This statement aims to deliver information on how Personal Data is collected and processed by LCMS Limited in accordance with the General Data Protection Regulation (GDPR).

1. Who we are:

   LCMS Limited is a limited liability company offering business solutions to it’s clients in all areas relating to debt collection. The registered business address of LCMS Limited is W6B Ladytown Business Park, Newhall, Naas, Co. Kildare. The trading name of the company is Legal & Credit Management Services. Helena McGarr is the Data Protection Officer: Phone number 045 431143, Email address helenamcg@lcms.ie

2. The data we collect and the purpose for which it is collected:

   Data initially transferred to us by Creditors (Our clients)
   LCMS is contracted by public bodies and private companies to collect outstanding monies. Our clients remain the 'Data Controllers' of all personal data shared with LCMS Limited. The personal data we receive from our clients include the contact information and additional information in relation to sums which our clients claim are due to them. That information is stored on our I.T system and updated as collection activity progresses. Our clients can log into our dedicated portal and view all of the information that we hold on debts they have transferred to us for collection.
   The legal basis for processing that data is 'Contract'.

   Data we collect from debtors
   When an LCMS agent makes contact with a debtor, the agent may make a note of what was said in the conversation. That note can be viewed by the data controller. Recordings of telephone conversations may be retained on the I.T system for training and quality purposes. The legal basis for processing that data is 'Legitimate Interest'.

   Data from people who view and interact with our website
   LCMS processes data from people who interact with our website in order to respond to queries received through our ‘Contact Us’ feature and to provide quotations. The legal basis for this processing is 'Legitimate Interest'.

   Data we hold as a Data Controller
   

   LCMS Limited holds data in relation to its employees and service providers and that data is retained, processed and disposed of in a manner which meets statutory requirements. 
   

   The basis for that processing is 'Legal Requirement'.

3. How we use and share your information:

   LCMS uses information to the extent that it is necessary to carry out our lawful business activities. We share all the information that we hold in relation to the debts transferred to us for collection with the creditor/client.  They have a log-in facility to our portal to view their debts and the data we hold on their debtors.

   In the event that a debt is to be pursued by legal means, we share the data that we hold with the legal representatives for the creditor. Similarly, where a client requests that a field-agent be engaged to make contact with the debtor, or visit him/her with a view to collecting the outstanding monies or to negotiate a settlement, we provide the agent with the necessary data. LCMS holds a confidentiality agreement with all third party providers. We do not share debtor information with other third parties.

4. Your rights:

   Under the GDPR you have certain rights to control your information and the manner in which we process it. Those rights include:

   • To access the data – you have the right to request a copy of the personal data that we hold about you, together with other information about our processing of personal data.
   • To rectification – you have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
   • To erasure – you have the right to request for us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
   • To restriction of processing or to object to processing – you have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
   • To data portability  – you have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.

   If we are processing personal data based on your consent, you may withdraw that consent at any time. All requests as above are forwarded to our respected clients and instruction sought in order to process the said requests.

5. Data Security cross border transfers:

   LCMS Limited is certified compliant to the international standard ISO27001 (Information Security Management System) and the requirements of GDPR have been integrated into the system. The system is subject to independent external audits. LCMS is also certified compliant to ISO9001.

   All the data we hold and the back-up of that data are held in the Amazon Centre in Dublin which comes within the scope of it’s ISO27018 certification. Data is not transferred outside the EEA.

6. How long we will hold your data:

   We retain data in accordance with our Data Retention Policy and no longer than is necessary to deliver the services we are contracted to provide.

7. How to make a Subject Access Request:

   If you would like a copy of the personal information we hold about you, kindly write to

   Subject Access Request,
   Data Protection Officer,
   W6B Ladytown Business Park,
   Newhall,
   Naas,
   Co. Kildare, or

   Email at helenamcg@lcms.ie or

   Telephone our office at (045)431143 for further assistance on the process. Verification information shall be required in order to identify the subject of the Subject Access Request.

   If you wish to make a complaint relating to how we handled your personal information, please contact our office at 045 431143 or write to Complaints Department, LCMS Limited, W6B Ladytown Business Park, Newhall, Naas, County Kildare.