Privacy notice recovery of council debts

We collect and process your personal information to carry out our official functions as a local authority. The main lawful basis we rely on for this processing is Article 6(1)(e) of the UK GDPR, which allows us to process personal data where it is necessary for the performance of a public task. In this case, that task is the billing, administration, and collection of council debts, such as council tax and business rates, which are essential for funding vital public services.

To manage your account and support you effectively, we, including Liberata UK Limited and our trusted third-party organisations collect, and process the following categories of information:

• Your full name, address, phone number, email address and other contact details.
• Your data of birth.
• Details of your outstanding debt(s) with the council.
• National insurance number.
• Your income and expenditure details, including employment data to help agree on an affordable repayment plan.
• Information about your wider financial circumstances, such as credit activity, county court judgements, or insolvency arrangements to better understand your ability to pay.
• Call recordings for training and quality assurance purposes.

We process your personal information to fulfil our statutory and public duties to recover unpaid sums owed to the council. Income from council tax and other charges are essential for funding vital local public services for our community. If you have a council debt, we are committed to working with you to find a way forward that fits your circumstances.

We use your information for the following purposes:

• To administer the process of recovering outstanding debts across any council services.
• To contact you to discuss your circumstances and agree on an affordable repayment plan.
• To identify and provide you with extra support, such as benefits checkers or referrals to independent debt advice services (with your consent).
• To prevent and detect fraud.
• To ensure the information we hold is accurate and up-to-date through data tracing and enrichment.

To deliver the Debt Assist service, the council works with Liberata UK Limited. Where necessary, we share your information with trusted third-party organisations. These organisations act on our instructions as our processors unless stated otherwise. Your data may be shared with:

• Debt Assist: Liberata UK Limited; our primary partner for delivering the Debt Assist service;
• Data Enrichment and Tracing Services: Ascendant Solutions Ltd and TransUnion International Ltd are used to verify your identity and find up-to-date contact details if we have lost touch with you;
• Payment Processors: AccessPay Limited and Worldpay are used to securely process direct debits and card payments;
• Call Recording: IP Integration Limited is used to record telephone calls for training and quality monitoring purposes;
• Independent Debt Advice: With your express consent, we, including Liberata UK Limited may refer you to The Money and Pensions Service (operating as the Money Adviser Network), which provides free and impartial debt advice. Their delivery partners include Citizens Advice, Money Advice Trust, and others.

Here is how we use your information:

1. Initial Contact and Assessment. The council will securely share details of your outstanding debt with our trusted partner, Liberata UK Limited. Liberata UK Limited will then contact you on our behalf to discuss your financial situation. To help create a sustainable plan, they will invite you to share details about your income and expenditure.
2. Creating an affordable payment plan. Based on the information you provide, Liberata will work with you to agree upon a repayment plan that is affordable and tailored to your individual circumstances. Should your financial situation change at any time, the plan can be reviewed and adjusted accordingly.
3. Access to Additional Support. To further support you, we provide tools such as a benefits checker. This can help you identify any additional financial support you may be entitled to, which can make it easier to manage your payments. With your express consent, we can also refer you to free, independent debt advice services.

It is important to understand that Debt Assist is a supportive service, not an enforcement action. This means:

• It will not instruct enforcement agents or send bailiffs to your property; and
• We will not add enforcement fees to your account.

Your personal information will be retained by Arun District Council only for as long as necessary in line with our statutory obligations and corporate retention schedule. For financial records such as council tax, this is typically six years after the financial year the debt is settled. Although some records may be retained longer where it is required by law. 

Liberata UK Limited will securely destroy any personal data it holds on our behalf three months after the contract for the service ends, unless it is required to be retained longer by law.

You have legal rights in respect of the personal information we collect from you. Please see our main Privacy policy page for further details.

If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance by contacting our Data Protection Officer at data.protection@arun.gov.uk. Alternatively, you can raise any concerns directly to the Information Commissioner's Office at: https://ico.org.uk/concerns/.