Purnells Insolvency Practitioners © All Rights Reserved.
What is this Notice for?
Corporate & Personal Recovery Specialists Limited T/A Purnells are a firm of Insolvency Practitioners and Chartered Certified Accountants, providing both corporate and personal insolvency advice.
We take issues relating to your personal data really seriously. Our Data Protection Manager is Susan Purnell to whom you should address any queries.
This notice is to explain more to you about how we handle personal data. It is important that you read this, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are aware of how and why we are using such information.
What do the various terms mean?
“Personal Data” Means recorded information we collect, store or hold about individuals from which a person can be identified. It may include the following:-
Personal contact details such as name, title, address, telephone numbers and personal email address or company email address.
Date of birth.
Marital status and dependants.
Payroll records and tax status information.
Salary, annual leave, pension and benefits information.
Location of employment or workplace.
Driving and other licenses.
Details of assets and liabilities.
“Processing” Means doing anything with the data, such as accessing, disclosing, destroying or using the data in any way.
How is personal data collected?
Typically you have given us the data in relation to a matter we are advising on. We do not buy in personal data for marketing purposes.
Occasionally we are passed details by a third party such as an accountant or a solicitor where they ask us to contact a person because they require our assistance. In such cases if a person does not wish to proceed to instruct us we will not retain any records.
What purpose do you use personal data for?
We will only use personal information when the law allows us to. Most commonly, we will use personal information in the following circumstances:
Where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use personal data in the following situations, which are likely to be rare:
Where we need to protect your interests (or someone else’s interests).
Where it is needed in the public interest or for official purposes.
The situations in which we will process personal data are listed below and relate to either advising a client regarding:
Dealing with providing preliminary advice
Acting in relation to:
Creditors Voluntary Liquidation
Company Voluntary Arrangements
Individual Voluntary Arrangements
Section 1003 Applications
Members Voluntary Liquidation
What if there is a change of purpose?
We will only use your personal data for the purposes for which we collected it or are given it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use personal data for an unrelated purpose, we will notify you and we will explain the legal basis which we believe, allows us to do so.
Please note that we may process your personal data without an individual’s knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
What safeguards are in place?
We will comply with the eight data protection principles in the DPA, which say that personal data must be;
Processed fairly and lawfully.
Processed for limited purposes and in an appropriate way.
Adequate, relevant and not excessive for the purpose.
Not kept longer than necessary for the purpose (and in accordance with the Insolvency Act 1986).
Processed in line with individuals’ rights.
Not transferred to people or organisations situated in countries without adequate protection.
We will keep the personal data we store accurate and up to date. Data that is inaccurate will be amended when we are made aware that it is out of date. Please notify us if your personal details change or if you become aware of any inaccuracies in the personal data we hold about you.
We will not keep personal data for longer than is necessary for the purpose or carrying out our retainer. This means that data will be destroyed or erased from our systems when it is no longer required. For compliance purposes we are required to keep our files for a six year period after which they are securely destroyed.
We will ensure that appropriate measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
We have in place procedures and technologies to maintain the security of all personal data from the point of collecting to the point of destruction. Maintaining data security means guaranteeing the confidentiality, integrity and availability (for authorised purposes) of the personal data. For example, we take the following steps to protect data:
Staff are trained in relation to the importance of privacy and data security.
We don’t give advice on social media or via text message.
Electronic files can only be accessed via password logins.
We will only pass your data to third parties where you have asked for us to or it is required under the Insolvency Act 1986. For example, you might ask us to refer your contact details to other professionals. We only make referrals of this kind when consent has been expressly given. We do not sell any data or pass data to other organisations.
We will not disclose your personal data to a third party without your consent unless we are satisfied that they are legally entitled to the data. Where we do disclose your personal data to a third party, we will have regard to the eight data protection principles. We will only transfer personal data to a third party if he/she agrees to comply with those procedures and policies, or if he puts in place adequate measures him/herself.
What rights do I have?
Your duty to inform us of changes
It is important that the personal information we hold for you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law individuals have the right to;
Request access to your personal information (commonly known as a “data subject access request”). This enables a person to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
Request correction of the personal information that we hold about them. This enables them to have any incomplete or inaccurate information we hold about them corrected.
Request the erasure of personal information. This enables a person to ask us to delete or remove personal data where there is no good reason for us to continue to process it. They also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about their particular situation which makes them want to object to processing on this ground.
Request the restriction or processing of personal information. This enables a person to ask us to suspend the processing of personal data about them, for example if they want us to establish its accuracy or the reason for processing it.
Request the transfer of personal information to another party.
If a person wants to review, verify, correct or request erasure of their personal data, object to the processing of personal data, or request that we transfer a copy of your personal information to another party, please contact Susan Purnell in writing.
No fee usually required
A person will not have a pay a fee to access their personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if the request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need
We may need to request specific information from a person to help us confirm their identity and ensure that their right to access the information (or to exercise any of their other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where a person may have provided consent to the collection, processing and transfer of their personal data for a specific purpose, they have the right to withdraw their consent for that specific processing at any time. To withdraw consent please contact Susan Purnell. Once we have received notification that a person has withdrawn consent, we will no longer process their information for the purpose or purposes they originally agreed to, unless we have another legitimate basis for doing so in law.
Data protection manager
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle personal information, please contact Susan Purnell. Anyone has the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing for your personal information.
© Copyright 2018 Purnells
QF1227-N AUTH BY: S.P. ISSUE DATE: 25 MAY 2018
ISSUE: NO. C1
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