Our Privacy Policy

Data Controller

We, West Midlands Case Management Limited are the data controller of your personal data.

Data Protection Officer

West Midlands Case Management Limited has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, please get in touch by either

• Writing to The Data Protection Officer, West Midlands Case Management Limited, Unit 29 Highcroft Industrial Estate Enterprise Road, Horndean, Waterlooville, PO8 0BT ; or
• Emailing to contact@wmcasemanagement.co.uk

Complaints

You have the right to make a complaint at any time to the relevant supervisory authority. In the UK, this is the Information Commissioner’s Office (ICO), https://ico.org.uk, or to the data protection regulator in the country where you live or work.

We would appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact the Data Protection Officer (see ‘Who we are and other important information/Data Protection Officer’ section above) in the first instance.

If you’re in the UK, we must confirm we’ve received your complaint within 30 days. We’ll then look into it and reply within a reasonable time.

Third-Party Links

This website may include links to third-party websites, plug ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit to ensure that you are happy about using that site.

What personal information we might gather

Personal information or personal data as it is also referred to means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Some of the information will come directly from you (for example, when you purchase a product or when you open an account with us) and we might also get some from publicly available places. The information that we collect will depend on the reason for your contact with us.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, home address, email address and telephone numbers.
• Financial Data includes payment card details and, where you or your business have or apply for a credit account with us, bank account details and information held by credit reference and fraud prevention agencies.
• Transaction Data includes details about you/your business trading history, including payments from you/your business and signatures used to sign for receipt of goods.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website/or any apps.
• Profile Data includes your username and password, products/services provided to you/your business, feedback and survey responses.
• Usage Data includes information as to how you use our website.
• Marketing and Communications Data includes your preferences as to whether you are happy to receive marketing from us and, if so, your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal data in law as this data does not directly or indirectly reveal your identity (for example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature). However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.

In the normal course, we will not collect Special Categories of Personal Data about you.

What purposes might use your personal data for

We’ll only use your information if we have your permission, or we have another legal reason for using it. These reasons include:

• if we need to look into our legitimate interests;
• to enter into or carry out an agreement we have with you;
• where we’re required to by law;
• where we believe it’s in the public interest for us to do so e.g. to help prevent or detect crime;
• to establish, utilise or defend our legal rights;

We have set out below, the reasons we use your personal information, and which of the legal bases we rely on to do so and what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

When we refer to legitimate interests, we mean the interest of our business in conducting and managing our business to enable us to give you the best service/product. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

If you are in the UK and we rely on recognised legitimate interests (like preventing crime or protecting vulnerable people), we don’t need to do a formal assessment. But we will still make sure your rights are protected.

Automated decision making

We do not currently undertake automated decision making using your personal information.

In the future, we will only use automated systems to make important decisions about you if the law allows it and we have already informed you.

Tracking or recording what you say or do

We may store details of your interactions with us. We may also record and keep track of conversations with us including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication.

We may use these to check your instructions to us, improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also store additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use.

We use closed circuit television (CCTV) in and around our offices and branches and these may collect photos or videos of you or record your voice. Our websites, apps, and other digital products may track and record your interactions with them.

Marketing/promotional offers

We strive to provide you with choices regarding certain personal information uses, particularly around marketing. Where you have agreed to receive it, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which goods, services and offers may be relevant for you.

We will only share your personal data for marketing purposes in accordance with your preferences/consent. To make a change to marketing messages at any time, you have the following options either:

• By logging on to your account on our website and changing your marketing preferences, or
• By asking one of our colleagues in branch to change your marketing preferences, or
• By following the opt-out links on any marketing message sent to you; or
• By Contacting Us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Changing the purpose for using your personal information

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sharing your data

We may share your information with others where lawful to do so including where we or they:

• need to in order to provide you with products or services you’ve asked for;
• have a public or legal duty to do so, e.g. to help with detecting and preventing fraud, tax evasion and financial crime;
• need to for any regulatory reporting, litigation or asserting or defending legal rights and interests;
• wish to send marketing to you or others, where you’ve given us your permission, or it’s within our legitimate interest to do so;
• other companies in the Grafton Group and any sub-contractors, agents or service providers who work for us or provide services to us or other Grafton Group companies (including their employees, sub-contractors, service providers, directors and officers) whether directly or providing underlying infrastructure services;

Occasional reasons for sharing

We may share your information for these purposes with others including:

• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimisation of our services and website;
• professional advisers, including lawyers, banks, auditors and insurers;
• debt collection and/or debtor tracing agencies in connection with the recovery of your/your businesses unpaid debt;
• other businesses in the same or related sectors relating to your/your business' trading history with us;
• other businesses in the West Midlands Case Management Limited Group relating to your/your business' trading history with us;
• regulators and other authorities;
• prevention/detection;
• third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.

Where these third parties are our processors, we require them to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party processors to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions. Some of the third parties mentioned above, for example, many professional advisers and HM Revenue and Customs, are controllers who, like us, are subject to specific obligations under data protection law, and who will have their own privacy notices setting out how they deal with personal data.

Your Privacy Rights

You have a number of rights in relation to the information that we hold about you. These rights include:

• the right to see information we hold about you and to get information about what we do with it;
• in some circumstances, the right to withdraw your permission to our processing of your information, that you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
• in some circumstances, the right to receive certain information you have provided to us in an electronic format and/or ask that we send it to a third party;
• the right to ask that we correct your information if it’s inaccurate or incomplete;
• in some circumstances, the right to ask that we delete your information. We may continue to keep your information if we’re entitled or required to keep it;
• the right to object to, and to ask that we limit our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to limit our processing of your information but we’re entitled to continue and/or to refuse that request.

You can exercise your rights by contacting the Data Protection Officer, see ‘Who we are and other important information’ section above.

What we need from you

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

We may update this Privacy Notice from time to time and encourage you to review it regularly.