Goodwillie & Corcoran is an Enforcement Agency that carries out data processing on behalf of a number of Clients (Local Authorities and Private Landlords).
The Data Controller are the Clients named on communications you have received from us. Your data has been given to us by Clients and has not been obtained from publically available sources although having obtained your data from our Clients, Goodwillie & Corcoran may add to or amend using publically available information and information voluntarily provided to us by data subjects.
Goodwillie & Corcoran is registered with the Information Commissioners Office (Z6321044)
Our Data Protection Officer can be contacted by phoning 020 8466 9111 or emailing email@example.com
Purpose of Processing
The processing of personal data is necessary for our Clients and for Us to fulfil our statutory and contractual obligations to our Clients.
The lawful basis for processing are:
Legal Obligation: (GDPR Article 6c): The processing is necessary to comply with the Law (The Tribunals, Court and Enforcement Act 2007 and the associated Taking Control of Goods Regulations)
Public Task (GDPR Article 6e): Processing is necessary for us to perform tasks in the public interest and to perform official functions on behalf of our Clients e.g. the collection and recovery of taxes, civil penalties and commercial rent arrears and other public funds through the execution of Warrants of Control and debt collection. Both the task and functions have a clear basis in Law e.g. The Tribunals, Court and Enforcement Act 2007.
Legitimate Interest (GDPR Article 6f): Processing is necessary for Goodwillie & Corcoran’s legitimate interests as it is central to the conduct of our business.
Categories of Data Processed
The following information about you is provided by our Clients:
We may also add to this the following:
Data obtained from Credit Bureaux:
Data obtained from the DVLA:
Any Data you supply to us voluntarily and in particular in support of claimed vulnerability:
Data obtained through our use of born worn audio – video and audio recordings of phone calls to our offices.
Who We Share your Data With
We only share your data with our instructing Client and data is not transferred outside the UK.
Data Retention Periods
Body Worn Audio – Video footage: The purpose of retaining footage is to assist in the investigation of complaints. We consider 28 days is a sufficient period to allow for a complaint to be received and footage is normally erased after 28 days. However, if we have reason to believe that a complaint or litigation is likely in a particular case and that it is essential to retain the footage for evidential purposes and to adequately defend any proceedings, we may retain that footage for a longer period.
Audio Recording of Phone Calls: The purpose of retaining audio recordings is to confirm the content of the conversation in the event that a dispute arises. In our view an audio recording is considerably less intrusive that an audio-visual recording and a longer retention period is justified. Accordingly, we may retain audio recordings for one year after we have completed action on a case e.g. the case is paid in full or otherwise returned to the Client.
All other Data: Is retained for 6 years after we have completed action on a case. This is because the Limitations Act 1980 allows civil proceedings to be issued up to 6 years after an event which gave rise to them. Our business is litigious by its very nature and consequently, people who feel aggrieved by our actions may issue proceedings against us and sometimes do years after the event. We can only defend ourselves against such proceedings if we have retained a full and thorough record of our actions.