Template for legal review
Tailor to the operating organisation and hosting setup before launch. The statements below about logging and retention depend on the hosting provider used and must be confirmed.
Who we are
Debt Relief Order (debtrelieforder.org) is an independent educational website about Debt Relief Orders in England and Wales. The data controller for any personal data processed through this site is [LAUNCH BLOCKER: legal name of the data controller], Newcastle upon Tyne. [LAUNCH BLOCKER: ICO registration number, or a statement that registration is not required and why]
We are not the Insolvency Service and are not connected to any government body, creditor or debt advice organisation. Nothing you read here is shared with any of them.
What we collect
This is a static website. Unless you choose to send us something, it collects nothing about you directly:
- We do not set cookies or use similar technologies. See our cookie policy.
- We do not run analytics, advertising or tracking scripts of any kind.
- We do not operate newsletters, comments or user accounts. The only ways to send us personal data are the enquiry form described below and email.
Like almost every website, the server that delivers our pages keeps technical logs. These may record your IP address, the page requested, the date and time, your browser type and the referring page. We do not combine these logs with other data or use them to identify individuals. The site is hosted by [LAUNCH BLOCKER: name of hosting provider or CDN], which retains server logs for [LAUNCH BLOCKER: retention period as stated in the host's documentation]. The host's own privacy notice applies to its processing: [LAUNCH BLOCKER: link to the hosting provider's privacy notice].
The enquiry form
Each page carries an enquiry form. If you complete it, we receive the name, email address, telephone number and type of debt you enter. We also receive whether you have asked for a video call, whether you have agreed to be contacted by text message, and the address of the page you submitted it from. We use this only to respond to your enquiry and talk through your options. We do not use it for marketing and we do not sell it.
The form is processed by Formspree, Inc., a third-party form-handling service. Formspree sends your submission to our inbox at info@debtrelieforder.org and may keep a copy on its own systems under its privacy policy. Formspree is based in the United States, so your data may be transferred outside the UK. Formspree states that it relies on standard contractual safeguards for such transfers. [LAUNCH BLOCKER: confirm the Formspree plan, its submission retention setting and the international transfer safeguard in use, and record them here]
The form includes a hidden anti-spam field that is never shown to people. If it is filled in, the submission is discarded. We keep enquiries only for as long as needed to respond to them: [LAUNCH BLOCKER: enquiry retention period].
The eligibility checker
The DRO eligibility checker asks about your debts, income, assets and circumstances. Your answers are processed entirely within your web browser by a script delivered with the page. Nothing you enter is sent to our server or any third party, stored on our systems or written to your browser's storage. When you close or refresh the page, the answers are gone.
Because of this, we never see your answers and cannot retrieve them for you. The checker creates no record of you, and using it has no effect on any DRO application you may later make.
Third parties
Google Fonts
Our pages load the Inter typeface from Google Fonts. When a page loads, your browser requests the font files from fonts.googleapis.com and fonts.gstatic.com. That request sends your IP address and standard request headers to Google, which may process them under its own privacy policy. We do not control that processing. [LAUNCH BLOCKER: decide whether to self-host the Inter font files, which would remove this third-party request entirely, and update this section accordingly]
Links to other websites
We link to GOV.UK, debt advice charities and other external sites. Once you follow a link, that site's privacy policy applies, not ours. We receive no information about what you do on other sites.
We do not share or sell personal data. Our only data processors are the hosting provider named above and Formspree, which handles the enquiry form.
Legal basis for processing
To the limited extent that server logs amount to personal data, we rely on our legitimate interests under Article 6(1)(f) of the UK General Data Protection Regulation (UK GDPR). Those interests are keeping the site secure, diagnosing faults and preventing abuse. This processing is minimal, expected by visitors to any website, and unlikely to affect your rights or interests. We do no other processing on this basis.
If you contact us by email or through the enquiry form, we process the details you provide in order to reply and discuss your enquiry. We rely on our legitimate interest in responding to enquiries. Where you tick the box agreeing to text-message contact, we rely on your consent, which you can withdraw at any time by emailing us. We keep correspondence only for as long as needed to deal with it: [LAUNCH BLOCKER: correspondence retention period].
Your rights
Under the UK GDPR and the Data Protection Act 2018 you have the right to:
- access the personal data we hold about you;
- rectification of inaccurate data;
- erasure of your data in certain circumstances;
- restriction of processing in certain circumstances;
- object to processing based on legitimate interests; and
- data portability, where processing is automated and based on consent or contract; and
- withdraw consent to text-message contact at any time.
In practice, the data we hold is limited to the hosting provider's technical logs and the enquiries and correspondence you send us. To exercise any right, contact us using the details below. We will respond within one month.
You also have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator, at ico.org.uk. We would welcome the chance to address any concern first, but you do not have to contact us before going to the ICO.
Children
This site is written for adults in England and Wales considering a Debt Relief Order. It is not directed at children and we do not knowingly collect data from anyone under 18. If you believe a child has sent us personal information through the enquiry form or by email, please contact us and we will delete it.
Changes to this policy
We will update this policy if the way the site works changes, for example if analytics, self-hosted fonts or a different form provider are introduced. Any change that affects how your data is handled will be described here, with the date it takes effect, before it comes into force. This policy was last updated on [LAUNCH BLOCKER: effective date of this policy].
Contact
Questions about this policy or requests to exercise your rights can be sent to info@debtrelieforder.org or by post to the address given under "Who we are". [LAUNCH BLOCKER: name a data protection contact or state that none is required]
Sources and further reading
- Information Commissioner's Office, ico.org.uk
- Debt Relief Order, Cookie policy and Terms and conditions