At Winterbottom’s Schoolwear, we treat all information we hold about you as confidential and want to be open and transparent with you as to how we process and protect your personal data.

The following privacy policy sets out how we collect and use personal information about individuals and covers:

1. Information we may collect about you

2. Use of your information

3. Contacting you

4. Sharing your information

5.Close Brothers Invoice Finance Assignment

6. Our legal basis for collecting and storing your information

7.Security and data retention

8Your Rights

9. Appendix A

  1. Information we may collect about you

You may provide us with personal information by filling in a form, contacting us by phone/e-mail or in person. The information you give us depends on the reason for you contacting us, but may include your name, job title, address, date of birth, e-mail address, phone number, financial and debit card information, personal identification documents or data relating to access.

We use cookies to automatically collect information about individuals who visit our website, to help improve the performance of this website on your device. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. These cookies are stored only in the browser and are not accessed by or shared with any other service or third party.

You have the option to opt-in or opt-out of receiving cookies: Users who opt-in will continue to let the browser store the cookies, and users who opt-out will have the browser delete all the cookies stored under our website.

  1. Use of your information

We need to obtain, store and use information about you for legitimate business purposes - specifically so that you can enjoy and benefit from our services. We may use information we hold about you in the following ways:

  • To confirm your identity
  • To notify you on updates to your order
  • To let you know about other relevant services; both ours and those of other parties whose products and services we have agreed should be made available to you
  • To update and correct our customer records
  • To develop, test and improve our systems
  • To notify you about changes to our services
  • To conduct market research and product analysis
  • To provide you with marketing material, which may be tailored to your individual needs, when we have your permission to do so
  • To run competitions, events and promotional activities
  • To improve our website to ensure that content is presented in the most effective manner for you and for your computer
  1. Contacting you

An important part of our work is communicating with our customers, and in order to do so, we use personal information to keep in touch with individuals within our customer base. We will use the contact information you have given us to send you important information, which may be by post, email or telephone. We may also use the information we hold about you in order to provide you with information about other products or services we feel may interest you.

  1. Sharing your information

We may share your information with selected third parties including our software and website developers, and/or online service providers; such as payment gateways, marketing systems and survey tools.

  1. Close Brothers Invoice Finance Assignment

We may share your information with our Invoice Finance provider – Close Brothers Invoice Finance Ltd as set out in Appendix A of this document.

  1. Our legal basis for collecting, holding and using your information

Data protection law sets the lawful legal bases which allow us to collect, hold and use your personal information. This could be for one of the following reasons:

  • Where we believe that we have a legitimate interest in being able to provide our services to our customers. This sometimes requires us to collect and use personal information about individuals, however, we only use this legal basis where these interests are not overridden by your interests and fundamental rights or and freedoms
  • Where we have entered into a contract with you, as we may need to process your personal information in order to fulfil the contract
  • Where we are under a legal obligation to process personal information. For instance, we are required to collect certain information in accordance with our obligations under equalities legislation
  1. Security and data retention

Of the information about you that we collect, we will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We will keep personal information held as part of our accounts records, however, we will only keep this in line with legal requirements.



  1. Your rights

Customer information will be held by us on our IT systems and will be kept in line with our retention procedures. If you would like a copy of the information we hold about you, you can make a Data Subject Access Request under the Data Protection Act.  Individuals will be charged £10 per subject access request. The data controller will aim to provide the relevant data within 21 days. The data controller will always verify the identity of anyone making a subject access request before handing over any information.

You also have the right to ask us not to process your personal data for direct marketing purposes.

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, the Company shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the ICO (more information on the ICO website).



If you require any further information regarding this policy, please write to: HR Data Department, Winterbottom’s Schoolwear, Level One, Paton House, Victoria Viaduct, Carlisle, Cumbria, CA3 8AN




We may edit this policy from time to time. If we make any substantial changes, we will notify you by posting a prominent announcement on our web pages.


9. Appendix A




Your personal data will be collected and processed by Close Invoice Finance Limited referred to as “we”, “our” or “us”.

This notice is intended to provide an overview of what personal data we collect about you and why we process it. The type of personal data we collect may include your and your representatives’ name, address, e-mail address and telephone number, financial and credit card information, employment history, health information, credit history, identification records, qualifications and vehicle or asset details. You can find further information about how and why we use your personal data and the rights that you have in relation to your data at If you have any questions about this notice, about how we process your personal data or about your rights over your personal data, please contact our Data Protection Officer at: or DPO, Close Brothers, 10 Crown Place, London EC2A 4FT.

9.1. Purposes for which we use your personal data

The core purposes for which we process your personal data include the following:

  1. To verify your identity, assess your suitability for the products and services that you have requested, and decide whether to enter into an agreement with you, such as: carrying out credit reference and scoring checks, checking details on proposals and insurance claims, checks for criminal proceedings / convictions, carrying out financial assessments, anti-money laundering, terrorist financing and fraud prevention checks which may include sharing personal data with fraud prevention agencies, third party financial assessment providers, associated audit services, and managing credit or credit related accounts or facilities.
  2. To manage, administer and take decisions regarding your agreement, such as: providing products and services to you, exercising our rights, and performing our obligations, in connection with the agreement, making payments and recovering monies.
  3. Where it is necessary for our legitimate business interests, such as: carry out routine checks on your organisation’s directors and invoices to monitor the risks associated with our agreement with your organisation, improving customer service, market research, quality assurance, training staff, marketing (where we are permitted to send you promotional information), system development and statistical analysis on your personal data even if your application is declined by us or you decide not to complete your application with us.
  4. To meet our legal and regulatory obligations

9.2. Exchange of Information with Credit Reference Agencies

In considering whether to enter into an agreement with you or your organisation, we may use your personal data for making a credit check on you. We may carry out a search with a credit reference agency who will keep a record of our enquiry against your name. We may search your personal records at credit reference agencies which may be linked to your spouse/partner or other persons with whom you are linked financially (“associated records”) and you may be assessed with reference to “associated records”. More specific information in respect of the credit reference agencies with whom we share your personal data is available at:, and

Where any search or application is completed or agreement entered into involving joint parties, we may record details at credit reference agencies, as a result an “association” will be created that will link your financial records.

Where you provide us with personal information belonging to a third party, you must ensure you have obtained the necessary consents in order to disclose their information and have provided them with a copy of this notice.

We may also make periodic searches of credit reference agencies to manage your account with us, including for the purpose of making decisions about whether to make further credit available or to continue or extend existing credit.

Please contact us and consult our privacy notice at if you would like details of the credit reference agencies from whom we obtain, and to whom we pass, information about you.

We may also add to your or, if applicable, your business’s record with the credit reference agencies details of your Agreement with us, any payments you make under it and any default or failure to keep to its terms. These records will remain on the credit reference agencies file for 6 years after our agreement with you is settled or terminated whether settled by you or, if applicable, your business or by way of default. The credit reference agencies may add to their record about you, or, if applicable, your business, details of our search and your application whether or not your application proceeds. The credit reference agencies supply to us both public (including electoral register) and shared credit information. We may also use credit scoring or other automated decision making systems. These credit scoring techniques and automated decision making systems may take into account any previous applications for finance, defaults or existing debt. The results of this decision may decide whether we provide you with our services or not. If you disagree with the results of an automated decision, you can request a review of your application.

This Privacy Policy was last updated 27/07/2020