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Legal Information

Company Information

We are Azzurro Associates Limited.
Registered in England with Company No: 10673742.
Registered office: 3 Hardman Square, Hardman Street, Spinningfields, Manchester, M3 3EB
ICO Data Protection Registration No: ZA288211
VAT Registration No: 295 6929 37

Azzurro Associates Limited is authorised and regulated by the Financial Conduct Authority. Registered on the Financial Services Register under registration number 832506.  

 

Terms & Conditions

The use of this Website is subject to the following terms and conditions of use, don’t worry, they’re short and make sense.

Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide without notice. We will not be liable if for any reason our site is unavailable for any period of time.

Occasionally we may restrict access to parts or to all our site; we will update it, replace content or redesign it and while all due care is taken to avoid errors and inaccuracies, we’re human too.

Our site is intended to inform but it is not intended to provide advice.  We therefore disclaim all liability and responsibility arising from any reliance placed on such content by you, or by anyone who may be informed of its content.

All content is copyright and owned by us or our partners, feel free to explore the site but not to use any of it without our prior written approval.


Website Privacy

As you would expect, Privacy and Security of data are fundamental to the way we work and this extends to your use of our website. We have designed it to provide you with a brief overview of our company, it is not a sales or marketing tool as such, so we collect no personal data from you.

The Cookies we do use are there to enhance your use of this website or let us know which job advertisement or information pages visitors find interesting, and which they don’t. Our content management system is Concrete5 and our Google Analytics tracking code will both use Cookies, they are:

Cookiecontent_status | Once you click on the 'agree to cookies' message, this cookie is saved to show you consented and stops the message popping up every time you visit.

_ga | Part of Google Analytics to let us know how many unique visitors we have and when they visit.

_gid | Part of Google Analytics and works with the above to let us know which pages people are looking at.

_gat_gtag_*Property* | Part of Google Analytics and used to throttle the request rate (how often the above send their data)

concrete5 | Functional cookie and part of the system that runs this website; used to help you navigate between pages and helps us log in to administer the website.

Managing or deleting cookies varies according to your browser and a few useful links are provided below, general information is available at www.aboutcookies.org

 

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Microsoft Internet Explorer Open

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Data Protection

This website is hosted on 'Green' servers using 100% renewable power, right here in the UK.
All operational data is stored on our Northern European Secure Servers and is encrypted at rest by default. Personal data is accessed by us via encrypted VPN, transfers of data to us from a Partner or Debt Collection Agency, and transfers from us to them is done over encrypted sFTP, encrypted email or Password-protected data file, depending on content and audience.

As mentioned earlier, we don’t collect data about you unless there is a business need to do so, but if you email us about something, or send us personal details such as your CV then we take all appropriate measures to preserve your privacy and to secure the information you gave us. We’ll only retain the information for as long as is necessary to process your query; obviously if you ask us to keep your CV on file in case a suitable role comes up in the future, we’ll happily do that. You can ask for your information to be deleted at any time by emailing us at dpo@azzurroassociates.com


Email Information and Disclaimer

Unencrypted email is used for general communications and if you communicate with us about a matter, we cannot guarantee the security of data sent to us; transmission of such data is therefore entirely at your own risk. If you need to communicate sensitive information to us, let us know first and we can arrange a secure method for you.

Email content and any attachment may be confidential and intended solely for the use of the individual to whom it is addressed. Any views or opinions expressed are solely those of the author and do not necessarily represent those of Azzurro Associates Limited. If you are not the intended recipient of the email, you must neither take any action based upon its contents, nor should you disseminate, distribute or copy the e-mail. Please contact the sender if you believe you have received the email in error. Although we have taken reasonable precautions to ensure no virus is present in the email, the company cannot accept responsibility for any loss or damage arising from the use of the email or attachments.


Data Subject Access

Both the new Data Protection Act and GDPR place great importance on the ability of a Data Subject (that's you) to see what information and data a company hold about you, what they do with it, and why. This seems perfectly reasonable to us too and the Data Privacy Notices below should help you understand how we consume data.
If you believe we hold information about you and wish to know more detail, or you think that the data we have may be inaccurate and you wish to correct it, please contact dpo@azzurroassociates.com and we’ll help.


Data Privacy Notice - Recruitment

This section explains what personal information we collect as part of our recruitment process, and what we plan to do with it. As such it only applies to the personal data of job applicants and to potential candidates for employment. It does not apply to our employees, contractors or clients, or other personal data that we collect for other purposes; other specific Data Privacy Notices have been produced for them.

What we collect and why
We collect and process personal information about you as part of the recruitment process and this may also include sensitive personal information. Initially we rely on what you tell us on your CV or provide to the recruiter. If you progress through to a face-to-face interview, we will ask you to bring along some ID. Successful candidates will be made an offer conditional on successfully clearing some background checks. Those checks are a UK Right-to-Work check and may also include Criminal Record check and Financial Credit check. The type and level of check depends on the role applied for and you will be informed early in the recruitment process.  As a responsible company regulated by the Financial Conduct Authority (FCA), we have an obligation to our customers, clients and to the regulator to ensure we employ the right people. Certain roles have mandatory background checks as part of our FCA authorisation. We will also use publicly available content and Social Media posts such as company blogs, trade body stories and LinkedIn content where we feel it can provide additional pertinent information about your current or past roles.

Information will be processed in order to identify you, to maintain contact with you, and to assess your suitability for the role you are applying for by mapping your details to the job requirements and by identifying your strengths and weaknesses and comparing you with the other candidates.

Your information will be solely used for the purpose of arriving at a decision relating to the success of your application to work for us and will never be passed to a third party, unless that third party is actively involved in the recruitment process (such as a Recruitment agency) or you give us explicit permission to do so (such as us passing your CV to a partner organisation we feel you would be a good fit for).

We may also release personal information to regulatory or law enforcement agencies if they require us to do so. We will also disclose your information where we are permitted and requested to do so by law.

What we will do with your data
Your data will be stored securely in an encrypted volume. Access to your data is controlled by a user-permissions structure, ensuring that only those with a need to view your details can do so.

Your data will be retained until a decision about your application has been made and at that time you will be informed of the outcome.
Where your application has been successful we will move your details in to our Employee files and additional information will be required and collected as part of our onboarding process.

Where you are not successful, our actions will be based on our legitimate interest mentioned and the consent you have given to store and process your details during the application process, and we assume you request we keep your details on file for any future roles we feel you might be suitable for. If you change your mind and do not wish for us to retain your details on file for future consideration, you can let us know at any time.

Where you request your details be deleted we will do so, with the exception of sufficient detail to allow us to identify you should you apply for another position in the future. This detail will typically be name and address and our commentary regarding this application.

Your rights over this data
You have the right, at any time, to request a copy of the information we hold on file about you. This is known as a Subject Access Request and if you would like to exercise this right, please contact our Data Protection Officer stating you wish to make a SAR and we will help you with the process.

You have the right to update and correct any information we hold. For example, if you have been rejected due to a lack of qualifications but we have agreed to keep you on file for the future, you can inform us of any new qualifications that make you more suitable for future employment and we will update our records.

Notifying us of any change to contact details would also be worthwhile.

You can object to our processing of your data, withdraw Consent (where we rely on consent) and request that data we hold about you be deleted at any time.

Where you believe we are acting otherwise in accordance with the law you have the right to lodge a complaint with a supervisory authority. For the UK that would be The Information Commissioner’s Office. An online service is available at: https://ico.org.uk/concerns/handling/


Data Privacy Notice - Customers

This section explains what personal information we typically collect once you become a customer, following our purchase of your debt, and what we plan to do with it. As such it only applies to the personal data of our customers. It does not apply to job applicants or employees or to other personal data that we collect for other purposes; other specific Data Privacy Notices have been produced for them.

What we collect and why

You provided a range of personal information to the original creditor as part of entering into a contract with them. This information will have been amended and updated during the course of your relationship with them. They will have obtained additional information about you as part of their processes, such as a credit check, or confirming your details through background checks and searches.

Some or all of this information is passed to Azzurro when we purchase your debt, and we are now the Data Controller in respect of the Account and all related information. We have the same rights to give information to Credit Referencing Agencies (CRAs) about the debt that you owe in respect of this Account, for example if you have fallen behind with your payments; information about the process can be found at http://www.scoronline.co.uk/

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained at each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document.

https://www.transunion.co.uk/crain; TransUnion (formerly Callcredit),

https://www.equifax.co.uk/crain; Equifax

https://www.experian.co.uk/crain/ Experian

We will also use this information in order to continue the relationship with you and to enable you to continue servicing the debt with us. We may carry out further checks at the start of our relationship with you, such as credit checks and searches, in order to confirm the accuracy of the information we have been passed, and to verify your current circumstances and ability to repay the debt.

Your information will be used for the purpose of operating our business and some personal details will be released to third-party organisations, such as Debt Collection Agencies and Solicitors acting on our behalf. We may also release personal information to regulatory or law enforcement agencies if they require us to do so. We will also disclose your information where we are permitted and requested to do so by law.

 

What we will do with your data

Your data will be stored securely in an encrypted volume in the EU. Access to your data is controlled to ensure that only those with a business-need to view your details or process your data can do so.

Information will be gathered during the course of the collections process in relation to payments and account management, and this may include both factual data and formed opinion. This information may be used to assist in the management of you as a customer, for the purposes of payment review or making you an offer of settlement, for making reasonable adjustments to terms, and for the pursuit of legal proceedings.

We analyse data and create groups and profiles in order to tailor the human interaction that follows, or to segment accounts in order to pass them to collections agents who specialise in your type of account; we do not make any fully-automated decisions about you from data.

Your rights over this data

You have the right to request a copy of the information we hold about you. This is known as a Subject Access Request and if you would like to exercise this right, please contact our Data Protection Officer stating you wish to make a SAR and we will help you with the process.

We encourage you to exercise your right to update and correct any inaccurate information we hold on you as decisions should always be made with the most accurate information. Where you identify we have something wrong, you can request we restrict processing until data is correct again.

You can object to our processing of your data, withdraw Consent (where we rely on consent rather than a Contract) and request that data we hold about you be deleted at any time. Where such requests are made, a review of the data will be made with a view to balancing your rights and request, with any business need of Azzurro, regulatory or legislative requirement to continue processing, or to retain said data.


Summary of how we may use your personal data

Under the GDPR and our new Data Protection Act 2018, you have a number of new rights, and the way companies use your data should be made clear to you - which is what this page is all about.
More information on the subject can be found at https://ico.org.uk/your-data-matters/

We have set out below the types of information we may hold (which will vary according to our relationship with you), the ways in which we may use your personal data, and which legal basis allows us to do so. We have also identified what our legitimate interests are where appropriate.

It's all pretty straightforward and we use your data in ways you'd expect us to. There are no surprises, and we don't do marketing, so the only contact from us will be in direct relation to your account, job or application to work for us.

Please note that we may process your personal data for more than one lawful reason, depending on the specific purpose for which we are using your data.
NB the lists are not exhaustive and are provided as a general summary, to inform you of the type of processing activity undertaken. Please contact us if you would like more detail about any of the information shown, such as which piece of legislation grants us rights, or where we have listed more than one type of data or Lawful basis, which one applies specifically to you.

Identity Data may include first name, last name, maiden name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data may include current address, previous address(s), email address and telephone numbers.

Financial Data
Customers - may include original debt value, additional advances/credit, interest and charges, historic and current notes about your account and financial situation. We store no bank account or payment card details.
Employees - we store your bank details to pay your salary.

Transactional Data
Customers - may include details about payments made by you, credits made against your account, notes and details about your account and collections.
Employees - Salary and expense payments, pension contributions and other benefits paid.

Profile Data is a tag to identify you as a job applicant, member or former member of staff, or a customer.

Performance Data may include productivity, sickness, absence information and statistics, accident reports, qualifications and CPD.

Communications Data may include details of your preferences in how we make contact with you, emails and letters, notes and transcripts, and some recordings of calls.

Technical Data may include internet protocol (IP) addresses, operating system, browser type, location (country only), date and time of contact. For employees this will aso include systems access and usage logs.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a job Applicant, new member of Staff or a new Customer

Identity

Contact

  • Necessary for our Legitimate Interests (to keep our records updated)
  • Performance of a contract with you

To deal with a general enquiry

Identity

Contact

  • Consent
  • Necessary for our Legitimate interests (Reasonable expectation to satisfy the request)

To deal with a Subject Access Request

Identity

Contact

Financial

Transactional

Communications

Performance

Technical

  • Necessary to comply with a legal obligation

To manage our relationship with you which may include:

  • notifying you about interviews, changes to roles or working practices, to inform of new roles you may be interested in, to obtain references.
  • updates to how your account is being managed
  • to undertake normal business activities
  • to pay your Salary or Pension and related Tax/NI
  • asking you to take part in an account review or take a survey
  • monitoring of performance, sickness, absence, undertaking reviews, evaluation for promotion or disciplinary
  • to provide a suitable and fair reference

Identity

Contact

Profile

Communications

Performance

  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated, to employ or re-employ the best staff, to provide requested references)

To manage your account and records, which may include:

  • manage payments, fees and charges
  • collect and recover money owed to us
  • share data with a Debt Collection Agent or to update a Credit Referencing Agency (CRA)
  • manage salary and expense payments, pension contributions, Tax/NI, to administer other benefits, accident reports, RIDDOR

Identity

Contact

Financial

Transactional

Communications

Performance

Special Category Data

  • Performance of a contract with you
  • Necessary for our legitimate interests (to maintain accurate records and data, to recover debts due to us, to prevent fraud)
  • Necessary to comply with a legal obligation
  • Necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity

To maintain an archive of your data, following the end of our relationship

All account data

 

  • Necessary to comply with a legal obligation

To administer and protect our business (including data analysis, testing, system maintenance, support, audit, reporting and hosting of data)

Identity

Contact

Financial

Transactional

Communications

Technical

Performance

  • Necessary for our legitimate interests (to run our business, provision of administration and recovery services, retention and use of accurate data, to prevent fraud, for data protection and network security)
  • Necessary to comply with a legal obligation
To use data analytics to improve our business processes

Financial

Transactional

Technical

Performance

  • Necessary for our legitimate interests (to define types of customers and their financial behaviour, to develop our business and to inform our investment and operational strategies)

 

Data Retention Periods

The period of time we retain data for depends on a number of factors, such as its relevance, its purpose, its source and any regulatory or legal requirements we must consider.

We follow the requirements of the Data Protection Act 2018 and GDPR in terms of only retaining data for the purpose(s) it was collected for, ensuring as far as possible that it is correct and accurate, and not stored for any longer than we or the law requires. Where we identify an issue with our data, we take appropriate action to correct and update as quickly as possible.

In general:

  • General information from enquiries and questions is retained only until we have answered the question
    We may retain certain aspects for longer, for the purpose of FAQs to better answer future questions or to evaluate our service and communications, but no personal information will be retained.
  • Recruitment information is retained until the end of the process and a decision is made. For an unsuccessful candidate we will retain for longer if you like the idea of working with us and wish to be considered for future roles, and you can still ask us to delete at any time
  • Where you are successful, most of your information is retained within staff records and updated throughout your employment, with the exception of CRB/background checks which are deleted shortly after you join as they serve no further purpose
  • Customer data is typically retained for 6 years after the end of our relationship in case of future legal action, query or audit. Some retention periods are longer as they are governed by the type of debt involved

If you have any specific questions about your data, please get in touch via dpo@azzurroassociates.com

 

How to make a complaint

Azzurro Associate’s aim is to treat customers fairly at all times. However, we recognise that sometimes things can go wrong. If you've got an issue, in the first instance please contact the 3rd party agency that we have appointed to act on our behalf and is managing your account, and let them know what your concerns are. If the agency is unable to resolve the issue you should contact us via our “contact us” page or via dpo@azzurroassociates.com

If you’re not satisfied with the outcome of your complaint,  you can refer your complaint to the Financial Ombudsman Service or call 0800 023 4567; the FOS are an independent authority for settling complaints between businesses and their customers. However, if you do not take up the problem with us first, any case will be referred back to us by the ombudsman in the first instance.

Where you believe we are acting otherwise in accordance with the law you have the right to lodge a complaint straight to the supervisory authority. For the UK that would be The Information Commissioner’s Office. 
An online service is available at: https://ico.org.uk/concerns/handling/

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