to 6 years from the date the telephone call was made.

  • 16. Contact Us

    If you have any questions or queries about how we use your personal information you can contact us or our Data Protection Officer using the address or email below:

    Data Protection Officer
    Gregory Pennington Limited
    Think Park
    Mosley Road
    Trafford Park
    Manchester
    M17 1FQ

    Email: [email protected]

    If you are not happy with how we process your personal information you should contact us in the first instance. If you’re not happy with how we have dealt with your complaint you have the right to lodge a complaint with the Information Commissioner’s Office. You can find their details on their website at https://ico.org.uk/

  • 17. Updates to this Privacy Policy

    Any updates to this privacy policy will be found on this page. If we make any important or significant changes to the way we may collect and use your personal information we will endeavour to notify you of this change.

  • 18. Cookies

    When using this website, some information may be collected automatically using 'cookies'. These are small text files that facilitate the processing of your data and enable us to analyse how the website is being used. Cookies can be temporary or permanent.

    Temporary cookies form part of the security process while you are using the website; permanent cookies identify the link you used to find our website, check your browser so that we can make sure that our website and services work well with your computer and to help us monitor traffic on our website.

    Why are cookies used?

    They help visitors. Cookies allow sites to do things like provide personalised content and remember their log-in details and settings. You can turn them off - this won't stop a website from working, but it might mean it won't work as well as it could, or that you have to do the same thing more than once.

    They help website owners. Cookies tell website owners things like: what search engine a visitor used to find the website, how often they've visited it, how long they've spent on it, and so on.

    We've set out below the cookies that we may use and those that are set by third parties on our website.

    Except for essential cookies, all cookies will expire after 10 years.



    Disabling/Enabling Cookies

    You have the ability to accept or decline cookies by modifying the settings on your browser and by clicking on the disable button below. Please remember though that disabling certain cookies may affect the functionality of our website.

    None of the features of our website will be affected - giving you the full experience.

    If you are using Microsoft Windows Explorer:

    • • Open 'Windows Explorer'

    • • Click on the 'Search' button on the tool bar

    • • Type 'cookie' into the search box for 'Folders and Files'

    • • Select 'My computer' in the 'Look In' box

    • • Click 'Search Now'

    • • Double click on the folders that are found

    • • 'Select' any cookie file

    • • Use the 'Delete' button on your keyboard

    If you are not using Microsoft Windows Explorer, then you should select 'cookies' in the 'Help' function for information on where to find your cookie folder.

    We do not pass on, or sell cookies to any other companies. Further information on the use of and managing cookies can be found at http://www.allaboutcookies.org.