VFS Privacy Policy
1 Introduction
The data protection rules which apply from 25th May 2018 (the General Data Protection Regulation (GDPR)) requires data (information) to be treated and handled in certain ways which support compliance with its requirements. The data of significance is data relating to Data Subjects (People) where the Data Subject is a Natural Person. This document provides an overview of:
- the types of information we collect about you
- how we collect and use it
- who we might share it with
- the steps we’ll take to make sure it stays private and secure
- your rights to your information
2 More information
This Privacy Policy will be amended to stay up to date. You can view a copy by visiting www.vfslegal.com or if you have any questions please contact VFS on 020 3747 9333. See section 12 below.
3 Who we are
When we say ‘VFS’, we mean Vertical Financial Services Limited who is the Data Controller for the information in this overview. This means we are responsible for deciding how we can use your information. Vertical Financial Services Limited has two wholly owned subsidiaries; VFS Legal Limited and Virtual Business Operation Services Limited.
4 This Privacy Policy
4.1 The Core Purpose
As a business VFS undertakes a number of functions. This Privacy Policy applies to the data processed to undertake its core purpose (Purpose) (see section 4.1). Privacy Policies covering data processed for other purposes are documented separately.
4.1.1 Description of the Core Purpose.
VFS provides services to businesses under commercial contract with those businesses (VFS Clients). The services provided consist of purchasing rights to and receiving payment of costs and payments in connection with these purchased rights, relating to a matter managed by the VFS Client. The services are a Core Activity of VFS and the activities to enable VFS to provide this service form the Purpose.
4.1.2 How we use your information for the Purpose
It is for the Purpose that it is necessary for data to be provided by VFS Clients to VFS and by VFS with other parties. VFS will use your information to
- identify the receivables purchased
- Exercise our rights to receive costs and payments due to it in relation to these purchased rights.
5 Lawful basis for processing personal data
VFS processes Personal Data and Special Categories of Data for the Purpose. It processes the data using the lawful basis of Consent, of the Data Subject. The consent is provided in a document – Consent to share information with VFS. It is obtained by the Business contracted to VFS (the VFS Client) and for which VFS operates the Purpose.
The Consent complies with the requirements for consent as defined by the GDPR and includes information on how to withdraw Consent.
6 Retention of Information
VFS will keep your information for as long as we have payments due to us. After this we will keep it whilst it is required for our legitimate purposes e.g. to help us respond to queries or complaints or for other reasons such as fraud prevention or resolution, and responding to requests from regulators, or as legally required by law.
7 The types of information we collect about you
The information we collect will include information relating to a matter (usually a legal matter) being run by the VFS Client, on behalf of their client who is often an individual, or the Data Subject in the context of this policy.
7.1 Categories of data
In performing the Purpose VFS will or may be provided with
- Personal Data
- Special Category Personal Data.
7.2 Types of information supplied
The following information is necessary to enable VFS to execute the Purpose. In each case the data will be that relating to the VFS Client’s matter for which the Purpose is being undertaken.
- Full or partial names of parties in the matter.
- Matter reference
- Consent to share information with VFS
- Assignments of rights
- ATE Insurer name and policy number
- Appointed Costs Draftsman
- Details of Disbursement costs
- Details of Bill of Costs
- Nature and details of legal settlements.
- Details of Opponent(s)
- Details of Opponents representatives
- Details of Promisors – being parties legally liable to, or who will pay costs, including disbursements
- The dates of events
- Details relating to the subject or relevant matters in hand which may include personal Health, Medical and Financial information.
Some or all of the above may for Personal Data or Special Category Personal Data as defined under the GDPR.
8 how we collect and use it
VFS will be supplied with and may seek information from several sources including:
- VFS Clients
- Costs Draftsman
- Sources of Public information
- Defendant Parties
- Insurers
9 who we might share it with
VFS does not share Special Category Personal Data with third parties for support of the Purpose
VFS shares information provided for the Purpose with the following parties who will process that information;
9.1.1 Within the VFS Limited Group of companies including wholly owned subsidiary businesses.
- Business Accounts
- Client Relationship Management
- Operations Administration
- Business Operations
9.1.2 With Third Parties for the Purpose
- Opponents and their representatives
- Appointed Costs Draftsman
- ATE Providers
9.2 Third Parties for support of VFS including general business support and support for the Purpose
- The PC Mac Company Limited
- Business IT Support services
- Ravensbay Limited
- Systems Development and applications support
- VFS Funders – OneSavings Bank plc
- Borrowing audit functions
10 the steps we’ll take to make sure it stays private and secure
VFS takes its responsibilities to safeguard your information seriously. Measures we take include: –
10.1 Electronically held information
- is held on systems owned by VFS and located in the UK, and / or
- All systems are protected by a firewall which meets industry standards.
- is held on compliant commercial facilities requiring authorised user ID and passwords
- Access to information is by authorised users only and requires user ID and Passwords
- All users are bound by security and privacy obligations which they have agreed to
- Information in transit is only held in encrypted form and requires User ID and passwords to access
10.2 Paper based information
- Is stored in locked cabinets with access restricted to authorised users
- Is stored in premises secured by controlled access.
- All users are bound by security and privacy obligations which they have agreed to
11 your rights to your information
VFS will support individuals’ requests to access their personal data in accordance with the requirements of the GDPR. In the first instance individuals should contact the party to whom they provided their Consent to Share information with VFS.
11.1 Individuals rights:
Individuals have the right to:
- confirmation that their data is being processed
- access to their personal data; and
- access to their Special Category Data
- other supplementary information, as defined in section 7.2 (Types of information supplied) of this document
- ask VFS to update incorrect information
- ask for processing to be restricted
- to be forgotten.
11.2 Access to your information
Any individual wishing to seek details of the information processed by VFS for the Purpose should in the first instance contact the party to which they provided consent for their information to be shared.
VFS will when requested provide applicable information to the party supplying the information to VFS and identify the Data Subject (you) to which it relates.
12 Contact VFS
VFS may be contacted by emailing – Enquiries@vfslegal.com. Please include details of how you can be contacted for the purpose of a reply.
Alternatively, please telephone 020 3747 9333.