Privacy Policy

Last updated: March 2026

Trustdeedscotland.net^® is a trading style of Harper McDermott Ltd (“we”, “us”, “our”).

We respect your privacy and are committed to protecting your personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, share, and protect your personal data when you contact us, visit our website, or use our services.

1. Who We Are

Data Controller: Harper McDermott Ltd
Trading as: Trust Deed Scotland®
Address: First Floor, The Reel House, Glasgow, G2 1RW
Email: enquiries@trustdeedscotland.net
Phone: 0141 221 0999
Company No: SC464959
ICO Registration No: ZA212015

2. The Information We Collect

We may collect and process the following types of personal information:
• Contact details: name, address, phone number, email, and date of birth.
• Financial information: income, expenditure, debts, and creditor details.
• Identification information: proof of identity or address.
• Technical data: IP address, browser type, device identifiers, cookies, and website usage information.
• Special category data: health or vulnerability information (only where relevant to your financial situation and with your explicit consent).
• Communication data: call recordings, emails, live chat, WhatsApp, SMS, Facebook Messenger, or other correspondence.

We only collect the information we genuinely need to provide and improve our services.

3. How We Collect Your Data

We collect data when you:

• Complete an enquiry form on our website.
• Contact us by phone, email, live chat, WhatsApp, SMS, or Facebook Messenger.
• Engage with us on social media.
• Apply for or enter into a debt solution.
• Interact with our website or respond to our marketing communications.

4. Why We Use Your Data (Lawful Basis for Processing)

Assess your eligibility for debt solutions and provide advice Consent / Contract

Manage and administer your case Contract / Legal obligation

Comply with insolvency and financial-services regulation Legal obligation

Communicate with you by phone, email, SMS, WhatsApp, or Messenger Legitimate interest / Consent

Improve our website, marketing, and customer service Legitimate interest

Send marketing communications (where permitted) Consent / Soft opt-in (PECR)

Maintain security and prevent fraud Legal obligation / Legitimate interest

Where we rely on legitimate interests, we ensure your rights and freedoms are not overridden.

5. Special Category Data

We may process information about your health or other sensitive circumstances only with your explicit consent or where permitted by law (for example, to protect your vital interests).

This data is subject to strict safeguards and limited access.

6. Who We Share Your Information With

We never sell your data.

We only share it with trusted service providers and partners who process information on our behalf, under written contracts and strict confidentiality.

Our key processors include:
• Aryza Group – case-management and debt-solution software provider.
• Blue Telecoms Ltd – telephony and call-centre platform.
• Gilson Gray LLP – solicitors providing legal support where required.
• Number AI (formerly SendBee) – secure integration for WhatsApp Business messaging.
• Teknobu Ltd – analytics and marketing-automation provider, which partners with ClickSend Pty Ltd (clicksend.com) to send SMS messages on our behalf.
• Shepherd Chartered Surveyors – valuation services related to debt solutions.
• Insolvency Practitioners Association (IPA) – professional regulatory and supervisory body maintaining insolvency standards.
• Zapier Inc. – workflow-automation platform used to securely transfer limited data between systems.
• ManyChat Inc. – messaging-automation platform used to respond to customers via Facebook Messenger.
• WP Engine, Inc. – website-hosting provider that securely stores website and form data.
• Cloudflare, Inc. – content-delivery and web-security provider that protects our website and processes limited technical data (e.g., IP addresses).
• Red Mosquito Ltd – IT support and infrastructure provider with limited maintenance access only.
We may also share data with:
• Regulatory bodies – including the Financial Conduct Authority (FCA), the Insolvency Service, the Information Commissioner’s Office (ICO), and the Accountant in Bankruptcy (AiB).
• Marketing agencies – who manage advertising and campaign performance. These agencies do not access or process personal customer data and works only with anonymised or aggregated information for performance and optimisation purposes.

All third parties are bound by confidentiality and data-processing agreements, and your data is shared only where necessary and lawful.

7. International Transfers

We primarily store and process data in the UK.
If data must be transferred outside the UK (for example, to cloud providers in the EEA or US), we ensure adequate safeguards such as the UK Addendum to the EU Standard Contractual Clauses or other recognised mechanisms.

8. How Long We Keep Your Data

• Enquiry data: kept for up to 2 years if no case is opened.
• Active cases: retained for 5 years after closure or as required by law.
• Marketing consent records: retained until you withdraw consent.

After these periods, data is securely deleted or anonymised.

9. Your Rights

You have the right to:

• Access a copy of your data.
• Correct inaccurate or incomplete information.
• Request deletion (“right to be forgotten”).
• Restrict or object to processing.
• Request data portability.
• Withdraw consent at any time.
• Lodge a complaint with the Information Commissioner’s Office (ICO): www.ico.org.uk

To exercise your rights, contact enquiries@trustdeedscotland.net.

10. Cookies and Tracking

Our website uses cookies and similar technologies to make the site work properly, improve functionality, and help us understand how visitors use it.

We use CookieYes to manage cookie consent and maintain an up-to-date list of cookies used on our website. This allows you to view, accept, or reject non-essential cookies at any time.

Essential cookies (such as those storing consent preferences) are always active; analytics and marketing cookies are only used with your consent.

You can manage your preferences or withdraw consent at any time via “Cookie Settings” on our website or by visiting: https://www.trustdeedscotland.net/cookie-policy/

That page lists all current cookies and updates automatically via CookieYes to ensure transparency and compliance.

11. Security of Your Information

We apply appropriate technical and organisational measures to protect your data, including:
• Encryption of data in transit and at rest.
• Controlled access and regular staff training.
• Secure document disposal and auditing.

12. Use of WhatsApp, SMS and Other Communications

We may contact you using WhatsApp Business, SMS, Facebook Messenger, or other secure digital channels to provide updates, respond to your enquiry, or manage your case.

• Number AI (formerly SendBee) delivers WhatsApp Business messages securely and in encrypted form.
• Teknobu Ltd, in partnership with ClickSend Pty Ltd (clicksend.com), sends SMS messages on our behalf.
• ManyChat Inc. helps us manage and automate conversations with customers who contact us via Facebook Messenger.

These tools are used only for legitimate business purposes such as responding to enquiries, managing cases, or sending permitted service or marketing messages.

All communications are processed securely under written data-processing agreements.
You can opt out of WhatsApp, SMS, or Messenger communications at any time by contacting us.

13. Marketing Communications

We may contact you by email, SMS, or WhatsApp about services you have requested or similar services we believe may help you, in line with UK GDPR and PECR.

We will only send marketing where we have your consent or a lawful “soft opt-in.”
You can opt out at any time by:
• Following the unsubscribe link in our messages,
• Visiting https://www.trustdeedscotland.net/stop, or
• Emailing marketing@trustdeedscotland.net.

We process opt-out requests within 72 hours, although you may receive messages already scheduled during that time.

You will still receive essential service or regulatory communications where required by law.

14. Children’s Data

Our services are intended for individuals aged 18 and over.
We do not knowingly collect or process children’s personal data.

15. Data Breaches

We take all personal data breaches seriously.

A data breach means any incident leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

If we become aware of a potential or confirmed breach, we will:

1. Identify and contain the incident.
2. Assess the impact and level of risk to individuals.
3. Record the incident in our internal breach log.
4. Notify the Information Commissioner’s Office (ICO) within 72 hours if required.
5. Inform affected individuals without undue delay if the breach poses a high risk, explaining what happened, what data was involved, and what steps have been taken.
6. Review and improve our systems and staff training to reduce the likelihood of recurrence.
If you believe your data may have been compromised, contact our Data Protection Officer at enquiries@trustdeedscotland.net or call 0141 221 0999.

16. Updates to This Policy

We may update this Privacy Policy from time to time to reflect legal, technical, or operational changes.
The latest version will always be available here with an updated “Last updated” date.

Contact Us
Data Protection Officer
Harper McDermott Ltd
First Floor, The Reel House, Glasgow, G2 1RW
Email: enquiries@trustdeedscotland.net
Phone: 0141 221 0999

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