How we work

Our business model is built on gaining the fullest possible picture of the individual in debt and then building an appropriate recovery strategy. One size doesn’t fit all.

Our focus on consumer outcome

As with all relationships, we believe that it is critical to build understanding. Only when you know more about a consumer in arrears can you achieve a fair outcome.

The service we provide to the government is founded on the principle of defining the best and most appropriate level of activity based on the debt and the individual’s circumstances. We do this by using data, insight and the best specialist suppliers in the market.

We work closely with government departments to understand their policies and overlay industry best practice and guidelines, such as those of the CSA (Credit Services Association) to ensure that every consumer is treated fairly.

The recoveries strategies and contact approaches we use are defined in advance of the first contact, using as much data and insight as possible to better understand the consumer. We evolve the strategy as we learn more through the recoveries process.

Who we work with

Our services are available to all public bodies in the UK, including local authorities and NHS bodies. We currently work with six key government departments:

  • HM Revenue & Customs;
  • Department for Work and Pensions;
  • Home Office;
  • Driver and Vehicle Licensing Agency;
  • Legal Aid Agency; and
  • Student Loans Company.

How we handle data

Although we don’t work directly with consumers, we do capture and process consumer personal data in order to carry out our service for clients.

We only ever capture and process personal data under clear written instructions from clients and it cannot be used by us for any other purpose. Consumer data passed to us by the government cannot be shared with anyone other than our agreed list of suppliers and where personal data needs to be shared in order to perform the service, the minimum required amount of data only is shared.

In addition to adhering to the Data Protection Act 2018 and GDPR, all of our suppliers are certified to ISO27001, the international standard for information security. This means that the policies, processes and controls which contribute to keeping consumer data secure are subject to independent audit by the British Standards Institute every year.

While we share and apply learnings and insight between our clients (for example, if we have learned a new way to better identify those who are vulnerable), we never share actual data. Each client’s data is segregated and processed in accordance with strict department policies and relevant regulation.

In almost all cases, the personal consumer information that we process remains under the control of our clients (who act as Data Controllers under the Data Protection Act 2018 and GDPR. If you would like to know more about what data we collect and how we use it, please read our Privacy Policy.


How we choose suppliers

We have access to the full market of debt recovery specialists, including debt collection agencies.

Bespoke panels of debt recovery specialists are chosen to work on behalf of each of our clients. They are chosen based on four key criteria:

  1. the quality of their consumer focus and debt collection practices;
  2. the requirements of our client;
  3. the type of debt being collected; and
  4. the supplier’s specialism.

All our suppliers are ISO 27001 certified, and the debt collection agencies we use are regulated by the FCA. They are monitored to high standards and are managed on a day-to-day basis by a dedicated team. They conduct spot checks, call listening, account audits and activity reviews in addition to regular site visits. Debt recovery technology captures data on the activity that is undertaken – for example how many calls are made and at what time of day enabling clear insight into the treatment of consumers.