Ascent is committed to the protection and security of your privacy and personal data.
Your personal data is processed fairly and in accordance with the law and this webpage explains how we use your personal information in the course of our normal activities.
Ascent generally acts as a data processor for the Clients from whom we receive instruction
You may also make requests in relation to your data rights by completing the request form on our group data protection site here.
Ascent Privacy Notice
Ascent Performance Group Ltd (Ascent) is a subsidiary of the IM Group and is a specialist law firm and financial services business providing customer outsource services, arrears management, mediation, debt collection, litigation and recovery services across the UK. Any reference to “we”, “our” or “us” means Ascent Performance Group Ltd.
In order that you are reliably informed about how we operate, we have developed this privacy notice, which describes the ways in which we collect, manage, process, store and share information about you as a result of you visiting this site. The privacy notice also provides you with information about how you can have control over the use of your data.
Ascent acts as a data processor for the clients from whom we receive instruction. In some limited circumstances Ascent will also act as a data controller.
If you have any comments or queries regarding our use of your data, please contact our Group Data Protection Officer at email@example.com
Alternatively, you can write to our Group Data Protection Officer at Ascent, Imperial House, 31 Temple Street, Birmingham B2 5DB.
2. What information do we collect about you?
In general terms, we seek to collect information about you so that we can:
- support you to reach an agreement with your creditors to manage your debt.
- aid financial organisations within the UK with debt recovery management and to help you to find a solution to repay any debts.
- locate you when contact between you and your creditors has been lost.
- assist you with your equity loan mortgage advice.
The information that we need for these purposes is known as your “personal data”. This includes your name, home address, email address, telephone and other contact numbers and financial information. We collect this in a number of different ways. For example, you may provide this data to us directly online or over the telephone, or when corresponding with us by letter.
We also process sensitive classes of information (also known as special category data) that includes:
- physical or mental health details
- racial or ethnic origin
- religious or other beliefs of a similar nature
- offences including alleged offences
- criminal proceedings, outcomes and sentences
Lastly, we process sensitive data such as offences including alleged offences and criminal proceedings, outcomes and sentences.
We will seek your permission where required if we need to record any of your sensitive personal data on our systems.
We voice record our customer interactions, therefore any information captured via this medium will automatically be stored, for training and monitoring purposes.
3. How will we use the information?
We use the data collected from you for the specific purposes listed in the table below. Please note that this table also explains:
- the legal basis for processing your data, linked to each processing purpose; and
- in what circumstances your data will be shared with a third party organisation.
|Purpose for processing data||Legal basis for processing data||Third party organisations with whom data is shared|
|To process customer requests for debt management support.||To meet the requirements of a contract.||Ascent is part of the Irwin Mitchell Group and there are a number of services that are
centralised within the Group such as IT, and regulatory or operational services. Therefore, we will also share your information with Irwin Mitchell LLP for these reasons.
Ascent also uses LPC Law to act on our behalf at any Court appearances. We will share information with this third party when providing our instructions.
|To process payments.||To meet the requirements of a contract.||Irwin Mitchell Group – Accounts Department, IT Department|
|To communicate with you via email, telephone, SMS, in writing in order to update you as necessary about your specific financial matters.||To meet the requirements of a contract.||LPC Law.
Adare SEC Limited
Ascent also use Appointed Representatives to complete home visits, we will share information with these Self Employed Agents so that they can contact you about the visit.
|To provide customer support by telephone – to include recording of telephone conversations for monitoring and quality purposes.||This is deemed legitimate as it is in customers’ interest that we can access their data in order to resolve any queries, questions, concerns, complaints.||Irwin Mitchell Group – IT Department
BSL, Redbox – call recording
|To enable us to locate customers who have lost touch with their creditors.||To meet the requirements of a contract between the creditor and customer.||We use UK Search to help us locate Customers.|
|To enable us to manage customer accounts that have been outsourced to us by financial organisations.||To meet the requirements of a contract.||Irwin Mitchell Group – Risk and Compliance, IT Department, Accounts Department.|
|To assist you with equity loan management advice.||Legal obligation.||Irwin Mitchell Group|
Whether we can change the purpose that we are collecting, storing and using your personal information for is not covered in the privacy notice.
How we process your personal information in relation to marketing is not covered either
4. Your rights?
If you wish to make a request under data protection legislation, please contact Group Data Protection Officer at Ascent, Imperial House, 31 Temple Street, Birmingham B2 5DB
As explained above, Ascent generally acts as a data processor for the clients from whom we receive instruction. Therefore, in scenarios in which you make a request as a customer of one of our clients, we will inform you to relay this request to our client.
Under the terms of data protection legislation, you have the following rights:
Right to be informed
Right to access
You have the right to ask us what personal information that we hold about you. This is known as a “Subject Access Request”. Except in exceptional circumstances (which we would discuss and agree with you in advance), you can obtain this information at no cost. We will send you a copy of the information within 30 days of receiving your validated request.
To make Subject Access Request, please write to our Group Data Protection Officer at Ascent, Imperial House, 31 Temple Street, Birmingham B2 5DB
Right to rectification
If any of the information that we hold about you is inaccurate, you have the right to ask us to correct any errors in your personal information.
Right to be forgotten
You have the right to ask us to delete your personal information where:
(i) we don’t need your personal information anymore;
(ii) you withdraw your consent to our use of your personal information and we have no other legal basis to keep your personal information;
(iii) you have asked us to review and explain our legitimate interests to you and we don’t actually have a valid legitimate interest to do what we are doing;
(iv) our use of your personal information is illegal;
(v) we have to delete your personal information to comply with our legal obligations.
Right to object
You have the right to object to:
- the continued use of your data for any purpose listed in section 3 above for which consent is identified as the lawful basis for processing i.e. you have the right to withdraw your consent at any time.
- the continued use of your data for any purpose listed in section 3 above for which the lawful basis of processing is that it has been deemed legitimate.
Right to restrict processing
You have the right to ask us to restrict our use of your personal information where:
You don’t think the personal information we have about you is correct, so that we can check if it is correct
What we are doing with your personal information is illegal but you would rather we stop using your personal information rather than delete it
We don’t need your personal information anymore, but you need us to keep it so that you can exercise any legal rights
You have asked us to review and explain our legitimate interests to you, so that we can check whether we actually have a valid legitimate interest to do what we are doing.
If any of these circumstances apply, then please contact us.
Right to data portability
The right to ask us to provide you with a copy of the personal information you have provided to us, in a structured, commonly used and machine-readable format and the right to transfer that personal information to another entity where:
(i) we are using your personal information on the basis of your consent or on the basis that it is necessary to perform a contract with you; and
(ii) the use we are making of your personal information is carried out by automated means.
If you would like to move, copy or transfer the electronic personal information that we hold about you to another organisation, please contact us.
Rights related to automated decision-making and profiling
Automated decision making is individual decision-making (making a decision solely by automated means without any human involvement), and profiling is automated processing of personal data to evaluate certain things about an individual). Profiling can be part of an automated decision-making process.
If you would like to object to automated decision making without any individual involvement, and to the profiling of your data, please contact our Group Data Protection Officer at Ascent, Imperial House, 31 Temple Street, Birmingham B2 5DB or via email at firstname.lastname@example.org
Right to make a complaint
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), (the UK regulator for data protection issues, who may be contacted at Wycliffe House, Water Lane, Wilmslow SK9 5AF or ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO and so, if you are happy to do so, please contact us in the first instance and we will try to resolve your issue.
5. Is the processing of information likely to cause individuals to object or complain?
Ascent is not aware of any justifiable reasons that would constitute a legitimate reason for objecting or complaining about the way we process or control information.
6. How long will we retain information for?
Ascent will typically retain information for a period of seven years. This is due to regulatory reasons and to ensure our business records are adequate to maintain the requisite levels of insurance to protect both our clients and customers.
In some cases where Ascent is not the data controller, your information may be kept for a longer period due to our instructing client requirements. In such cases our clients will hold specific details of the retention periods should you require further clarification about this.
7. Do I have the right to withdraw consent to hold my information?
Due to the nature of work undertaken by Ascent and the contractual position between our customers and clients there will not usually be a right to withdraw consent for Ascent to hold your information. This is because there is a legitimate reason for Ascent to control or process your information as described above, which is not based upon consent.
However, where you have provided your consent for us to process your data, e.g. where you have agreed to providing us with special category data or sensitive personal data as mentioned above then you can withdraw your consent to us processing this data at any time.
8. Overseas transfers
None of the information that we collect process or store as a result of this website is transferred outside of the European Economic Area (EEA). This includes information that is exchanged with any third party organisation as described above.
9. Data privacy and security
At Ascent, we maintain a comprehensive data management work programme, which includes processes for ensuring that data protection is a key consideration of all new and existing IT systems that hold personal data. Where any concerns, risks or issues are identified, we conduct relevant impact assessments in order to determine any actions that are necessary to ensure optimum privacy.
We also maintain an active information security work programme which seeks to protect the availability, confidentiality and integrity of all physical and information assets. Specifically, this helps us to:
- protect against potential breaches of confidentiality;
- ensure all IT facilities are protected against damage, loss or misuse;
- increase awareness and understanding of the requirements of information security, and the responsibility of our colleagues to protect the confidentiality and integrity of the information that they handle; and
- ensure the optimum security of this website.
Questions and comments regarding this Privacy Notice are welcomed, and should be sent to our Group Data Protection Officer at email@example.com
Alternatively, you can write to our Group Data Protection Officer at Ascent, Imperial House, 31 Temple Street, Birmingham B2 5DB.
You can also contact our Group Data Protection Officer is you have any concerns or complaints about the ways in which your personal data has been handled as a result of you using this website.
Alternatively, you have the right to lodge a complaint with the Information Commissioner’s Office who may be contacted at Wycliffe House, Water Lane, Wilmslow SK9 5AF or https://ico.org.uk