Vulnerable Persons Policy

May 2023

AIM OF THIS POLICY

The aim of this policy is to outline the practice and procedures for staff to contribute to the prevention of detriment to clients who find themselves in vulnerable circumstances.

The policy covers all staff within the firm, and those operating in areas that deal directly with customers.

At the outset we should make it clear that our Specialist Agents are fully trained to identify and support those who are vulnerable. Our Training Programme is ongoing with regular updates provided to all our team.

The way an agent of Countrywide Collection Services Limited deals with a customer who may be vulnerable is likely to vary from one customer to another. How each customer is managed is dependent on the individual’s circumstances and the severity of the vulnerability

In all cases of vulnerability our agents adopt the established principle of Treating Customers Fairly alongside the guidelines relating to Consumer Duty which is the FCA Framework which dictates the level of care regulated firms must provide whilst ensuring they act in the interests of consumers through the full life cycle of the services we offer.

DEFINITION OF VULNERABILITY

The Financial Conduct Authority (FCA) has developed the following definition to guide work in this area:

“A vulnerable consumer to be someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when a firm is not acting with appropriate levels of care.”

Vulnerability occurs in a variety of ways which may be permanent, temporary, or even sporadic, dependent on its nature. In many circumstances the individual may not recognise themselves as ‘vulnerable.’

We recognise that vulnerability may not be simply due to the situation of the consumer but caused or aggravated by the actions or processes of the firms they may deal with.

We recognise that clients who might be considered as being in vulnerable circumstances could include clients with:

Mental capacity deficiencies (including language or communication), including mental illness and dementia.
Stress or subject to financial shock of all types, such as employment concerns, bereavement (or potential bereavement), marital or relationship difficulties.
A physical impairment that may not allow them to engage with automated, or other standard process requirements (such as photographic ID, phone keypad recognition, or internet applications).
Severe and long-term illness (both life-limiting and where recovery is expected).
Little or no financial experience or have no access to mainstream financial services.
Low income.

An existing distressed financial situation.
Responsibilities for others, such as ‘carers’ or acting as power of attorney.
No access to the internet or other digital media.
Poor language skills.
Who is or may need community services due to age, illness or a mental or physical disability.
Who is or unable to take care of his or herself or unable to protect themselves against significant harm or exploitation
A person who may have served and recently been discharged from HM Forces.
A person who is either long-term or has just become unemployed.
A person whose circumstances have changed because of the cost-of-living crisis.
A general vulnerability due to being aged 75 and over or aged 18 years and under.

As a firm we must remain mindful of the potential for enquiry by these clients and the potential for any change of circumstance in respect of existing customers.

IDENTIFICATION OF CLIENTS IN VULNERABLE CIRCUMSTANCES

Vulnerability is broad and may occur at any time. It will usually involve the interplay of characteristics of the individual, their circumstances, and static or transitory status.

We only deal with customers in vulnerable circumstances where we are aware of their needs:

Mental capacity deficiencies – the FCA provides clear guidance on the identification of mental capacity limitation issues in their Handbook.
Stress or financial shock – may be identifiable (facial expression, posture, or stance etc.), but otherwise may be revealed through conversation before and during interview
Physical impairment – may be identified visually, or through interview
Severe and long-term illness – may be identifiable through conversation or through interview
Financial inexperience – may be identified through the fact find process and their credit profile
Low income – may be identified through interview and credit profile
In financial distress – may be identified through interview and credit profile
Carers – may be identified through interview or conversation
Digital exclusion – identifiable through interview or via routes of engagement (or non- engagement) with the firm
Poor language skills – may be audible or identifiable via routes of engagement with firm
Clients aged 75 and over or clients aged 18 years and under – should be offered the opportunity to have a relative or friend accompany the client to a meeting

The nature of the need area to be addressed may also indicate vulnerability. For example, people wanting to arrange:

An equity release product
Right-to-buy
A first-time buyer mortgages
Debt consolidation or further credit
Debt management
The provision of long-term care
Excessive monetary withdrawals from investments

These could be some indicators of vulnerability, but this is not designed as an exhaustive list. In the circumstances that apply to our firm we will apply additional safeguards, as appropriate, to ensure fair treatment. This will apply to each individual but where we identify groups of the same people, we may establish a process aligned to the needs and circumstances of that group.

ASSESSMENT AND MANAGEMENT OF RISK

Just because somebody is vulnerable does not automatically mean that they are unsuitable for the advice and services our firm supplies. As soon we think we may be engaging with a vulnerable consumer we will make a record of this and ensure we adhere to this policy.

When speaking to the vulnerable consumer we will:

Provide additional opportunities for the customer to ask questions about the information we have provided
Continuously seek confirmation that they have understood the information that has been provided
Ask if there is anybody with them who can assist them, and offer them the opportunity to have a family member or friend present during the conversation

We will not discriminate against clients in vulnerable circumstances. Where the vulnerability is mutually recognised, we will only adjust our fees where our services require extra resource to treat the client fairly. Any additional costs will not seek to profiteer from the situation and will be fully disclosed to the client before any subsequent work is conducted.

Where we feel we do not have the expertise to deal with the client due to their personal situation we will make every attempt to refer them to another firm or third party for the appropriate level of support to be provided.

Protocol that we will adopt when there is a possibility that a customer is vulnerable.

If an agent believes a customer falls into the above categories or the customer requests a grace period due to physical or mental issues the account will immediately be moved to Management Review.
The account will be brought to the attention of a Senior Manager or Director.
The account will be reviewed by senior management and all contact with the customer will be at senior level.
A letter or email will be sent to the customer seeking information concerning their vulnerability. This letter will be sensitive in content and will seek supporting documentation.
The client must be notified of the development and the fact the account is on hold, and will remain on hold until information is provided.
When the information is received it will be evaluated by a Senior Manager or Director who will make recommendations on how the vulnerable customer can be supported. These recommendations may include referral to an appropriate charity, extended deferral of collection activities or a recommendation to the client that the debt should be written off.
If no information is received the account will be returned to the client for instructions.
Whilst waiting for a response the account will remain on hold.

What is initially required for us to assess?

When we are advised that a customer has a Mental Health illness or is a vulnerable person, we will request documentation to enable us to evaluate the position.
This documentation may include:
- Authorisation confirming third party is the approved carer or social worker to act on customer’s behalf.
- In cases of terminal or serious illness medical confirmation from Hospital Consultant or General Practitioners.
- Third Party authorisation enabling us to communicate with that third party rather than the customer.

What are their current circumstances?

Are they employed or unemployable.
Is there is any likelihood of the debt being repaid within the remaining term of the debt.
Were they vulnerable when the debt was originally incurred?
If not under a carer or social worker, is the customer able to seek help from a free debt advice organisation who could provide them with guidance.

Client Instructions/Write off the debt

The ultimate decision to write off a debt lies with our client who will make the decision based upon the information provided to us and passed to them as part of this process. Write off may occur in the following circumstances:

If there is a serious health issues (Mental Health or Terminal illness) that are supported with medical evidence.
It has been judged by management, based upon the evidence provided, that the customer has no means or is incapable of repaying the debt

Respect

In all our dealings with vulnerable customers we will show respect and fairness whilst gathering all requisite information upon which our clients may then make a decision.

Understanding the benefits to our firm

Supporting customers and clients who are in a vulnerable position is not just a regulatory but is also a moral responsibility. We intend to fulfil our duties in this area and as a firm we see the benefits in adopting the right approach. These include:

Reduction in complaints
Greater client satisfaction
Engagement from a particular client set
Reputational benefits

Good publicity
Improvement of overall “culture”

We will review our practices periodically for consistency and to determine adherence to the stated policy.

The following table illustrates mitigating actions for clients with mental capacity deficiencies (for the avoidance of confusion “competent person” means an individual without the limitation presented by the client):

Capacity Issue

Risk

Mitigation

Language

Client cannot fully understand important features of their agreement with us, their recommendation, or the consequences of that recommendation

Client to instruct a competent person to function as interpreter.

Other communication problem created by disability

As above

Client to instruct a competent person to function as interpreter.

Client to nominate a reasonable communication medium suitable for their disability.

Mental incapacity (temporary) e.g., intoxication, mental illness

As above plus the potential for reckless disregard for consequence

Client to instruct a competent person to communicate on their behalf. Legal agreement must be reached outside of any period of incapacity.

Client should be encouraged to seek independent professional advice.

If legal agreement cannot be reached outside of any incapacity, client must provide “Power of Attorney” for a competent individual to act on their behalf.

Mental incapacity (Permanent)

As above plus the possibility that any agreement might be unenforceable because of known incapacity.

Client must provide “Power of Attorney” to a competent individual to act on their behalf.

RIGHTS & RESPONSIBILITIES

Our responsibilities:

To abide by the FCA’s principles and rules in this area FCA Principles for Business 2,3,6,7 & 9.

TCF Outcomes 1,2 & 4. Conduct of Business Rules.

DEPP 6.5A.2 (calculation of enforcement fines). Senior Manager Conduct Rules.

Individual Conduct Rules.

To ensure staff are aware of this policy and are trained to identify and deal with clients who are or may appear “vulnerable”

To support individuals in relation to identified risk and vulnerability

To provide means of reporting any instance where they believe that a client might be in vulnerable circumstances

Responsibilities of our employees:

To be familiar with this policy and procedures, and be able to recognise where additional support or signposting to other agencies may be required

To take appropriate action in line with this policy

To report any instance where they believe that a client might be in a vulnerable circumstance, and act accordingly in line with the policy

Identification of and treatment of vulnerable clients – Client Evaluation

The table below sets out our approach to dealing with all individuals, helping us to determine their circumstances and if they are in a permanent or temporary vulnerable situation. These guidelines will be distributed to all staff, and each will be trained on the areas relevant to their role.

Client evaluation

All clients will be assessed, as a minimum, against the following criteria. This is in addition to any processes we have in place for different vulnerability groups.

O U R C L I E N T S B E S T I N T E R E S T S

Assess the client against our vulnerability policy

Actively seek to encourage disclosure about potential vulnerability

Ensure the approach taken is accurately reflected in the business records

Consider whether to discuss the approach with colleagues/other professionals

Ensure the ‘know your client information’ gathers sufficient details to support the advice and uses additional questioning where appropriate

Consider any unusual aspects – e.g., if someone else is accompanying a client, is there the potential for undue influence from that person

Understand who the client is, and the extent of the instructions needed to act on e.g., Power of Attorney

Consider whether the client is acting differently/showing signs of a change of character

Set a list of questions to check client memory recollection, where appropriate

When working with more than one person, is there the potential for any conflict of interest or undue influence

Confirm any change in circumstances which might lead to vulnerability e.g., taking on caring responsibilities

Establish whether the client’s stated needs and objectives align with their current circumstances

Consider whether the standard sales process or specific vulnerability group process is appropriate to the client’s needs

Identify products/solutions that are clear and easy to understand for those showing signs of vulnerability

Consider whether there is a need to adjust the delivery and format of communications e.g., providing a report in large print

Explain all matters with no or limited use of jargon

Try to accommodate flexibility around appointment locations and times e.g., visiting the client at their home at their preferred time of the day

Try to determine if the duration of the meeting will need extending to accommodate more detailed explanations and delivery of information

Determine if the complexity of the advice will require delivery over a greater number of meetings

Considered the accessibility of office visits for those with health conditions/disabilities

GDPR – Data Protection Act 2018

OPERATIVE PROVISIONS

1.1Compliance with laws [and confidentiality]

In performing the Services and its other obligations under this Agreement COUNTRYWIDE COLLECTION SERVICES LIMITED will, and will procure that any Authorised Sub-Processor will, comply with the Data Protection Laws.

COUNTRYWIDE COLLECTION SERVICES LIMITED, and any persons authorised to process the Personal Data, will keep the Personal Data secret and confidential in accordance with the terms of this Agreement.

Any Authorised Sub-Processor will keep the Personal Data secret and confidential in accordance with the terms of this Agreement.

1.2Authority and roles

Without prejudice to clause 1.4.1.1, (INSERT CLIENT NAME) authorises COUNTRYWIDE COLLECTION SERVICES LIMITED, on its own behalf, to Process the Personal Data during the term of this Agreement as a Data Processor and solely for the purpose of providing the Services.

The Parties acknowledge and agree that (INSERT CLIENT NAME) is the Data Controller(s) of the Personal Data.

1.3Sub-Processing

The COUNTRYWIDE COLLECTION SERVICES LIMITED will not engage or use any third party for the Processing of Personal Data or otherwise cause or permit any third party to Process Personal Data without the prior written consent of (INSERT CLIENT NAME).

If COUNTRYWIDE COLLECTION SERVICES LIMITED appoints an Authorised Sub-Processor pursuant to clause 1.3.1, COUNTRYWIDE COLLECTION SERVICES LIMITED will ensure that there is in place a written contract between COUNTRYWIDE COLLECTION SERVICES LIMITED and the Authorised Sub-Processor that specifies the Authorised Sub-Processor’s Processing activities and imposes on the Authorised Sub-Processor the same terms as are imposed on the COUNTRYWIDE COLLECTION SERVICES LIMITED in this Annex 1.

COUNTRYWIDE COLLECTION SERVICES LIMITED will remain responsible and fully liable to (INSERT CLIENT NAME) for all acts and omissions of Authorised Sub- Processors as if they were its own. .

1.4COUNTRYWIDE COLLECTION SERVICES LIMITED’s obligations as Data Processor

COUNTRYWIDE COLLECTION SERVICES LIMITED will, and will procure that any Authorised Sub- Processor will:

Process the Personal Data only on documented instructions from (INSERT CLIENT NAME) (including for the avoidance of doubt the instructions as are set out in this Agreement;

Immediately inform (INSERT CLIENT NAME) if, in its reasonable opinion, any instruction received in connection with this Annex 1 infringes any Data Protection Laws;

Without prejudice to clause 1.4.1.1, ensure that Personal Data will be used solely for the purpose of providing, and to the extent required to provide, the Services;

Not cause or permit any Processing of Personal Data to occur outside the United Kingdom and/or the European Economic Area (as it is made up from time to time), including by way of any transfer, without (INSERT CLIENT NAME)’s prior written consent;

(In the event that the consent more particularly referred to in clause 1.4.1.4 is given, COUNTRYWIDE COLLECTION SERVICES LIMITED will, prior to causing or permitting any such Processing to occur outside the United Kingdom and/or the European Economic Area:

verify that the transfer is to a recipient located within an Adequate Jurisdiction (subject to any applicable restrictions);

ensure that the Standard Contractual Clauses are entered into as between (INSERT CLIENT NAME) (and/or the relevant member of (INSERT CLIENT NAME) Group) as ‘data exporter’ and the recipient of the Personal Data (including the Approved Sub-Processor, as relevant) as ‘data importer’ and that they remain in place throughout the term of the Agreement;

provide evidence in writing to (INSERT CLIENT NAME) that the recipient of the Personal Data (including the Approved Sub-Processor, as relevant) is certified under the EU/US Privacy Shield framework and that the certification is valid in respect of Processing of Personal Data under this Agreement (and COUNTRYWIDE COLLECTION SERVICES LIMITED hereby warrants and undertakes to ensure that the

Standard Contractual Clauses are entered into in the manner more particularly described at clause 1.4.1.5(b) immediately in the event that the recipient of the Personal Data is no longer certified under the EU/US Privacy Shield framework); or

provide evidence in writing to (INSERT CLIENT NAME) that the recipient of the Personal Data (including the Approved Sub-Processor, as relevant) has entered into Binding Corporate Rules which are valid in respect of Processing of Personal Data under this Agreement and which have been approved by the European Commission and/or appropriate regulators (and COUNTRYWIDE COLLECTION SERVICES LIMITED hereby warrants and undertakes to ensure that the Standard Contractual Clauses are entered into in the manner more particularly described at clause 1.4.1.5(b) immediately in the event that the recipient of the Personal Data is no longer a party bound by the Binding Corporate Rules);)

(Should any of the transfer mechanisms more particularly referred to in clause 1.4.1.5 which are being used by COUNTRYWIDE COLLECTION SERVICES LIMITED for the purposes of transfers under this Agreement be held by the European Commission to be invalid under the Data Protection Laws or be formally described by the Supervisory Authority as no longer providing for adequate protection for Personal Data under the Data Protection Laws, COUNTRYWIDE COLLECTION SERVICES LIMITED will (at the option of (INSERT CLIENT NAME)):

immediately at no additional cost to (INSERT CLIENT NAME) put in place an alternative mechanism for transfers which has been prior approved in writing by (INSERT CLIENT NAME) having regard to the Data Protection Laws; or

cease transfers of the Personal Data to the relevant recipient forthwith and procure that the relevant recipient immediately takes all actions as are necessary in order for COUNTRYWIDE COLLECTION SERVICES LIMITED to comply with clause 1.4.1.11;)

Ensure that every individual who is authorised to Process Personal Data (including for the avoidance of doubt employees and other staff working for COUNTRYWIDE COLLECTION SERVICES LIMITED or for any Approved Sub-Processor) has committed themselves to confidentiality (meaning that they are either subject to confidentiality obligations equivalent to those set out in [the terms of this Agreement or that they are under an appropriate statutory obligation of confidentiality), and ensure that

they will comply with this Annex 1, be appropriately reliable, qualified and trained, and that they will only be permitted to have access to the Personal Data as necessary to perform their roles in relation to the provision of the Services;

Implement (and assist (INSERT CLIENT NAME) to implement) technical and organisational measures so as to ensure a level of security appropriate to the risk presented by Processing the Personal Data including the risk of varying likelihood and severity for the rights and freedoms of Data Subjects, and in particular from a Data Security Incident. This may include, but is not limited to; encryption, Pseudonymisation, resilience of processing systems and backing up Personal Data.

Notify (INSERT CLIENT NAME) without undue delay (and in any event no later than 12 hours) after becoming aware of any Data Security Incident, including the nature of the Data Security Incident, the categories and approximate number of Data Subjects and Personal Data records concerned, the name and contact details of the data protection officer or other contact point at COUNTRYWIDE COLLECTION SERVICES LIMITED (or the relevant Approved Sub- Processor) where more information can be obtained, the likely consequences of the Data Security Incident, and any measure(s) taken or proposed to be taken to address the Data Security Incident and to mitigate its possible adverse effects, in each case taking into account the nature of the Processing and the information available to COUNTRYWIDE COLLECTION SERVICES LIMITED, and where and in so far as it is not possible to provide all the relevant information at the same time, the information may be provided in phases without undue further delay, but COUNTRYWIDE COLLECTION SERVICES LIMITED (and Authorised Sub-Processors, as applicable) may not delay notification under this clause

1.4.1.9 on the basis that an investigation is incomplete or ongoing;

Taking into account the nature of the Processing, and at no additional cost to (INSERT CLIENT NAME), assist (INSERT CLIENT NAME) in fulfilling its/their obligations under the Data Protection Laws, including in relation to:

responding to requests for exercising Data Subjects’ rights under the Data Protection Laws, including by appropriate technical and organisational measures, insofar as this is possible, and including the right to be informed, the right to have personal information corrected if it is inaccurate, the right to object to certain processing of personal information, the right to restrict

processing of personal information, the right to have personal information erased (commonly known as ‘right to be forgotten’), the right to request access to personal information, the right to move, copy or transfer certain personal information (commonly known as ‘data portability’), rights in relation to automated decision making including profiling, and the right to complain to the Supervisory Authority about infringements of the Data Protection Laws, and for the avoidance of doubt in cases where a Data Subject has engaged the right to have personal information erased under the Data Protection Laws, COUNTRYWIDE COLLECTION SERVICES LIMITED acknowledges and agrees that merely putting beyond use the Personal Data or suppressing the same will not amount to erasure so as to enable it to comply with this clause 1.4.1.10(a)];

(without prejudice to clause 1.4.1.9) documenting any Data Security Incidents (including the facts relating to the Data Security Incidents, their effects and the remedial action taken) and reporting any Data Security Incidents to the Supervisory Authority, any other Regulator and/or Data Subjects, including by taking into account the information available to COUNTRYWIDE COLLECTION SERVICES LIMITED;

(without prejudice to clause 1.4.1.9) taking measures to address Data Security Incidents, including, where appropriate, measures to mitigate their possible adverse effects; and

conducting privacy impact assessments of any Processing operations and consulting with supervisory authorities, Data Subjects and their representatives in respect of the same; and

Promptly after the end of the provision of Services relating to Processing of the Personal Data (including following termination of this Agreement if that is when the provision of Services ends) and sooner at any other time at the written request of the Customer (provided the Customer is acting reasonably):

securely delete all Personal Data (including by irrevocably, completely and permanently deleting the same, including from archives and back up facilities, as relevant, and in such a way that there shall be no ability to recover the same at any time from any medium, repository, or location whatsoever), or return to the Customer all Personal Data (and it shall be at the option of the Customer whether there is deletion or, in the alternative, return under this clause 1.4.1.11(a));

(in the event that the Customer opts for return pursuant to clause 1.4.1.11(a)) securely delete any existing or remaining copies of the Personal Data (deletion having the same meaning as is set out above); and

promptly certify (via a director) when the exercise described in this clause 1.4.1.11 has been completed

assist the Data Controller with meeting the GDPR Article 32 obligation to keep Personal Data secure.

assist the Data Controller with meeting the GDPR Article

35 obligation to carry out Data Protection Impact Assessments (DPIAs).

assist the Data Controller with meeting the GDPR Article 36 obligation to consult with their supervisory authority where Data Protection Impact Assessments (DPIAs) indicate there is an unmitigated high risk to the processing.

1.5Information provision

COUNTRYWIDE COLLECTION SERVICES LIMITED will, and will procure that Authorised Sub- Processors will, and at no additional cost to (INSERT CLIENT NAME):

make available to (INSERT CLIENT NAME) all information necessary to demonstrate compliance with the obligations set out in this Annex 1; and

allow for and contribute to audits, including inspections, conducted by the or another auditor mandated by (INSERT CLIENT NAME); and

allow for and contribute to audits, including inspections, conducted by the Supervisory Authority and provide all information necessary in response to any request from the Supervisory Authority in relation to the same, in each case which relates in whole or in part to the Personal Data; [and

without prejudice to clauses 1.5.1.1, 1.5.1.2 and 1.5.1.3, conduct an annual audit in respect of its processing of the Personal Data, its compliance with the Data Protection Laws including in relation to the Personal Data, and its compliance with this Annex 1, and promptly thereafter supply (INSERT CLIENT NAME) with a copy of a written report in respect of the annual audit including the findings and outcomes relating to the same.

1.6Indemnity

COUNTRYWIDE COLLECTION SERVICES LIMITED will indemnify (INSERT CLIENT NAME) and hold it harmless against all of the Liabilities suffered or incurred by it, in each case arising out of or in connection with any breach by COUNTRYWIDE COLLECTION SERVICES LIMITED of any of its obligations under this Annex 1 (including any failure or delay in performing, or negligent performance or non-performance of, any of those obligations) including for the avoidance of doubt any breach by COUNTRYWIDE COLLECTION SERVICES LIMITED which arises out of the actions or omissions of any of the Approved Sub-Processors.

1.7Liability

COUNTRYWIDE COLLECTION SERVICES LIMITED’s liability for any breach of this Annex 1 and in respect of the indemnity at clause 1.6 will be unlimited and for the avoidance of doubt all such liability will be outside of any cap(s) or limitation(s) as may be set out in the Agreement.

1.8Termination for breach

A breach of this Annex 1 by COUNTRYWIDE COLLECTION SERVICES LIMITED, including for the avoidance of doubt any breach by COUNTRYWIDE COLLECTION SERVICES LIMITED which arises out of the actions or omissions of any of the Approved Sub-Processors, or of the Standard Contractual Clauses (as relevant) will be a material breach of this Agreement.

1.9Conflict

The provisions of the Agreement shall at all times be subject to COUNTRYWIDE COLLECTION SERVICES LIMITED’s obligations under this Annex 1

1.10Interpretation of consent

Wherever under this Annex 1 (INSERT CLIENT NAME)S consent is required before COUNTRYWIDE COLLECTION SERVICES LIMITED is permitted to do a particular act or thing, unless expressly provided otherwise, the (INSERT CLIENT NAME) shall be entitled to give or withhold consent or make consent subject to conditions at its sole discretion.

1.11Further assurance

COUNTRYWIDE COLLECTION SERVICES LIMITED will execute all such documents and do all such acts or things as (INSERT CLIENT NAME) may reasonably request from time to time in order for (INSERT CLIENT NAME) to comply with its/their obligation(s) under the Data Protection Laws, in particular in respect of what is required in written terms between Data Controllers and Data Processors, including having regard to any updates to Annex 1 which may be necessary from time to time by reason of formal guidance or codes of practice issued by the Supervisory Authority and which are relevant to the subject matter of this Annex 1.

1.12Description of Processing

COUNTRYWIDE COLLECTION SERVICES LIMITED warrants and undertakes to ensure that its description of the Processing carried out on the Personal Data under

this Annex 1is complete and accurate as at the date of COUNTRYWIDE COLLECTION SERVICES LIMITED’s signature on this Annex 1.

(INSERT CLIENT NAME) reserves the right to review and amend the description of the Processing more particularly referred to in clause 1.12.1 at its sole discretion.

1.13Survival

The clauses in this Annex 1 shall survive termination of the Agreement.