Privacy Policy

(web)

• ✔️Your right of access
• ✔️Your right to rectification
• ✔️Your right to erasure
• ✔️Your right to restriction of processing
• ✔️Your right to object to processing
• ✔️Your right to data portability

Produced by

Compliance Department

October 2025

This document is issued by the Compliance Department of:
Debt Advisory Services (Scotland) Limited
Crescent House, Lever Street, Bolton BL3 6NN

Registered in Scotland with no. SC296502 at
International House, 38 Thistle Street, Edinburgh EH2 1EN
Authorised and regulated by the Financial Conduct Authority (FRN 671573) to provide debt counselling and debt adjusting services
Data Protection Registration Number: Z9406864
Web: www.debt-advisory-services.co.uk

Data Protection Act 2018 and UK GDPR – How we will use your information

Please read the following section carefully, as it explains what personal data we collect about you and how we use this information.

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it can also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Debt Advisory Services (Scotland) Limited trading as Debt Advisory Services will use your information only to contact you to discuss the provision of debt solutions and related services like credit information services. We also have permissions for claims management services. Where the service you have requested is provided on our behalf by a third party we will notify you of that fact. We will treat all your Personal Information as defined by the DPA and UK GDPR as confidential (although we reserve the right to disclose this information in the circumstances set out below). We will keep it on a secure cloud-based server, and we will fully comply with all applicable UK data protection and consumer legislation.

We will not retain your personal information for longer than is necessary for the maintenance of your account, or for legal or regulatory requirements. Where you provide the name(s) or other personal information about family/household members you confirm that you have their consent to do so for the purposes set out in our Privacy Policy.

Any information we collect, and hold is used to help us improve the quality of our service, including electronic call recordings, scanned documents and secure messages between you and us.

We confirm that any Personal Information that we collect about you, from which we can identify you, is held in accordance with the requirements of the DPA and UK GDPR. We use your information only for the following purposes:

• Provision of regulated debt management services
• Provision of credit information services
• Provision of claims management services
• Provision of financial services and advice
• Debt administration and factoring
• Undertaking Know Your Client (KYC) and Anti-Money Laundering checks, where required
• To administer our websites
• Accounts and records
• For the prevention and detection of crime and the prosecution of offenders
• Advertising, Marketing and Public Relations on our own behalf or on behalf of third parties (subject to your consent)

Unless required to do so by law, regulation or contract, we will only collect, use and share information from and about you if we have agreed this with you first. We may discuss data sharing with not-for-profit providers like the Vulnerability Registration Service (VRS), where this is in your best interests and consistent with the new legitimate interest provisions in the Data Use and Access Act 2025.

Your Personal Information may be disclosed to other businesses within the Debt Advisory Services group and to reputable third parties who will help process any account you may have with us as part of core service delivery (e.g. a debt advice session). Debt Advisory Services requires all such third parties to treat your personal data as fully confidential and to fully comply with all applicable UK data protection and consumer legislation from time to time in place.

Marketing

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by post, e-mail, SMS, WhatsApp or telephone with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003. You will always have the opportunity to opt-out or select your contact preferences. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

You may unsubscribe from our mail, e-mail, telephone or SMS contact list at any time by replying to a promotional e-mail or SMS message with the word “STOP” in the subject line; by e-mailing us at
info@debtadvisoryservices.co.uk
or telephoning on 01204 890 760, Monday – Thursday 9am to 7pm and Friday 9am – 5.30pm.

You should be aware that if we are requested by the police or any other regulatory or government authority investigating suspected illegal activities to provide your Personal Information and/or User Information, we may be legally required to do so.

We use Cookies to personalise your experience and so that you may retrieve your details at any time – if you do not accept Cookies you may be unable to use these facilities on our website. See “About cookies” for further details.

Any changes to this policy will be posted on our website or notified to you in writing.

When we share your information

We will treat your personal information as private and confidential, but may share it with others and disclose it outside of Debt Advisory Services if:

• allowed by the debt management agreement
• you explicitly consent
• HM Revenue & Customs or other authorities require it
• the law, regulatory bodies (including for research purposes), or the public interest permits or requires it;
• required by us or others to investigate or prevent crime
• required as part of our duty to protect your accounts, for example we are required to disclose your information to the UK Financial Services Compensation Scheme (FSCS)

The DPA and UK GDPR defines certain information as ‘special category’ or ‘sensitive’ (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). We may ask you for some ‘sensitive’ details or special category data where you meet our Vulnerable Customer Policy. We will only use this information to provide the service you require and we will ask for your explicit consent. As a customer, there may be times when you give us sensitive information.

We will always ensure your information remains safe and secure. It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

The following personal data is collected, held, and processed by Debt Advisory Services for the purposes of delivering its core services as a regulated debt management firm:

Your rights under Data Protection Law

We operate under the Data Protection Act 2018 (‘DPA’) and UK GDPR.

The DPA and UK GDPR apply to ‘personal data’ that we process, and the data protection principles set out the main responsibilities we are responsible for.

You have a right to receive a copy of the personal data that we hold about you.

To obtain a copy of the personal information we hold on you, please write to us at the address below or ring us on 01204 890 760 (Monday – Thursday 9am to 7pm and Friday 9am – 5.30pm) and provide us with your details or ask for a Data Subject Access Request (DSAR) form.

Questions regarding this Policy should be directed to:

Data Protection Officer
Debt Advisory Services (Scotland) Limited
Crescent House, Lever Street, Bolton BL3 6NN

We must ensure that personal data shall be:

1. •processed lawfully, fairly and in a transparent manner;
2. •collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
3. •adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
4. •accurate and where necessary kept up to date;
5. •kept for no longer than is necessary for the purposes for which the personal data are processed. We operate a data retention policy that ensures we meet this obligation. We only retain personal data for the purposes for which it was collected and for a reasonable period thereafter where there is a legitimate business need or legal obligation to do so. For detail of our current retention policy contact our Data Protection Officer at:
   info@debtadvisoryservices.co.uk.
6. •processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.

We ensure lawful processing of personal data by obtaining consent; or where there is a contractual obligation to do so in providing appropriate products and services; or where processing the data is necessary for the purposes of our legitimate interests in providing appropriate products and services.

In the majority of cases we process personal data based on your contract (i.e. Debt management agreement) with the us. In other cases, we process personal data only where there are legitimate grounds for so doing.

To meet its Data Protection obligations, we have established comprehensive and proportionate governance measures.

We have our own Data Protection Officer to oversee data protection compliance across Debt Advisory Services through:

• implementing appropriate technical and organisational measures including internal data protection policies, staff training, internal audits of processing activities and reviews of internal HR policies.
• maintaining relevant documentation on processing activities.
• implementing measures that meet the principles of data protection by design and data protection by default including data minimisation, pseudonymisation, transparency, deploying the most up-to-date data security protocols and using data protection impact assessments across our organisation and in any third party arrangements.

You have the following specific rights in respect of the personal data we process:

1. •The right to be informed about how we use personal data. This Privacy Statement explains who we are; the purposes for which we process personal data and our legitimate interests in so doing; the categories of data we process; third party disclosures; and details of any transfers of personal data outside the UK.
2. •The right of access to the personal data we hold. In most cases this will be free of charge and must be provided within one month of receipt.
3. •The right to rectification where data are inaccurate or incomplete. In such cases we shall make any amendments or additions within one month of your request.
4. •The right to erasure of personal data, but only in very specific circumstances, typically where the personal data are no longer necessary in relation to the purpose for which it was originally collected or processed; or, in certain cases where we have relied on consent to process the data, when that consent is withdrawn and there is no other legitimate reason for continuing to process that data; or when the individual objects to the processing and there is no overriding legitimate interest for continuing the processing.
5. •The right to restrict processing, for example while we are reviewing the accuracy or completeness of data, or deciding on whether any request for erasure is valid. In such cases we shall continue to store the data, but not further process it until such time as we have resolved the issue.
6. •The right to data portability which, subject to a number of qualifying conditions, allows individuals to obtain and reuse their personal data for their own purposes across different services.
7. •The right to object in cases where processing is based on legitimate interests, where our requirement to process the data is overridden by the rights of the individual concerned; or for the purposes of direct marketing (including profiling); or for processing for purposes of scientific / historical research and statistics, unless this is necessary for the performance of a public interest task.
8. •Rights in relation to automated decision making and profiling.

Please contact our Data Protection Officer at
info@debtadvisoryservices.co.uk
for more information about the GDPR and your rights under Data Protection law.

If you have a complaint about any data protection matter then contact our Data Protection Officer at
complaints@debtadvisoryservices.co.uk
in the first instance.

Alternatively contact our supervisory authority for data protection compliance
(www.ico.org.uk):

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)

https://ico.org.uk/for-the-public/how-to-make-a-data-protection-complaint/