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Corporate and Social Responsibility Policy

Credit Assist Ltd is committed to operating its business in a manner that is both sensitive and responsible with proper regard to its legal obligations and according to relevant directives, regulations and codes of practice. It is also committed to supporting the Government's vision for Corporate Social Responsibility, specifically:


  • Promoting business activity that brings simultaneous economic, social and environmental benefits.

  • Encouraging innovative approaches and continuing development and application of best practices.

  • Ensuring the best minimum levels of performance in areas such as health & safety, the environment and equal opportunities.

  • Creating a framework that facilitates business practices that balance profit and success with the achievement of social and sustainability goals.

  • Taking an active part in supporting the local community and social causes.

Commitment to Corporate Social Responsibility

Credit Assist recognises that its operations have an effect on the communities and environment in which it operates. In light of this, Credit Assist is committed to operating in a socially responsible manner, supporting a number of local communities and social / charitable causes, as well as running its operation in an environmentally sustainable manner.

Local Community & Social Responsibilities

Credit Assist is proud to support local community projects as well as a range of deserving and charitable causes.

Our Work Colleagues

We are committed to ensuring that we provide a motivational, fulfilling and fun environment in which to work. We focus hard on recruiting and retaining the best people, recognising their achievements and rewarding their efforts.

We believe that much of our success can be attributed to the values that we hold and that are embedded throughout the organisation.  Credit Assist's core values are as follows:


  • To provide a first class, professional service to our clients and our prospects.

  • To be courteous, honest and behave with integrity at all times.

  • Always act wholeheartedly in the best interests of Credit Assist.

  • Have pace, ambition and teamwork as core principles.

  • Treat each other equally and with respect and dignity.

Actions that we take to ensure that our colleagues remain motivated, fulfilled, rewarded and happy at Credit Assist include the following:


  • We formally appraise all colleagues annually, with periodic informal reviews.

  • We hold regular monthly meetings at which we appraise all team members with regards to development, results and plans.

  • We hold at least one company off site "Sharing the Vision" meeting each year, at which we spend half a day sharing results, developments and strategy with all colleagues.

  • We share and celebrate success with financial rewards for non-sales team colleagues who generate business opportunities.

  • We recognise and reward inspirational service by colleagues.

Whilst Credit Assist does not produce any emissions or pollutants that come under the Integrated Pollution Prevention and Control Regulations issued by DEFRA. Credit Assist has identified that it's most significant impacts on the environment include the disposal & recycling of waste (including paper, consumables and electronic  equipment), energy & water usage, transport and car usage, purchase of consumables.

Methods for meeting the objectives within the Environmental Management Programme include:


  • Maximising the reuse, recycling and sustainable disposal of waste.

  • All waste paper, cardboard and plastics are recycled.

  • Minimising unnecessary energy usage and waste.

  • Minimising the impact of car usage.

  • Purchasing consumables in an environmentally sustainable and fair manner.

  • Minimising unnecessary water usage and waste.

We have in place a full environmental policy which details how these impacts will be monitored, managed and wherever possible, reduced.

Equal Opportunities

It is Credit Assist's aim to create an environment that encourages and values diversity within its workforce and builds on the differences individuals bring, enabling Credit Assist's continued success. We aim to draw upon the widest possible range of views and experiences in order to meet the changing needs of our colleagues, clients and partners.

We seek to promote diversity and to respond to the needs of all individuals in a fair and equitable manner, whilst observing our commitment and responsibility to current legislation.

To achieve this, Credit Assist will:


  • Fulfill its social responsibility towards its colleagues, temporary workers and the communities in which it operates.

  • Recognise all of its legal obligations.

  • Make all opportunities (including advertising, interview and selection processes, promotion and training) as accessible as possible to under-represented and protected characteristic groups.

  • Endeavour to attain a workforce that is representative of the communities from which it is drawn to secure the widest pool of talent possible.

  • Recruit, train and promote the best person for the job, to make full use of the talents and resources of all our colleagues.

  • Create a working environment free from unlawful discrimination, victimisation and harassment in which all colleagues are treated with dignity and respect.

  • Periodically review its selection criteria and procedures to ensure that they remain compliant and maintain a system that ensures fairness.

  • Ensure that its Equality & Diversity Policy is circulated to all Credit Assist colleagues, temporary workers, clients, partners, visitors to Credit Assist, and elsewhere as appropriate.

  • Provide the facilities and opportunity for any colleague who believes that they have been treated inequitably within the scope of this policy to raise the matter through the appropriate grievance or complaints procedure.

  • Log all reported instances of harassment and take action to mitigate and minimise harassment and victimisation wherever possible.

  • Ensure that colleagues understand that breaches of this policy will not be tolerated and could lead to disciplinary proceedings.

Our approach to equal opportunities applies equally to both our own employees and the way in which our recruitment services are offered to clients and candidates.

Health & Safety

It is Credit Assist's duty to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all colleagues. This requires that regard is paid in particular to:


  • Maintaining healthy and safe premises, as well as a healthy and safe working environment

  • Providing and maintaining safe systems at work

  • Providing health and safety information and training

  • Publishing and regularly updating a Company Safety Policy

  • Ensuring safety in the use of articles and substances

  • Conducting special risk assessments for expectant, new mothers and young persons

  • Providing such information, training, instruction and supervision as is necessary to  ensure the health and safety at work of all employees

  • Ensuring that home based colleagues' health and safety is of equal importance as office based colleague

Publishing our H&S manual with contents covering at least the following areas:


  • Health & Safety Policy Statement

  • Health & Safety Rules

  • Accident Recording and Reporting

  • Communication and Consultation

  • Contractors

  • Disabled Workers

  • Display Screen Equipment (DSE) or Visual Display Units (VDUs)

  • Electricity

  • Fire

  • Fire and Emergency Evacuation

  • Home Working

  • Manual Handling

  • New and Expectant Mothers

  • Personal Protective Equipment

  • Risk Assessment

  • Smoking

  • Stress at Work

  • Training for Health & Safety

Human Rights

Credit Assist is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion.

Credit Assist will ensure that all of its colleagues, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights.

Credit Assist will not enter into any business arrangement with any person, company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation's activities.

Ethical Purchasing & Procurement

Credit Assist is committed to procuring its works, goods and services in an ethically and environmentally sensitive way, yet with proper regard to its commercial obligations, ensuring that suppliers deliver to agreed timescales, quality and cost. Purchasing is undertaken in a manner that encourages competition, and offers fair and objective evaluation of offers from all potential suppliers.

Purchase of goods and services with an annual value in excess of £10,000 excluding VAT will be conducted according to the following principles:

A business case to evidence the need to purchase will be completed.
Research will be conducted to ensure a clear understanding of the risks associated with the purchase of goods and services, and purchasing decisions will include contingency and risk mitigation strategies.
Tendering is based on both quality and cost and is evaluated in a fair, objective, and structured manner that actively encourages competition.
Small local organisations will be encouraged to participate in the procurement process.
We also consider the logistics of delivering goods, to reduce both costs and emissions.
Company colleagues responsible for purchasing will not accept corporate gifts, or any type of solicitation that could be construed as enticement.
Procurement practices will be transparent, auditable and fair.
The procurement process demonstrates that the approach taken to competition is rigorous, balanced and driven by service needs and market intelligence.
As far as possible, we ensure our suppliers are ethical, sensitive to the environment and operate within EU and UK legislation.
Suppliers are able to demonstrate their ability to deliver continuous improvement and cost savings throughout the life of the contract.
We work with our suppliers to procure environmentally responsible products, such as those containing recycled materials or components.
Business transactions will, where possible be conducted electronically.
Whilst there is a limited choice of utility providers available to us, in choosing a supplier we consider environmental sustainability and energy generated via renewable sources.
We subcontract the provision of certain services to Associates. They agree to provide those services to our clients on behalf of and in our name. Whilst many of the above policies apply, supplier choice will be limited to those:


  • possessing the skills and competence to perform the Services to a sufficiently high standard
  • based within reasonable proximity of the client

Modern Slavery Policy

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time.


Responsibility for the policy

Management at all levels has responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Management at all levels have day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given any required training.


Compliance

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue of suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your Manager or report it in accordance with our Whistleblowing Policy as soon as possible.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitutes any of the various forms of modern slavery, raise it with your Manager.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.


Communication and awareness

Training on this policy, and on the risk our business faces from modern slavery in its supply chain will be given where needed.

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.


Policy breaches

Any employee who breaches this policy may face disciplinary action, up to and including dismissal.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Review

This policy will be reviewed regularly and may be altered from time to time in light of Legislative changes or other prevailing circumstances.

For more information or assistance please email our helpdesk or telephone 01604 217333.

Privacy Notice

Introduction

Welcome to Credit Assist Limited's privacy notice.

Credit Assist Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data which you provide to us when you enter into a contract with us to purchase a product or service (whether on behalf of an organisation or personally), make payment to us, make an enquiry to us, visit our website at www.creditassist.co.uk (regardless of where you visit it from) or otherwise. This privacy notice will also tell you about your privacy rights and how the law protects you.

Whenever you give us personal data, you are consenting to its collection and use in accordance with this privacy notice, including our use of cookies. If you give us personal data on behalf of someone else, you are confirming that you have given them the information in this privacy notice and that they have agreed for us to use their personal data in the way we describe in this privacy notice.

Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.


1.    Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Credit Assist Limited collects and processes your personal data which you provide to us when you enter into a contract with us to purchase a product or service (whether on behalf of an organisation or personally), make payment to us, make an enquiry to us, visit our website (regardless of where you visit it from) or otherwise.

We do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Credit Assist Limited is the controller and is responsible for your personal data (collectively referred to as the "Company", "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Credit Assist Limited - for the attention of the data privacy manager

York Studios, Cold Ashby Road, Guilsborough, Northamptonshire, NN6 8QP

helpdesk@creditassist.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in March 2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links on our website

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.


2.    The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and systems.

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

  • Usage Data includes information about how you use our website, products and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our website. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


3.     How is your personal data collected

We may use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;

  • create an account with us (on our website or otherwise);

  • subscribe to our service or publications;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey; or

  • give us some feedback.

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.

We may also record phone conversations we have with you.


4.    How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order/instructions including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)us)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communicationss
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communicationss
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers and other information (such as in respect of events we may run or news updates we may provide) may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have opted-in to receive that marketing and have not subsequently opted out of receiving that marketing.

Third-party marketing

We will also get your express opt-in consent before we share your personal data with any company outside the Company (or our group) for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Cookies

Me may use cookies to monitor how people use our website. This helps us to understand how our customers and potential customers use our website so we can improve things like layout, function and design.

A cookie is a piece of information stored on your computer's hard drive that records how you have used a website. The next time you visit that website, it can tailor your options based on the information it has stored about your last visit.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


5.    Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.


  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We would not allow any third-party service providers to us to use your personal data for their own purposes and would only permit them to process your personal data for specified purposes and in accordance with our instructions.


6.    International transfers

We do not knowingly transfer your personal data outside the European Economic Area ("EEA"). However, some External Third Parties may run their operations outside of the EEA. Although they may not be subject to the same data protection laws as organisations based in the UK, we will take steps to make sure they provide an adequate level of protection in accordance with UK data protection law. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside of the EEA.

7.    Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


8.    Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available from us by request. Please be aware that, by law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data. Please see below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


9.    Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are explained in the Glossary.

If you wish to exercise any of these rights, please contact us.  

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


10.  Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or an organisation you represent are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Company's group, acting as joint controllers or processors.

External Third Parties include:

  • Service providers acting as processors who provide IT and system administration services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, marketing advisers, human resources advisers and insurers who provide consultancy, banking, legal, marketing, human resources, insurance and accounting services.

  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:


Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Complaints

All complaints or concerns and appropriate resolution relating to the practices of handling personal information will be logged. Any complaints of this nature should be made to helpdesk@creditassist.co.uk

You also have the right to lodge a complaint with a supervisory authority.

Credit Assist Cookie Policy

CREDIT ASSIST is committed to protecting your personal information and ensuring your experience with us is as safe and as enjoyable as possible. In this section, you'll find information on how and why we use "cookies" to improve our service and your web experience. You'll also find out how to manage the information that is collected.

What Are Cookies?

Most websites, including CREDIT ASSIST, use cookies to improve your browsing experience. Cookies are small amounts of information in the form of text files sent by our website (or the website of a company we have a relationship with) to your computer, mobile phone or other device when you visit our website. They allow us to do various things, including tailor the content you see, and ensure the security of your online experience. Cookies cannot be used to run programs or deliver viruses to your computer.

Cookie Types and Their Uses

CREDIT ASSIST uses a combination of different cookies to improve your on-line experience. For example, CREDIT ASSIST uses cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalised content.


Session Cookies

Session cookies only last for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality. Most of the cookies CREDIT ASSIST uses are session cookies. They keep you signed into CREDIT ASSIST while you move between pages and service your account.

Persistent Cookies

CREDIT ASSIST also uses persistent cookies. These cookies last beyond your session and remain after you have closed your browser. Persistent cookies will remain on your computer until you choose to remove them.

CREDIT ASSIST uses persistent cookies in a few ways, such as to remember your username for sign in so you don't have to re-enter the information on every visit.

First and Third Party Cookies

You may have seen references on other websites to "first party cookies" and "third party cookies." Determining whether or not a cookie is a first or third party cookie depends on which website sets the cookie on your device. First party cookies are set by, or on behalf of, the company whose website you visit. Cookies set by any other company are third party cookies. For example, third party cookies may be used by advertising companies to serve ads when you visit their website. CREDIT ASSIST uses first and third party cookies.

For new visitors, we use first party cookies or Web beacons to collect limited data, such as the date, time, and areas of our website that are visited, as well as the website from which the new visitor came. We may use IP addresses to derive certain other information concerning businesses visiting our websites as described in this policy, but we do not analyse this information in a way which would reveal the identity of the individual browsing our websites. When you select one of our products or services, register for a newsletter or e-mail alert, fill out an online form, or complete a survey, we may try to identify your browser and we may combine information from cookies, Web beacons, and other information collected online with other data that we maintain about you. By improving the features, marketing, and content of our website and by making your online experience more convenient and meaningful, we are able to better serve our customers' needs.

What If I Don't Want to Accept Cookies?

You can choose to restrict or block access to cookies set by CREDIT ASSIST or any other company. You can set your browser to notify you when a web server attempts to write a cookie to your computer. This gives you a chance to accept or reject the cookie. You can control whether or not these cookies are used, but preventing them may mean you will be unable to log in to certain CREDIT ASSIST websites.

How Can I Control Cookies?

Managing Cookies

If you don't want to receive cookies from the CREDIT ASSIST website, you can opt out of them when given the consent option.

Web Browser Cookies

If you don't want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set.

If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings. The Help function within your browser should tell you how. Alternatively, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers. You'll also find details on how to delete cookies from your computer, as well as more general information about cookies.

Most CREDIT ASSIST websites do work without cookies, but you will lose some features and functionality if you choose to disable cookies. Occasionally some CREDIT ASSIST websites will be completely unable to function without cookies being enabled.

If you permit us to use cookies, we will also use a cookie to remember your cookie preference. But if the time comes when you delete all your cookies, such as in your browser preference, then you will need to update your preferences at that time. You'll also have to consent to cookie use again if you log in from a browser or device that has not been used to accept the cookies previously.

For more information or assistance please email our helpdesk or telephone 01604 217333.

Anti-Bribery Policy

Introduction
The Company is committed to the highest standards of ethical conduct and integrity in its business activities and as such, we will not tolerate any form of bribery within our Organisation or directed to any person within our Organisation.

Every employee and individual acting on the organisation's behalf is responsible for maintaining the organisation's reputation and for conducting company business honestly and professionally.

The Bribery Act 2010 came into force on 1st July 2011 which made it a criminal offence to offer, promise or accept a bribe. All employees and associated persons are required to comply with this policy, in accordance with the Bribery Act 2010.

What is a bribe?
A bribe is a financial advantage or other reward that is offered to, given to, or received by an individual or company (whether directly or indirectly) to induce or influence that individual or company to perform public or corporate functions or duties improperly.

Employees and others acting for or on behalf of the organisation are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

As such you should not offer, promise, give, request, agree to receive, or accept any bribes:

  • During the course of employment;
  • When conducting company business; or
  • When representing the organisation in any other capacity.

Procedure for offering or accepting gifts, hospitality etc.
Any gifts, rewards or entertainment received or offered from clients, public officials, suppliers or other business contacts should be reported immediately to your Manager.

In certain circumstances, it may not be appropriate to retain such gifts or be provided with the entertainment and employees and associated persons may be asked to return the gifts to the sender or refuse the entertainment, for example, where there could be a real or perceived conflict of interest. As a general rule, small tokens of appreciation, such as flowers or a bottle of wine, may be retained by employees.

If you wish to provide gifts to suppliers, clients or other business contacts, prior written approval must be obtained from the Manager. These will be authorised only in limited circumstances and must be proportionate, reasonable and made in good faith.

Reporting suspected bribery
You should report any concerns that you may have to the Manager as soon as possible. Issues that should be reported include:

  • any suspected or actual attempts at bribery;
  • concerns that other employees or associated persons may be being bribed; or
  • concerns that other employees or associated persons may be bribing third parties, such as clients or government officials.

In line with our whistle-blowing policy any person who reports instances of bribery or suspected bribery in good faith will be supported by the Company. We will take your concerns seriously and will ensure that you are not subjected to detrimental treatment as a consequence of your report. An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a manager, you should not agree to remain silent.

Action by the company
We will fully investigate any instances of alleged or suspected bribery. Employees suspected of bribery may be suspended from their duties while the investigation is being carried out. The Company will invoke its disciplinary procedures where any employee is suspected of bribery, and proven allegations may result in a finding of gross misconduct and immediate dismissal.

Any instances of detrimental treatment by a fellow employee towards any person who raises their concerns will be treated as a disciplinary offence.

The Company may also report any matter to the relevant authorities, including the Director of Public Prosecutions, Serious Fraud Office, Revenue and Customs Prosecutions Office and the police. The Company will provide all necessary assistance to the relevant authorities in any subsequent prosecution.
Penalties.

A breach of the organisation's anti-bribery policy by an employee will be treated as grounds for disciplinary action, up to and including dismissal.

You should be aware that that bribery is a criminal offence that may result in up to 10 years' imprisonment and/or an unlimited monetary fine for the individual accepting, offering or attempting to cover up a bribe along with an unlimited fine for the organisation.

Records
Accurate, detailed and up-to-date records of all corporate hospitality, entertainment or gifts accepted or offered must be kept.

If you are offered any gift or hospitality, you should report the matter to the Manager. A record of all offers will be kept.

If you offer any gift or hospitality to any person, or organisation, you must first obtain permission from the Manager again the offer must be properly recorded.