We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to the Data Protection Act 2018 (DPA 2018)we are responsible as ‘controller’ of that personal information for the purposes of those laws.
It would be helpful to start by explaining some key terms used in this policy:
This Privacy Notice covers the type of information we collect, how we collect it and what we use the information for. It covers information we collect about our customers (who are mainly service providers as well as about their customers who are unable to make payments, or in early stages of potential financial crisis. We also collect information from visitors to our website and digital assessment and this privacy notice also covers all visitors to our website: www.telljo.org.
Personal information we collect about you
We may collect and use the following personal information about you:
- E-mail address
- Phone number
- Business or company name
- Bank details that companies have permitted us to use for the purpose of invoicing
- Information relating to financial hardship
- People who use our services, e.g. who subscribe to our newsletter or request a publication from us
- Your mental and physical health
- Your general wellbeing
- Possible addictions
This above list is not exhaustive and there may be other information which we need to collect for the purposes of carrying out our services. You can find out what personal data we have collected and hold about you by contacting us. See “Your Rights” section below.
Special Category Data
Where you are showing signs of potential crisis such as a missed payment, in order to determine whether there are extenuating circumstances (such as vulnerability) affecting your ability to meet your obligations to pay your bills we may need to review Special Category Data. In order to make this determination we may ask you for, or you may volunteer to give us, Special Category Data such as information about disability, illness or pregnancy and/or information about age, recent bereavement, family circumstances and employment status. We will only use this personal data to determine your vulnerability and we will obtain your consent to processing this data.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps.
We may also collect information:
- Directly from a third party, eg:
- Companies that would like us to contact you to identify potential vulnerability in order to positively discriminate.
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations.
- for the performance of our contract with you or to take steps at your request before entering into a contract.
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we, or a third party have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Where you are a customer of one of our clients that provides services to you we may rely on legitimate interests to collect and process information about you. This is because we have a legitimate interest in helping our clients understand if they are likely to recover payment for their services. We also have an interest in helping you manage your payment issues and communicate effectively with those service providers to which you owe money. When we process your information for legitimate interests we make sure that we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal data where our interests (or those of our clients) are overridden by the impact on you (unless we have your consent or are otherwise permitted by law).
You have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section below.
Other Purposes and Reasons for Processing Personal Information
The table below provides more information about the purposes for which we use Personal Information and our reasons for doing so.
To comply with our legal and regulatory obligations.
or our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about new products and services.
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
- existing and former customers.
- third parties who have previously expressed an interest in our services.
- third parties with whom we have had no previous dealings.
The above table does not apply to Special Category Data, which we will only process with your explicit consent.
We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including about new services and products. Where you are a customer of ours or have shown an interest in becoming a customer or using our services, we have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’ ). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the TellJO group for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us at [email protected]
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Where your personal information is held
Information may be held at our offices and those of our group companies, clients, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’ ).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’ .
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing services to you.
Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law;
- in order to reprofile and rescore vulnerability in order to measure social and financial resilience and measure changes in score;
- in order to offer free interventions that can support your identified vulnerability or have a positive impact in your life
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), eg:
- with our offices outside the EEA;
- with your and our service providers located outside the EEA;
These transfers are subject to special rules under European and UK data protection law.
We will ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the Data Protection Act 2018 (DPA 2018). To obtain a copy of those clauses and would like further information please contact us (see How to contact us below).
You have the following rights, which you can exercise free of charge:
- at any time to your personal information being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- complete a data subject request form—available on our website at http://telljo.org/TellJO_SAR.pdf or
- email, call or write to us — see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address and customer account or matter reference number);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published on 18th July 2018 and last updated on 15th March 2022 We may change this privacy notice from time to time—when we do we will inform you via email and/or website update.
How to contact us
Our contact details are shown below:
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above)