SFP Corporate Solutions Privacy Policy

INTRODUCTION

Welcome to the SFP Corporate Solutions Limited privacy notice.

SFP Corporate Solutions Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

  1. ABOUT SFP CORPORATE SOLUTIONS
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY

1. ABOUT SFP CORPORATE SOLUTIONS

Purpose of this Privacy Notice
This privacy notice aims to give you information on how SFP Corporate Solutions Limited (SFP Corporate Solutions) collects and processes your personal data.

This website is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller
SFP Corporate Solutions Limited is the controller and responsible for your personal data (collectively referred to as ”SFP Corporate Solutions”, “we”, “us” or “our” in this privacy notice). Where one (or more) of our licensed insolvency practitioners is appointed under the Insolvency Act 1986 or the Law of Property Act 1925 (i.e. acting as an “insolvency office holder”), they may be the controller. For the purposes of this notice, reference to SFP Corporate Solutions includes our insolvency practitioners acting in this capacity.

Richard Hunt is the Compliance Manager of SFP Restructuring Limited who is also responsible for overseeing questions in relation to this privacy notice for SFP Corporate Solutions and Alexander Reed is the Group Data Protection Compliance Lead. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact Richard Hunt or Alexander Reed using the details set out below.

Contact Details
Our full details are:

Full name of legal entity: SFP Corporate Solutions Limited

Name or title of persons responsible: Richard Hunt / Alexander Reed

Email address: RichardH@sfpgroup.com / AlexR@touchfinancial.co.uk

Postal address: 9 Ensign House, Admirals Way, Docklands, London, E14 9XQ

Telephone number: 020 7538 2222

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Privacy Notice and Your Duty to Inform us of Changes
This version was last updated on 22/05/2018.

The data protection law in the UK changed on 25 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
  • Contact Data includes email address and telephone numbers.
  • Financial Data e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes preferences and feedback.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, we may acquire some Special Categories of Personal Data in carrying out our duties as insolvency office holder.

If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • enquire for our services;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • give us some feedback; and
    • respond to our requests or notifications as insolvency office holder.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy below for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various interested parties and public records.
  • Clients and entities over which we are appointed insolvency office holder. Our clients may provide Identity, Contact and Financial Data about others, e.g. their customers or suppliers, to enable us to provide the service to the client. When we are appointed insolvency office holder, we have access to the insolvent entity’s records to enable us to carry out our statutory duties.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • 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.
  • Where we need to comply with a legal or regulatory obligation.

Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data. Where we have used consent you have the right to withdraw consent at any time by Contacting us.

Purposes for Which we Will Use Your Personal Data
We have set out below, a description of the ways we plan to use your personal data.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data.

The purpose for which personal information is processed may include any or all of the following:

  • deliver services and meet legal responsibilities;
  • 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
  • may also need to use data to defend or take legal actions related to the above.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If at any time you wish to change your marketing preferences please contact us using the contact details above.

Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us and, you have not opted out of receiving that marketing.

Opting Out
You can ask us to stop sending you marketing messages at any time by Contacting us time or by clicking unsubscribe at the bottom of any marketing information received.

Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we may notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We will not disclose your personal information to a third party unless you agree for us to do so, we are required to do so by law or It is required in the exercise of duties as an office holder.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. DATA RETENTION

How Long Will You Use My Personal Data For?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data can be requested from us by contacting us using the details above.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

*Further information on each of these rights can be found in the Glossary below.

If you wish to exercise any of the rights set out above, please contact us using the details above.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. GLOSSARY

Lawful Basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to carry out our role to a high standard. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your Legal Rights
You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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