The right way to select a tracing and recovery partner is to test four things before you instruct: regulatory standing, data governance, evidential quality, and what happens when a case does not go to plan. Price is the easiest of these to compare and the least useful, because the cheapest trace in a bad instruction is the most expensive thing on the file.

Here are the ten questions worth asking, and what a good answer sounds like.

1. Are you FCA authorised, and can you evidence it?

Debt collection activity for regulated credit agreements is a regulated activity. An agency operating outside that perimeter exposes the instructing lender, not just itself, to regulatory and reputational consequences.

A good answer gives you a firm reference number you can verify on the FCA register in thirty seconds, and a clear explanation of which permissions they hold. An agency that is vague about its regulatory position on a first call will not become clearer once it has your data.

2. What is your lawful basis for processing, and can you show me the assessment?

Tracing is permitted under GDPR Article 6(1)(f) on the basis of legitimate interests, subject to a proportionality test. That is not a slogan. It requires a documented Legitimate Interests Assessment for the activity being conducted.

A good answer references a named Data Protection Officer, documented LIAs, data minimisation in practice, defined retention periods, and staff training. As the instructing party you are a data controller in this relationship. Your supplier's compliance failures land on your desk as well as theirs.

3. How many independent sources support a confirmed address?

This is the single most revealing question you can ask, and the answers vary enormously.

A good answer is at least two independent sources, with the date of most recent confirmation stated on the report. A supplier who returns a single-source address with a percentage next to it is selling you a probability and calling it a result.

4. What is your definition of a successful trace?

Success rates are quoted freely across this industry and defined inconsistently. Some firms count any returned address as a hit, including ones that are never verified and never lead anywhere.

A good answer defines success as a confirmed, verified outcome rather than a data return, and is willing to explain the methodology behind the number. Ours is over 80% across trace, serve, and recovery, and we are happy to talk through how that is measured.

5. Will your report stand up in proceedings?

If a matter escalates, a report full of unsourced assertions is worse than no report at all.

A good answer includes a source reference against every finding, distinguishes statutory sources such as CRA data, Land Registry and DVLA from intelligence sources such as OSINT and field intelligence, and confirms that investigators are experienced in preparing witness statements where required.

6. How do your field agents identify and handle vulnerability?

Under Consumer Duty, the conduct of your agents is your exposure. A field agent who cannot recognise a mental health crisis, a domestic vulnerability, or a physical incapacity is a compliance incident waiting to happen at your customer's front door.

A good answer describes specific training, and critically, describes the authority agents have to pause or modify an approach on the doorstep. If agents are not empowered to stop, the training is decorative.

7. What visibility do I have while a case is live?

Reporting that arrives only at the end of a case is reporting you cannot act on.

A good answer is a client portal with real-time visibility of every action on every file, so your own compliance team can answer questions without emailing your supplier first.

8. Can you handle the next step, or do I need another supplier?

Fragmentation costs money and creates gaps. A trace from one supplier, a field visit from a second, and a repossession from a third means three handovers, three sets of assumptions, and no single accountable party when something goes wrong.

A good answer covers tracing, field visits, process serving, repossession, and forensic investigation under one instruction, with one accountable point of contact.

9. What will you tell me when the answer is no?

This question separates advisers from order-takers.

A good answer is a supplier who will tell you an account is uneconomic to pursue, that a customer genuinely cannot pay, or that litigation is not the right route, even where saying so means less work for them. A supplier who has never recommended you stop spending money is not assessing your cases, they are processing them.

10. Who actually does the work?

Subcontracting is common and not inherently wrong, but you should know about it.

A good answer is a clear account of which work is done in-house, which is subcontracted, how subcontractors are vetted and monitored, and whether they operate to the same compliance standards. Your customer does not distinguish between your supplier and your supplier's supplier. Neither will the FCA.

The Question Behind All Ten

Every one of these comes back to the same thing: is this supplier accountable for the outcome, or only for the activity?

Plenty of firms will sell you activity. Letters sent, calls attempted, addresses returned. Activity is easy to measure and easy to bill. Outcomes are harder, and they require a supplier willing to make judgement calls, tell you inconvenient things, and stand behind findings in a forum where they can be challenged.

The Towerhall Position

We have been doing this since 1999. We are FCA authorised, we hold more than seventy institutional clients, we have recovered over 97 million in assets, and we maintain an over 80% success rate across trace, serve, and recovery.

We are also comfortable being asked all ten of the questions above, because we would ask them of anyone we were considering instructing.

If you are reviewing your current arrangements, or tendering, we are happy to answer them in writing. Contact Towerhall Solutions for a confidential conversation.

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