Lowell Group Debt Collection 2020 – Solution, Guide, FAQs & More

Are you being hassled by Lowell Group Debt Collectors? Do you owe money you are unable to repay? Are you being asked to repay debts you don’t owe? Are you being threatened about being taken to court? If any of these questions relate to you, this article is designed to help you. You might not need to pay them back!

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Who are Lowell Group Debt Collection?

Lowell Group are a debt management company. The company buys the debts of people who are in arrears from other lenders and organisations and then tries to collect the money that is owed.

These debts are bought for less than the outstanding amount. Lowell Group hopes that its debt collection skills mean that the company can recover the full outstanding amount so they can make a profit.

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Are Lowell Group Debt Collection legit?

Lowell Group are a registered company and most importantly are authorised and regulated by the Financial Conduct Authority (FCA). The FCA have very strict rules, so it’s safe to say that they are legit. They have a legal right, having bought your debt, to collect the money from you.

Man being contacted by Lowell Group

Why are they contacting me?

Lowell Group will be contacting you because they think that you owe money that you have failed to repay.

They buy debts like yours from other organisations, so the money you owe will normally be money that was originally owed to a different organisation.

Who do they collect for?

Lowell collects debt for companies like:

  • Vanquis Credit Cards
  • Capital One
  • O2
  • Littlewoods
  • And others!

How debt collectors can make your life hard

Debt collectors can make your life hard in a number of ways and how they do that will depend on how much you owe and how far behind you are with your repayments.

First, they will contact you on a regular basis and this can be stressful. They may also visit you in person. Second, they can register your failure to make repayments with credit reference agencies, damaging your credit rating. And third, they can take you to court to obtain a CCJ against you.

It can prove almost impossible to get the debt collectors called off. Victims say they have suffered sleepless nights and been afraid to open their doors in case bailiffs turn up.

Man being uncertain and afraid of actions that would be taken by debt collectors

What actions are Lowell Group Debt Collection likely to take?

Initially, Lowell Group is likely to contact you either in writing, by phone or both. They will hope that they can secure repayment of the debt, either via a lump sum or by arranging a payment plan, without having to take further action.

If you fail to respond they may send a debt collector to your home. In extreme cases, you may be taken to court which could mean a CCJ is made against you.

What does the debt collection process look like?

Lowell will try to take payment over the phone if they can get hold of you. Otherwise, you can do it online. First, check out their budget calculator to ensure that your repayment is affordable, it’s no use making a payment only to go into more debt!

Budget Calculator page in Lowell Group Debt

Next check out the payment options page. Here you can enter your Lowell reference number that you likely received over the phone or on the letters that they have been sending you. Make sure you note down the reference number of your payment, so next time they call you you can tell them that you’ve already paid (it may take some time for this payment to be reflected on your account).

Payment options page in Lowell Group Debt

As you can see it’s relatively simple to make a payment providing you have the reference number and card to hand.

Will debt collectors send Bailiffs?

Will Lowell Group send bailiffs?

If you do not respond to their initial attempts to contact you, Lowell Group may send a debt collector to your home but they will not send bailiffs. Debt collectors have very limited powers compared to bailiffs.

If a CCJ is made against you and you do not settle the CCJ or keep up with the monthly instalments agreed by the court, the court may send bailiffs to your home.

Can Lowell Group sell my home?

Lowell Group cannot sell your home. However, if you are taken to court and a CCJ is made against you the court may grant a charging order which means that if you do not settle the CCJ or keep up with the monthly repayments agreed by the
court, you may be forced to sell your home to repay the debt.

Will Lowell Group give me an Attachment of Earnings Order?

An Attachment of Earnings Order means that your debt repayments are taken directly from your wages each payday so you cannot avoid making the payments.

Lowell Group cannot give you an Attachment of Earnings Order. However, if you are taken to court and a CCJ is made against you the court will consider an Attachment of Earnings Order as a method of ensuring that your debt is repaid.

Don't run from your debts!

Can I not reply to Lowell Group?

You can choose not to reply to Lowell Group although if you fail to reply, it is possible that Lowell Group will escalate matters. This could mean that they send a debt collector to your home or it could even mean that you end up in court.

If you agree that you owe the money it may be in your best interest to discuss the debt with Lowell Group. You don’t have to, but Lowell Group will generally be able to come up with a payment plan that makes it easier to repay your debt.

Can I prevent Lowell Group from contacting me?

If you want to prevent Lowell Group from contacting you, you can send them a “cease and desist” letter. Once you have sent this Lowell Group must not make further contact with you.

However, this “cease and desist” letter does not mean that your debt is written off and you will still owe the money. There is nothing to stop Lowell Group from taking you to court to obtain a CCJ against you if you do this.

Check that you owe Lowell Group

You should be able to check that you owe Lowell Group because they will tell you which organisation they have bought the debt from. They will also tell you how much is outstanding. Lowell Group should be able to provide you with a copy of your original credit agreement.

It is important that you check your own records to ensure that no mistakes have been made and that you do owe the amount that Lowell Group is claiming that you owe. You should also check that the amount being claimed by Lowell Group is the amount that you actually owe.

Follow my ‘prove it’ guide with letter templates and get them to prove that you owe the money.

Create a simple Budget

Create a simple budget

Taking 10 minutes to create a budget is time well spent. This will tell you what the maximum that you can afford to pay back with your current income and expenses. You can tell this information to the debt collectors and they can then work with you.

Check out my ‘financial snapshot‘ post to learn how.

Can’t afford to pay Lowell Group?

If you can’t afford to pay Lowell Group the full outstanding amount they will usually be prepared to agree to a payment plan based on your monthly income and expenditure.

Lowell Group may also be prepared to offer a discount in return for a full and final settlement figure. If such an offer is made you should get written confirmation that the debt has been settled once you have paid and no further action will be
taking before you make the payment.

Write off your Lowell Group Debt!

How do I write off my Lowell Group debt?

There are a number of ways of that you can write off your Lowell Group debt and how you do this will depend on your situation.

First, if you can prove that you do not owe the money you can have the debt written off. Alternatively, if you do owe the money you can pay the outstanding amount to settle the debt.

If you cannot repay the debt and will not be able to repay the debt in the foreseeable future, you might need to consider insolvency. This comes in a number of forms, such as Individual Voluntary Arrangements, Debt Relief Orders and bankruptcy.

You only qualify for the government IVA scheme if your debts are over £1,200 and you have more than one debt. Fill out a 30 second form to see if you qualify using my 5 question virtual assessment.

How can I set up a payment plan?

If you are unable to repay your debt in full but but can make monthly repayments, you can usually set up a payment plan. Lowell Group’s online budget calculator works how much money you have left over at the end of each month that can be
used towards debt repayment.

It is important to make sure you include absolutely all of your expenditure rather than just your monthly household bills. This includes the cost of travel to and from work, the cost of replacing clothing, etc.

You can register a payment plan via the portal on the Lowell Group website. Alternatively, you can phone the company to discuss your options.

How can I make a partial payment?

You can make a partial payment over the phone with a debit card, via a payment slip, via bank transfer or by cheque. You can also pay online via the Lowell Group website.

How this partial payment is used will depend on whether your account is in arrears. If your account is in arrears the payment will be used to pay off those arrears. If your account is not in arrears it will be used to reduce your outstanding
balance.

Can I pay with a credit card?

Can I pay with a credit card?

Yes, Lowell Group should accept credit cards online or over the phone. Do this very carefully though. I suggest you read my guide about using a credit card as a loan before you do.

Debt options

What other options are there with Lowell Group?

If you are unable to pay Lowell Group, either in full or via a payment plan, you should discuss your situation with a debt  counsellor who will be able to tell you whether there are better ways of handling your debt and what other options you have.

There are 5 main options that can help you with your debt:

  1. Snowball Method – if you can afford to make the minimum payments on your debt, then this method to become debt-free is almost definitely your best option. The great thing about the snowball method is that it actually improves your credit score, whereas the other options will damage it.
  • Debt Management Plan (DMP) – this solution has you paying less than the minimum every month and the lenders stop charging interest. Ideal for a short period if you have, for example, lost your job.
  • Individual Voluntary Arrangement (IVA) – this solution works well if you owe over £6,000 and need to protect your house from being repossessed.
  • Debt Relief Order – is suitable if you have debts of less thank £20,000, have barely any income and don’t have a house.
  • Bankruptcy – is for many people the fastest way to way to hit the reset button. Don’t be put off, there’s a lot of stigma around the word ‘bankruptcy’, however, it could be the right thing for you to do.

See my debt options overview page outlining all your possible debt options and pros and cons of each.

Man worried to call Debt collectors

I’m too shy to call Lowell Group

You shouldn’t worry about being too shy to call Lowell Group because the company deals with over 700,000 people in your situation each year and will know exactly how you are feeling.

However, if you really don’t want to call Lowell Group you can also email or send letters to the company.

Lowell Group Debt Collection Reviews

Rating:

3 out of 5 stars (3 / 5)

We’ve awarded Lowell Group Debt Collection a generous 3/5. Whilst there are lots of negative reports, we put this down to disgruntled customers who have to pay money back. Lowell Group actually has a fair amount of positive reviews saying that they were handled fairly.

Trustpilot scores the Lowell Group at 2.4/10. This score is largely skewed by 84% 1 star reviews. Here’s some of the bad ones:

“After closing my account with O2, these guys claimed I owed £12 which were not the case. I sent them evidence that there’s no debt, and it seemed to be sorted. Two months later though it appeared as a default on my credit score, and I did not even know. Until now, almost two years later when I see it on my Noddle credit rating report.”

“They are calling my mobile phone house phone 3 to 4 times a day I have had to change my number on my mobile phone with all my friends family had now having to up date the new number I give them”

However like we said before, there are quite a few positive reviews. 11% – this is high for a debt collection agency, which either means that they’re better than most, or they’re faking their reviews?! Anyhow, here’s a sample:

“Excellent customer services very understanding wiling to listen and very helpful excellent supervisiers good customer really helped my situation and would recommend to talk them explaining your situation and they will help you that’s why I’ve give them 5stars please talk to them do not Bury your heads in the sands”

“Look, – Lowell are just doing their job. They will have to ask you for name, DOB etc. before they can discuss anything. Ok, now on to us. We have had financial fraud (credit cards opened in our names). Lowell bought some of these debts. They then listened to us very carefully and we sent all the evidence we could to them. I know they pay peanuts to buy debts from Banks but they listened to us and then threw out all claims against us.

I would suggest your first point of action is to cool down and be polite with Lowell. They are not bandits, – they buy outstanding debts from companies and banks. Don’t ignore them and make yourself appear guilty! Supply them in writing and by phone all your evidence.

It’s really the Banks, Utility Companies etc that Lowell actually BUY debts off that are idiots. Hope this is useful to you. PS: If you really do owe money they’ll sort out a payment plan to suit you.”

How do I make a complaint about Lowell Group Debt Collection

If you want to make a complaint about Lowell Group the first thing you should do is to contact the company to see whether they can resolve it to your satisfaction.

If the matter is not resolved to your satisfaction you can escalate your complaint by speaking to the ombudsman. How you do that will depend on what type of debt is involved because there are two to different ombudsmen and each deals with different types of debt.

The Lowell Group complaints procedure is detailed on their website.

Lowell Group Contact Details

Website: www.lowell.co.uk 

Phone number: 0333 556 5701

Email address: post@lowellgroup.co.uk

Postal address: PO Box 1411, Northampton, NN2 1BQ

Monday – Thursday: 8:00 am – 8:00 pm
Friday: 8:00 am – 7:00 pm
Saturday: 9:00 am – 2:00 pm

Lowell Group FAQs

Who owns Lowell Group?

Lowell Group is a privately owned limited company. It was bought by International private equity firm Permira in 2015 and is independent. It is not owned by a specific lender.

Are Lowell Group regulated by the FCA?

Lowell Financial Limited – the company that manages the debts – is regulated by the FCA. Its registration number is 730175.
Lowell Portfolio I Limited – the company that owns the debts – is also regulated by the FCA. Its registration number is 730071.

Do the HMRC use Lowell Group?

HMRC does use debt collection agencies to collect unpaid tax but they do not currently use Lowell Group for this.

Does Lowell Group buy other companies debt?

Yes, Lowell Group buys other companies’ debts. It does this at less face value and makes its money when it collects the face value of the debts.

What happens if you don’t reply to Lowell Group’s letters?

If you don’t reply to Lowell Group’s letters what happens next well depend on a number of factors. They may send a debt collector to your home and may even take you to court to obtain a CCJ against you.

Can Lowell Group give me a County Court Judgement?

Lowell Group cannot give you a County Court Judgement but they can apply to the court to ask the court to grant one.

Can you be arrested for debt?

No, you cannot be arrested for debt other than in a very small number of specific circumstances. The debts that Lowell Group handle do not qualify so it is not possible for you to be arrested if you do not pay Lowell Group.

What happens if I ignore a CCJ letter from Lowell Group?

There are two types of CCJ letter. The first is a County Court claim form and if you ignore this the court will decide whether you owe the money in your absence. If it decides that you do, it will grant a CCJ against you. The second is the County Court Judgement. This confirms that the court has decided that you owe the money. If you ignore this letter, it could result in court bailiffs visiting your home.

Can Lowell Group issue a warrant?

Lowell Group cannot issue a warrant. However, the court may issue a warrant if a CCJ has been made against you.

Can Lowell Group issue a warrant?

Lowell Group cannot issue a warrant. However, the court may issue a warrant if a CCJ has been made against you.

Are Lowell Group bailiffs?

Lowell Group are debt collectors, not bailiffs. This means that they do not have the same powers as bailiffs.

Can Lowell Group come to your home?

Lowell Group can come to your home but you do not have to let them in. In fact, you are not even obliged to answer the door to them.

Can Lowell Group force themselves into your home?

Lowell Group cannot force themselves into your home. They can only enter your home if you invite them in and you do not need to do so.

Will Lowell Group give in?

In principle, Lowell Group will never give in. If you do not repay your debt, a record of your non-payment will remain on your credit history. In practice it is not economically viable for them to continue to chase small debts.

If it is obvious that you are unwilling or unable to repay a small debt they may stop pestering you after a while. However, if the debt is a large debt they will be more determined to ensure that the debt is repaid. This could involve taking you to court in an attempt to obtain a CCJ against you.

Will a debt ever be too old to collect?

Provided a CCJ has not been already made against you, a creditor can usually only take legal action in an attempt to recover a debt if it does so within six years of you last acknowledging the debt exists. This period is only five years in Scotland.

You can acknowledge a debt either by making a payment or by replying to correspondence about the debt. If you do that during the six (or five) year period, the clock is reset and the period starts running again.
After this time has elapsed, the debt becomes statute barred. This means that although you still owe the money, the debt will be too old for your creditor to collect.

How long can Lowell Group legally chase me for debt?

Within reason, Lowell Group can legally chase you for a debt for as long as they want provided they keep in regular contact with you. However, once a debt has become statute barred they cannot enforce that debt via legal action. You only have to repay it if you choose to repay it voluntarily.

Do Lowell Group write off debts?

Lowell Group do not write off debts, but they may consider a full and final settlement figure that is less that the amount owed. You should get written confirmation that the company will take no further action against you before paying the full and final settlement amount. Of course, if you go down the insolvency route they may have to write off some or all of the debt.

What’s the best way to contact Lowell Group?

You can contact Lowell Group by phone or email. Their contact centre is open from 8am to 8pm on weekdays and 8am to 2pm on Saturdays.

If you just want a general chat to discuss your options, the best way to contact Lowell Group is by phone. However, the advantage of contacting Lowell Group via email is that email gives you a record of what was said in case you need to refer back to that at a later date.

How do I make a Lowell Group payment?

You can make payments to Lowell Group in a number of ways and how you make the payment will depend whether you are making a one-off payment or regular payments as part of a payment plan.

For one-off payments, you can pay over the phone with a debit card, via a payment slip, via bank transfer or by cheque. You can also pay online via the Lowell Group website. Regular payments can also be made via direct debit or standing order.

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The Data Protection Act 1998 requires every data controller who is processing personal data to notify the Information Commissioner of any breaches no more than 72 hours after becoming aware of it unless they are exempt from doing so. Failure to notify is a criminal offence.  In addition, any FCA regulated firm must notify the FCA – ideally within 24hrs of discovery of a breach.

This document should be read in conjunction with our Acceptable Use policy and Information Security policy which form part of the Employee’s Handbook.  We are committed to protecting and respecting privacy.

This policy sets out the basis on which any personal data we collect from a consumer will be processed by us.

For the purpose of the Data Protection Act 1998 (“the Act”), the data controller is Nerd FS.

By visiting and using our website the consumer is consenting to the practices set out below.

If our firm needs to collect data for any purpose not stated above we should notify the Information Commissioner before collecting that data.

Whenever collecting information about people, our firm agrees to apply the Eight Data Protection Principles:

  1. Personal data should be processed fairly and lawfully
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  3. Data should be adequate, relevant and not excessive for the purposes required
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 Duties

The same principles apply to when data is taken out of the office

Working at home

The use of data for marketing purposes

For marketing purposes, there are two types of data:

Data obtained in-house

Data obtained from third parties

Security Statement

We have taken measures to guard against unauthorised or unlawful processing of personal data and against accidental loss, destruction or damage.

This includes:

Customers Right to Withdraw Consent

The customer has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before it’s withdrawal. However, it does mean you can no longer rely on consent as your lawful basis for processing. They withdraw consent by either of the following; putting this in writing to address details, by calling telephone number or emailing email address.

As the right to withdraw is ‘at any time’, it’s not enough to provide an opt-out only by reply. The individual must be able to opt out at any time they choose, on their own initiative.

In some cases you may need to keep a record of the withdrawal of consent for your own purposes – for example, to maintain suppression records so that you can comply with direct marketing rules. You don’t need consent for this, as long as you tell individuals that you will keep these records, why you need them, and your lawful basis for this processing (eg legal obligation or legitimate interests).

Subject Access Request (SAR)

One of the main rights which the Data Protection Act gives to individuals is the right of access to their personal information.  An individual is permitted to send us a subject access request (“SAR”) requiring that we tell them about the personal information we hold about them, and to provide them with a copy of that information.  In most cases we must respond to a valid subject access request within 40 calendar days of receipt.  Any business is able to charge a customer a reasonable charge of £10 for providing this data however it is not our companies policy to do so unless the request is excessive or unwarranted.  Any Subject Access Requests must be sent to a Senior Manager for processing purposes.

Third party requests are also permitted e.g. a friend or relative, a solicitor, a claims management company or other third party. Under the Data Protection Act 1998 and the Data Protection Principles, are not permitted to reveal such information to a third party without the authority of a customer. On this basis, for any third party SAR, we will ensure that we have a written record of authority held on file before we release any personal data.

Where there are two or more customers linked to one credit agreement and the request comes from one of these parties, we will provide the response to both parties

We are required to 'give' a copy of the executed agreement and any other document referred to in it and the required statement. In the FCA’s view, sending a copy of them by ordinary second class post will suffice. Guidance on what constitutes a ‘copy’ can be found in the case of Carey v HSBC Bank plc [2009] EWHC 3417 (QB).

The duty under the relevant section does not apply if no sum is, or will or may become, payable by customer under the agreement. This is irrespective of whether the agreement may have already been terminated.

We will promptly facilitate a SAR request, although we have up to 40 days to do so.  All staff are made aware of this during induction.  Refresher training will be provided on a regular basis.  Although the rules permit the Firm to charge a maximum of £10 for responding to the request for personal data, it is not the Firm’s own policy to do so.

Client consent to the application of the Act and their right to access to their records are included within the firm’s terms of business/client agreement.

Any data collected must not be excessive and must be relevant to the purpose and it must not be kept longer than is necessary.

Information Commissioner’s Office (ICO)

The ICO has the power to issue monetary penalty notices of up to £500,000 for serious breaches of the Data Protection Act occurring on or after 6 April 2010, and serious breaches of the Privacy and Electronic Communications Regulations.

Privacy

Our Privacy policy is in full view on our website.  This section must be read in conjunction with the Privacy Policy.

It is the responsibility of the senior management of our firm to ensure this policy is effective through monitoring and complaints procedures.

All employees, affiliates and ARs dealing with customers have a responsibility to read, understand and implement this policy and to hold their own valid and appropriate Privacy policy where appropriate.

The Firm holds a valid Data Protection license and it is bound by the rules of the Data Protection Act 1998.  The full extent of the rules can be found at www.dataprotection.gov.uk.

The 8 principles that the 1984 Act introduced are as follows.  Data must be:

Criminal offences

A criminal offence is committed by the Firm or an individual member of staff if they knowingly or recklessly:

Uses of customer information

When submitting application forms to banks, insurance companies and other financial institutions, this means that personal data will, by default, also be submitted.  In these cases, clients will be informed that their personal data may be used.

The Firm will request client consent before any transfer of data takes place.  Clients will be asked to confirm that they are comfortable to have their personal data used in one or more of the following forms:

Post, telephone, email etc. subject to the conditions of the Data Protection Act.

Information Classification

 Definitions

The following definitions provide a summary of the information classification levels that have been adopted by our firm and which underpin the 8 principles of information security. These classification levels explicitly incorporate the Data Protection Act’s (“DPA”) definitions of Personal Data and Sensitive Personal Data, as laid out in our firm’s Data Protection Policy.

‘Confidential’ information has significant value for our firm, and unauthorised disclosure or dissemination could result in severe financial or reputational damage to us as an FCA authorised firm, including fines of up to £500,000 from the Information Commissioner’s Office.

Data that is defined by the Data Protection Act as Sensitive Personal Data falls into this category. Only those who explicitly need access must be granted it, and only to the least degree in order to do their work (the ‘need to know’ and ‘least privilege’ principles).  When held outside our firm, on mobile devices such as laptops, tablets or phones, or in transit, ‘Confidential’ information must be protected behind an explicit logon and encryption at the device, drive or file level.

‘Restricted’ information is subject to controls on access, such as only allowing valid logons from a small group of staff. ‘Restricted’ information must be held in such a manner that prevents unauthorised access i.e. on a system that requires a valid and appropriate user to log in before access is granted. Information defined as Personal Data by the Data Protection Act falls into this category. Disclosure or dissemination of this information is not intended, and may incur some negative publicity, but is unlikely to cause severe financial or reputational damage to our firm.  Note that under the Data Protection Act large datasets (>1000 records) of ‘Restricted’ information may become classified as Confidential, thereby requiring a higher level of access control.

‘Internal use’ information can be disclosed or disseminated by its owner to appropriate members of our firm, partners and other individuals, as appropriate by information owners without any restrictions on content or time of publication.

‘Public’ information can be disclosed or disseminated without any restrictions on content, audience or time of publication. Disclosure or dissemination of the information must not violate any applicable laws or regulations, such as privacy rules.  Modification must be restricted to individuals who have been explicitly approved by information owners to modify that information, and who have successfully authenticated themselves to the appropriate computer system.

Designating information as ‘Confidential’ involves significant costs in terms of implementation, hardware and ongoing resources, and makes data less mobile. For this reason, information owners making classification decisions must balance the risk of damage that could result from unauthorised access to, or disclosure of, the information against the cost of additional hardware, software or services required to protect it.

Examples

Security Level

Definitions

Examples

FOIA2000 / DPA1998 status

1. Confidential

Normally accessible only to specified and/or relevant members of our staff

DPA-defined Sensitive personal data:

·                     racial/ethnic origin

·                     political opinion

·                     religious beliefs

·                     trade union membership

·                     physical/mental health condition

·                     sexual life

·                     criminal record

·                     salary information

·                     individuals’ bank details

·                     passwords

·                     large aggregates of DPA-defined Personal Data (>1000 records) including elements such as name, address, telephone number.

·                     HR system data

Subject to significant scrutiny in relation to appropriate exemptions/ public interest and legal considerations.

2. Restricted

Normally accessible only to specified and/or relevant members of our staff

DPA-defined Personal Data (information that identifies living individuals including:

·                     home / work address

·                     age

·                     telephone number

·                     schools attended

·                     photographs

Subject to significant scrutiny in relation to appropriate exemptions/ public interest and legal considerations.

3. Internal Use

Normally accessible only to our staff

·                     Internal correspondence,

·                     internal group papers and minutes,

·                     information held under license company policy and procedures

Subject to scrutiny in relation to appropriate exemptions/ public interest and legal considerations

4.  Public

Accessible to all members of the public

·                     Company filed documents

·                     Company websites

Freely available on the website.

Explicit Information Ownership and Other Rights of Access to Information

We recommend that departments and functions within our business explicitly designate information owners.

Other users may have rights of access to data according to the terms of engagement under which the data was gained or created.

Granularity of Classification

The sets of information being classified should, in general, be large rather than small. Smaller units require more administrative effort, involve more decisions and add to complexity, thus decreasing the overall security.

 Information Retention

There may be minimum or maximum timescales for which information has to be kept. These may be mandated in a commercial contract. Other forms of information retention may be covered by environmental or financial regulations.

Responsibilities

All ‘Users’ must obtain authorisation from their line manager before their classification request is submitted to Senior Managers. Nerd FS is responsible for assessing information and classifying its sensitivity.

Violations

A violation of our Information Security Policy and supporting policy documents will be investigated and consequentially may result in disciplinary action which could include the termination of employment contract for employees, the termination of contractual relations in the case of third parties, contractors or consultants.

A violation of this policy and misuse of the systems and applications within our firm may also be a breach of the Computer Misuse Act 1990; consequentially the company may at its discretion take legal action against an individual or organisation that is found to be in breach of its policies.

How we may use customer data

 We may as a result of a consumer or a third parties’ interaction with our website/s obtain their personal data and process their information on our computers and in any other way.

By “third parties” we mean any lender, broker or affiliate who interacts with us in enabling a consumer to make a loan application.

We will use the information to manage their account(s), give them statements and provide our services, for research, assessment and analysis (including credit and/or behaviour scoring, market and product analysis) and to develop and improve our services to the consumer and other consumers and protect our interests.

We, and other carefully selected third parties, will use their information to inform them by post, fax, telephone or other electronic means, about other products and services (including those of others) which we believe may be of interest to them.

If they contact us, we may keep a record of that correspondence.

We will keep details of transactions they carry out through our site and of the fulfilment of their applications and their loan history.

We will keep details of their visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.

In order for us to be able to collect and use personal data and / or to pass If they do not want us to use their data in this way, or to pass their details on to third parties for marketing purposes, customers must manually opt in to this agreement (See CONC section of this Compliance Manual).

IP Addresses

 We may collect information about their computer, including where available their IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Cookies

 For the same reason, we may obtain information about a consumer’s general internet usage by using a cookie file which is stored on their browser or the hard drive of their computer. Cookies contain information that is transferred to their computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. Some of the cookies we use are essential for the site to operate.

If they register with us or if they continue to use our site, they agree to our use of cookies.

Please note that our advertisers may also use cookies, over which we have no control.

Cookies can be blocked and a consumer may not be able to access all or parts of our site. Unless a consumer has adjusted their browser setting so that it will refuse cookies, our system will issue cookies as soon they visit our site.

Where we store data

The data that we collect from a consumer is stored within the European Economic Area ("EEA"). Such staff may be engaged in, among other things, the assessment and fulfilment of a consumer’s application, the processing of a consumer’s bank details and the provision of support services. By submitting their personal data, they agree to this transfer, storing or processing.  We will take all steps reasonably necessary to ensure that a consumer’s data is treated securely and in accordance with this privacy policy.

All information a consumer provides to us is stored on our secure servers. Any transactions will be encrypted. Where we have given (or where they have chosen) a password which enables you to access certain parts of our site, they are responsible for keeping this password confidential. We ask a consumer not to share a password with anyone.

The transmission of information via the internet is never completely secure. Although our systems exceed industry standards for security, and we will always do our best to protect a consumer’s personal data, we cannot guarantee the security of a consumer’s data transmitted to our site; any transmission is at their own risk. Once we have received their information, we will use strict procedures and security features to try to prevent unauthorised access.

Disclosure of information

We may disclose a consumer’s personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose a consumer’s personal information to third parties:

Credit Reference Agencies (CRAs)

When a customer makes an application for a credit, we will check whether they are likely to be able to meet the monthly payments and repay the loan.  However, we are limited in what we can actually do as we do not work directly with CRA’s as we are not eligible to do so.  We will work with what the applicant divulges on their fact find/application but we can only judge as accurately as the information given allows.

When we submit an application to a lender, it is normal practice for a lender to carry out a credit search with a CRA.  In the past, this would have left a search ‘footprint’ on the applicants’ credit file that may be seen by other lenders. Large numbers of applications made within a short period of time would adversely affect a customer’s ability to obtain credit, and they should always consider this before making an application for a loan.

However, the lenders that we have chosen to deal with offer a facility known as a ‘quotation’ search, which does not leave a footprint. This is in line with CONC 2.5.7 which suggests that during the ‘shopping around’ process of the customer, the lenders that we promote should only use a ‘quotation search’, which does not leave a footprint.

Access to information

The Act gives a consumer the right to access information held about them. Your right of access can be exercised in accordance with the Act. Any subject access request may be subject to a fee of £10 to meet our costs in providing them with details of the information we hold about them.

Changes to our Privacy Policy

 Any changes we may make to our privacy policy in the future will be posted on our web page, and, if appropriate, notified to consumers by e-mail.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to moneynerduk (at) gmail.com.

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