Your Personal Data – Personal Representatives, Executors and Administrators
Phillips & Cohen Associates (UK), Ltd respects the privacy of visitors to our online sites. Any personal information gathered on this site will be kept strictly confidential, stored securely in compliance with the Data Protection Act 2018 and the General Data Protection Regulations.
Who is Phillips & Cohen Associates (UK), Ltd and why do they need my Data?
Phillips & Cohen Associates (UK), Ltd. (PCA UK) is a ‘Processor’ of the personal data you provided to our client. This means that we are processing your information on behalf of a Data Controller. ‘Processing’ means that we will collect, use, store, access and retrieve some of your personal data that is necessary for us to perform the services to our clients. PCA UK specialises in deceased account management and the reason we are processing your data is to discuss estate matters in your capacity as the Personal Representative, Executor or Administrator. To do this, we may collect contact and payment information to discuss and settle outstanding Estate liabilities.
Unless otherwise agreed with you, we will only collect basic personal data about you (such as your name, home address, telephone numbers, email address and payment information). We will not usually process any special categories of personal information about you (often known as ‘sensitive personal data’) unless you disclose some sensitive information to us and we are expressly authorised by you to record the information.
PCA UK adopts a strict approach to Data Protection and have chosen to publish this Fair Processing Notice to ensure we are clear and transparent on who we are, what data we process and why. The information regarding a Late Account Holder is not covered under the data protection legislation, however we treat all information with the utmost respect and in strict confidence. You should also have been provided a Fair Processing Notice (sometimes called a Privacy Notice) from our client, the Data Controller.
Phillips & Cohen Associates (UK), Ltd is a limited company registration number is 5284353. Registered office: Building 5, Floor 9, Exchange Quay, Manchester, M5 3EF. PCA UK are authorised and regulated by the Financial Conduct Authority, our FCA number is 719200.
Information collected through our website
This website also collects and uses information in aggregate form to track the total number of visitors to our site, the number of visitors to each page of our site, the domain names of our visitors’ Internet service providers, and other such technical information. This is technical information that does not by itself identify a specific individual. No personal information is available in this process. We use this data in our collection efforts.
Third Party Links and Advertisement
As a convenience to our visitors, Phillips & Cohen Associates, Ltd. or Phillips & Cohen Associates (UK), Ltd websites may contain links to a number of sites that we believe offer useful information. The privacy policies and procedures described here do not apply to those sites. We suggest contacting those sites directly for information on their data collection and distribution policies.
We do not use third party advertising companies to provide advertisements or allow third party advertisers to track your browsing.
Sensitive personal data
In addition to the basic data described above, it may also benefit you to notify us of any health condition or disability you have, so that we are aware of these conditions and how they affect you. This will allow us to take any reasonable steps to accommodate specific needs or requirements you have when we contact you. This type of information is known under the law as ‘special category information’ (you may also know this as ‘sensitive personal data’) and we require your explicit consent to process this information.
This kind of information will only be collected from you and used by PCA UK to assist you. The information will only be shared with our Data Controller Client and will only be kept as long as it is required for this purpose, or until such time as you notify us you no longer consent to its processing.
What does PCA do with my data?
All the personal data we hold about you will be processed by our colleagues in the United Kingdom. The purpose of our processing is to contact you to discuss an estate to which you are an appointed representative, Administrator or Executor and, where relevant to take payment to settle the outstanding balances. We will not share your payment information (ie Card number or bank details) unless we are required to do so by law. We will only share your contact information with our client, as the Data Controller, and approved third parties that apply the same levels of information security and privacy as PCA UK. A list of our approved third party suppliers is available below. Please be aware, that your contact information may be stored on a cloud-based system whose servers are located within the European Union.
We take all reasonable steps to ensure that your personal data is processed securely and is adequately protected at all times.
How long does PCA UK keep my Data?
We will generally keep your personal data for a minimum of 6 years, after which time it will be destroyed if it is no longer required for the lawful purpose(s) for which it was obtained. If we have contacted you regarding a residential mortgage account, we will keep your data for a minimum of 12 years.
What are my rights?
Under data protection legislation, you have several rights regarding the use of your personal data. It is important to note that all requests made in relation to your rights will be referred to the Data Controller. As a Data Processor we will assist the Data Controller with any requests that are made as follows:
If at any point you wish to either confirm whether your personal data is being processed and/or wish to access the data we hold on you, you can request to see this information, usually free of charge. As we are a Data Processor, any such requests will be forwarded to the Data Controller and we will assist them in fulfilling this request to you. This means that we will usually provide our client with all of the information we hold, and they will fulfil your information request. The Data Controller may ask you to provide identification to ensure they are only releasing your personal information to you. Unless this is a complex request, the Data Controller will usually provide the information to you within a month.
You are entitled to have data corrected if it is inaccurate or incomplete. Some of our clients allow us to amend the data (for instance an incorrectly spelt name) whereas others insist that we refer all such requests to them. Please be assured we will deal with such requests as efficiently as possible.
Whilst you are entitled to have data deleted if it is no longer needed or there is no longer a legitimate reason for processing, or the data in question has otherwise unlawfully been processed, it is unlikely we will delete your data unless you are not involved with the Estate matters. Please note, if we delete your data, we will have no way of knowing that you are not the correct person to contact if we are provided your details again by a different Data Controller.
You have the right to object to the processing of your personal data (note that this only provides you with the right to raise your objections, not a blanket right to have any and all processing ceased).
You have the right to restrict the processing of your personal data under certain circumstances, including if you have contested its accuracy, or if we are reviewing an objection you have raised in relation to its processing.
How do I complain or enquire about the use of my data?
If you wish to raise a complaint about how we have handled your personal data, including in relation to any of the rights outlined above, you can contact our Data Protection Officer, Howard Enders, at [email protected].uk, and we will review your query and / or investigate your concerns. This will result in a referral to the Data Controller.
If you are not satisfied with our response, or believe we are processing your data unfairly or unlawfully, you can complain to the Information Commissioner’s Office (ICO). You can find further information about the ICO and their complaints procedure here: https://ico.org.uk/concerns/.
Current Operational sub-processors
- Adare Group, Clayton West, Huddersfield, HD8 9QQ – Letter production and printing
- Lexis Nexis Ltd, Lexis House, 30 Farringdon Street, London, EC4A 4HH – GRO database search and tracing activity
- Saica Natur UK Ltd, York Street, Audenshaw, Manchester, M34 5TN – Confidential waste destruction
- Call Credit Information Group Ltd, One Park Late, Leeds, LS3 1 EP – Tracing activities
- Noble Systems, 11 Commerce Way, Westing House, Manchester, M17 1HW – Telephony Servicer
- C&R Software Floor 4, Suite 118, 8 Devonshire Square, London, EC2M 3PL Software Support
- Mimecast, Citypoint, One Ropemaker Street, Moorgate, London, EC2Y 9AW – Email archiving
- Ingenico – Neptunusstraat 41-63, 2132 JA Hoofddorp, The Netherlands, registration number: 34140462 Merchant payment processing
- FINVI –1150 W Kilgore Ave, Muncie, IN 47305 – Estate-Serve provider
- Nasstar Group Ltd – 19-25 Nuffield Road Poole Dorset BH17 0RU – telephony systems and IVR payment solution
- Restore Data Shred – Unit 1, QED Business Park, Purfleet Bypass, Purfleet, RM19 1NA – Confidential waste destruction
- WorldPay – 25 Canada Square, Canary Wharf London E14 5LQ United Kingdom – payment processing
- CapitaPay 360 – 70 Brunswick St, Oldham OL1 1BT– payment processing
- Axess Systems – Denby Hall Business Park, Axess House New Winnings Court DE5 8LE – hardware/software support
- Deptive – Level 17/11-19 Customs Street West, Auckland CBD, Auckland 1010, New Zealand – software support
- Regus (UK) – The Zenith Building, 26 Spring Gardens, Manchester, M2 1AB – disaster recovery services
- Success KPI – 6475 Trillium House Lane, Centreville, Virginia 20120 – speech analytics