1. Introduction

Our Privacy Policy sets out the terms on which we process any personal data we collect from you or that you provide to us. It also applies to your use of our site. By using our site, you consent to such processing and you warrant that all data provided by you is accurate.

We are committed to protecting and respecting your privacy. For the purposes of the General Data Protection Regulation (GDPR) and any subsequent UK legislation covering data protection the Data Controller is Strong Anderson.

Where an insolvency practitioner of Strong-Anderson is not appointed as office holder, the data controller is either the company/individual on whose instructions Strong Anderson is acting or it is Strong Anderson.

 Where an insolvency practitioner of Strong-Anderson is appointed as office holder and the data processing is carried out as part of their statutory duties, the office holder(s) is/are the data controllers. The Insolvency Practitioner(s) can be contacted atmariastrong@strong-anderson.co.uk.

Maria Strong of Strong Anderson is responsible for matters relating to Data Protection and can be contacted on mariastrong@strong-anderson.co.uk.

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018 and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).

This Policy may change from time to time and, if so, we will advertise any significant changes on our website or contact you directly with the information.

2. What Information we Collect

The type and amount of information we collect depends on why you are providing it.

The information we hold about you may include the following:

• Your personal details (such as your name and/or address);
• Details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• Details of any services you have received from us;
• Our correspondence and communications with you;
• Financial information and location
• Information about any complaints and enquiries you make to us and
• Information we receive from other sources, such as publicly available information or information provided by your employer.

In rare cases, we may hold some special category data, e.g. trade union membership or information about individuals’ health, which will be necessary to administer the insolvency process in line with our legal obligations.

3. How we collect or who we provided Information

We may collect information from you whenever you contact us or have any involvement with us for example when you:

• Attend a meeting with us and provide us with information and
• Contact us in any way including online, email, phone or post

The personal data we have used to contact you was provided by:

• The company/individual (or persons acting on their behalf) on whose instructions we are acting or in relation to which our insolvency practitioner has been appointed and
• The Registrar of Companies and other similar public-access data providers

4. How we use your Information

We will use your personal information in a number of ways which reflect the legal basis applying to processing of your data. These may include:

• Deliver services and meet legal responsibilities;
• Carry out our obligations arising from any agreements entered into between you or your employer or our clients and us (which will most usually be for the provision of our services);
• Carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• Provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
• Verify identity where this is required;
• Communication by post, email or telephone;
• Understand needs and how they may be met;
• Maintain records;
• Process financial transactions;
• Prevent and detect crime, fraud or corruption and
• To defend or take legal actions related to the above
• Seek your thoughts and opinions on the services we provide and
• Notify you about any changes to our services.

In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.

5. Our Lawful Basis for Processing your Information

Most processing is carried out to comply with our legal obligations under statute and other regulatory obligations related to the insolvency process. For example, we have a statutory duty to circulate the Statement of Affairs which will include amongst information the names and postal addresses of shareholders, companies’ creditors (including current employees, former employees and consumers).

We also believe our processing is for the legitimate interests of all stakeholders in the insolvency process, as they are entitled to be kept informed and may wish to engagement in the insolvency process. Where Strong-Anderson has engaged with a client to perform a service, we will be required to process data to provide the service in accordance with the contractual terms

6. How we keep your Information Safe

We understand the importance of security of your personal information and take appropriate steps to safeguard it by encrypting all of our computers.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.We always ensure only authorised persons have access to your information, which means only our staff and contractors. We always ensure that everyone who has access is appropriately trained to manage your information.

With regard to data transmission over the internet we use an online document exchange portal that encrypts documents that we are sending to clients or vice versa. We encourage clients to send any personal data they need to give us via this method. Should you choose to send us data over the internet via another means we cannot guarantee the security of this information and you do this at your own risk.

7. Process

We may use third parties located outside the UK and the European Union (“EU”)to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes countries outside the EU and countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EU are done lawfully. Where we transfer personal data outside of the EU to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EU.

Personal data held by us may be transferred to:

• Third party organisations that otherwise assist us in providing goods, services or information;
• Auditors, accountants and other professional advisers;
• Appropriate staff;
• Third party organisations that provide applications, functionality, data processing or IT services to us and
• Law enforcement or other government and regulatory agencies or to third parties as required by, and in accordance with, applicable law or regulations.

8. Keeping your Information up to Date

We really appreciate it if you let us know if your contact details change. You can do so by contacting the Partner who is responsible for your affairs.

9. Children’s Information

Where appropriate we will ask for consent from a parent or guardian to collect information about children (under 16s).

10. How Long we Keep your Information For

We will hold your personal information for as long as it is necessary for the relevant activity

When assessing what retention period is appropriate for your personal data, we take into consideration:

• The requirements of our business and the services provided;
• any statutory or legal obligations;
• The purposes for which we originally collected the personal data;
• The lawful grounds on which we based our processing;
• The types of personal data we have collected;
• The amount and categories of your personal data and
• Whether the purpose of the processing could reasonably be fulfilled by other means.

11. Change of Purpose

We need to use your personal data for another reason, other than for the purpose for which we collected it, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing

12. Your Rights

You have a right of access to personal data held by us as a data controller. This right may be exercised by contacting the relevant Insolvency Practitioners acting as office holders, using the contact details provided with notification of this privacy notice to you. Alternatively you may email mariastrong@strong-anderson.co.uk. We will aim to respond to any requests for information promptly, and in any event within one month.

To update personal data submitted to us, you may contact the relevant Insolvency Practitioners acting as office holders, using the contact details provided with notification of this privacy notice to you. Alternatively you may email mariastrong@strong-anderson.co.uk.Or you may amend the personal details held on relevant applications with which you registered e.g. the IPS Portal.

Not all of the rights under the GDPR are available as one of the reasons we are holding your data is on the basis of it being a legal obligation and therefore the following rights do not apply:

• The right to erasure of your information (known as the “right to be forgotten”);
• The right to restrict the way in which we are dealing with and using your information;
• The right to request that your information be provided to you in a format that is secure and suitable for re-use (known as the “right to portability”);
• The right to withdraw consent;
• The right to object and
• Rights in relation to automated decision making and profiling including profiling for marketing purposes.

13. Links to other Sites

Strong Andersons website contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

14. Complaints

Should you want to complain about our use of personal data, please contact us by email at mariastrong@strong-anderson.co.uk.

You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.

15. Changes to this Policy

This Policy may be changed from time to time. If we make any significant changes we will advertise this on our website or contact you directly with the information.

Do please check this Policy each time you consider giving your personal information to us.

16. Contact Us

To contact us, please email mariastrong@strong-anderson.co.uk.

Paper copies of this privacy policy may also be obtained by emailing mariastrong@strong-anderson.co.uk.