PRIVACY POLICY

Protecting Your Privacy

Ashworth & Ingram Compensation Partners Limited ("we", "us", "our") takes your privacy seriously. This policy explains how we use your personal information when you use our claims management services.

We are registered with the Information Commissioner's Office (ICO) under registration number ZB907311 and authorised by the Financial Conduct Authority (FCA) under firm reference number 1042169.

Our Data Protection Officer is David Gerard.

Contact us about your data:

• •Email: data@ashworthingramcp.co.uk
• •Post: Data Protection Officer, Ashworth & Ingram Compensation Partners Limited, The Old Mill, Kings Mill, Kings Mill Lane, Nutfield, Surrey RH1 5NB

Trading Names

We may contact you using different trading names including Council Repair Claims and Car Finance Commission. Regardless of the name used, Ashworth & Ingram Compensation Partners Limited is responsible for your data and this policy applies.

What Information We Collect

We collect different types of information depending on our relationship with you.

If you are a customer making a claim:

• •Identity: Name, date of birth, nationality, passport or driving licence details
• •Contact: Address, email, phone numbers
• •Property: Your tenancy details, landlord information, evidence of disrepair (photos, reports)
• •Financial: Rent payment history, arrears information
• •Verification: Identity documents, facial images for verification (with your consent)
• •Communications: Call recordings, emails, messages
• •Technical: IP address, device information when you use our website
• •Additional Support Requirements: Information about circumstances that may affect how we support you (only with your consent)

Special category data: We process biometric data (facial images) for identity verification and may record other information (such as health conditions or disabilities) to ensure we support you appropriately. We only process this sensitive information with your explicit consent.

How We Collect Your Information

We collect information:

• •Directly from you via our website, phone calls, and documents you provide
• •From identity verification checks
• •From your landlord or housing association (details from evidence you provide)
• •From credit reference and fraud prevention agencies
• •Automatically when you visit our website (cookies and technical data)

Why We Use Your Information and Our Legal Basis

• •Providing our claims service: Contract with you
• •Verifying your identity: Your consent (for biometric data); legal obligation (for AML checks)
• •Preventing fraud: Our legitimate interest in protecting against fraud
• •Identifying additional support requirements: Your consent and our legitimate interest in supporting you
• •Referring your claim to solicitors: Contract with you
• •Recording calls for quality and compliance: Legal obligation (FCA rules)
• •Handling complaints: Legal obligation
• •Improving our services: Our legitimate interest

We will never sell your personal information.

Identity Verification and Biometric Data

To verify your identity, we use VSiD Verify. This involves uploading your identity document (passport or driving licence) and a facial recognition check to confirm the document belongs to you.

Important information about biometric data:

• •You must give explicit consent before we process biometric data
• •Facial images are stored for a maximum of 90 days, then deleted
• •All biometric processing takes place in the UK
• •A record of your verification (name, email, reference) is kept for 6 years
• •You can request deletion of biometric data at any time
• •VSiD's privacy policy: https://portal.virtualsignature.com/documents/PrivacyPolicy.pdf
• •If you do not wish to use biometric verification, please contact us to discuss alternatives.

Additional Support Information

We may ask about circumstances that could affect how we support you, such as health conditions, disabilities or difficult personal situations. This helps us communicate with you appropriately, provide extra support where needed and meet our regulatory obligations. We only record such information with your verbal consent, and you can ask us to remove it at any time.

Who We Share Your Information With

Solicitor partners: When your claim is ready, we share your file with a regulated solicitor who will progress your case. Currently, this is First Legal Solicitors Limited (SRA: 634939). You will be informed before any transfer, and the solicitor becomes responsible for your data once they accept your case.

Service providers: We use carefully selected companies to help deliver our services:

All providers operate under data processing agreements and are required to protect your information.

Regulators: We may be required to share information with the Financial Conduct Authority, Financial Ombudsman Service, or Information Commissioner's Office.

Legal requirements: We may disclose information where required by law or to protect our legal rights.

International Transfers

Some of our service providers are based outside the UK. When we transfer your data internationally, we ensure it is protected by UK adequacy decisions (for EU/EEA transfers), standard contractual clauses approved by the ICO, and technical security measures including encryption.

How Long We Keep Your Information

• •Successful claims: 6 years after claim concludes
• •Unsuccessful or declined claims: 12 months after our decision
• •Identity verification records: 5 years (up to 10 years for AML purposes)
• •Biometric data (at VSiD): Maximum 90 days
• •Call recordings: Aligned with your claim file
• •Complaints: 3 years
• •Enquiries where no service is provided: 12 months

After these periods, we securely delete or anonymise your information.

Your Rights

Under data protection law, you have the right to:

• •Access – Request a copy of the information we hold about you
• •Correction – Ask us to correct inaccurate information
• •Deletion – Ask us to delete your information (subject to legal requirements)
• •Restriction – Ask us to limit how we use your information
• •Portability – Receive your information in a portable format
• •Object – Object to certain processing, including direct marketing
• •Withdraw consent – Where we rely on your consent, you can withdraw it at any time

To exercise any of these rights, contact our Data Protection Officer using the details above. We will respond within one month.

Cookies

Our website uses cookies to improve your experience and help us understand how visitors use our site.

• •Essential cookies: Required for the website to function
• •Analytics cookies: Help us understand how visitors use our site (Google Analytics)
• •Advertising cookies: Used for marketing purposes (Google Ads)

You can manage your cookie preferences through your browser settings. For more information, visit www.allaboutcookies.org.

Eligibility Assessment

When you submit an enquiry, we carry out initial checks to determine whether we can accept your application. These checks assess whether your circumstances meet the criteria for our service and include automated verification processes.

If your application cannot be accepted, we will let you know. If you would like to understand or discuss this decision, you can contact us at info@councilrepairclaims.co.uk or call 03330 111104.

Telephone Preference Service

If you are registered with the Telephone Preference Service (TPS), by engaging our services you give express consent for us to contact you by telephone and SMS to progress your claim.

Complaints

If you are unhappy with how we have handled your information:

• •Contact us first at complaints@ashworthingramcp.co.uk or write to us at the address above. We will respond within 48 hours.
• •You can also contact the ICO directly: Website: ico.org.uk, Phone: 0303 123 1113, Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

Changes to This Policy

We may update this policy from time to time. The latest version will always be available on our website. We encourage you to check periodically for updates.

Key Contact Details

• •Data Protection Officer: David Gerard
• •Email: data@ashworthingramcp.co.uk
• •Address: Ashworth & Ingram Compensation Partners Limited, The Old Mill, Kings Mill, Kings Mill Lane, Nutfield, Surrey RH1 5NB
• •Phone: Contact details available on our website

Summary of Key Points

• •We only collect information necessary to progress your claim
• •We verify your identity using secure biometric technology (with your consent)
• •We share your information with solicitors to progress your claim
• •We use trusted service providers, some based outside the UK, with appropriate safeguards
• •We keep your information only as long as necessary
• •You have rights over your information – contact us to exercise them