Introduction

G.C.G  has prepared this privacy policy to inform you of its practices regarding the collection, use and disclosure of personal information about identifiable individuals. We take measures to safeguard the privacy and confidentiality of personal and confidential information. Adherence to strict confidentiality and privacy guidelines as outlined in the Fair Debt Collection Practices Act (FDCPA), the Federal Information Security Management Act (FISMA), the Fair Credit Reporting Act (FCRA) and the various state regulations is the cornerstone of our commitment to protecting the privacy of our employees, clients and their customers.


Scope 

This policy applies to the operations of G.C.G  and its subsidiaries across the U.S. and across all business units. [1] Personal information means any information, recorded in any form, about an identifiable individual. Personal information does not include anonymous or aggregated information. Anonymous or aggregated information is information that cannot be associated with or traced back to an identifiable individual.


Consent

Except where permitted or required by law, G.C.G will endeavor to obtain the consent of each individual and/or company providing personal information to G.C.G for the collection, use or disclosure of such personal information by G.C.G. Corporate responsibility G.C.G is a privately-owned and operated collection agency specializing in providing its clients with various debt collection services. G.C.G’s clients include major financial institutions, retailers, governments and their agencies, telecommunications companies, utilities and other companies that are in the practice of granting credit to their customers. Therefore, G.C.G owes a duty of care to its clients and, by extension, to our clients’ customers. The information to which     is granted access by its clients is of a highly confidential nature, as is the information that is acquired during the conduct of its business activities. For these reasons, G.C.G has developed and applied specific privacy and confidentiality policies in order to manage and safeguard this information.


Our employees’ responsibilities 

Each of our employees is responsible for maintaining the confidentiality of all personal information to which he/she is granted access. When they join G.C.G, employees are informed of their responsibilities with regard to privacy and required to sign a confidentiality agreement binding them to these responsibilities. In addition, all employees are required to review and confirm their understanding of the Fair Debt Collection Practices Act (FDCPA), the Federal Information Security Management Act (FISMA), the Fair Credit Reporting Act (FCRA), applicable state regulations and other regulatory guidelines. G.C.G continually coaches and trains our employees with respect to ongoing compliance and developing issues in the realm of privacy and confidentiality. As a condition of employment, G.C.G employees are required to conform to these policies and procedures.


Privacy principles regarding the collection, use and disclosure activities of G.C.G

• gains access, through its clients, to sensitive information, which is required for G.C.G to provide debt collection services to its clients;

• limits the amount and type of personal information it collects. G.C.G will only collect the information required for its business operations;

• will use information only for the reasons it was collected and will not willfully disclose this information to third parties unless duly authorized to do so or as required by law;

• will store all information in its care in a secured fashion, whether electronically or on paper. G.C.G will restrict access to those employees who specifically and lawfully require the information for the purpose of performing their duties;

• will maintain personal information for as long as G.C.G believes it is necessary to fulfil the purpose for which it was collected and as required by applicable laws. G.C.G will proceed to securely dispose of any information that is no longer of value to G.C.G in the completion of its business activities;

• will take all reasonable steps so that client/customer information is accurately maintained, complete and up to date as is necessary to fulfil the purposes for which this information is to be used;

• will take reasonable measures to protect client/customer information by means of appropriate security safeguards as required by the sensitivity level of the information maintained;

• will not sell any client/customer information;

• will be receptive and open to client concerns regarding our policies and procedures that apply to the management of the client/customer information;

• customers may, upon written request, have access to their personal information maintained by G.C.G. The written request must contain sufficient detail to enable G.C.G, with reasonable effort, to identify the information for which the written request is made;

• customers may challenge G.C.G’s compliance with the privacy policy. At the written request of the customer, we will undertake to investigate and respond in writing to any customer complaint.


In summary  
G.C.G considers privacy and the protection of confidential information to be a cornerstone of its business practices. G.C.G will continue to develop, review and monitor its policies and procedures to ensure compliance with all applicable legislation, customer requirements and general common sense, and commits to treating the individuals whose information has been entrusted to G.C.G with care and dignity.