This statement sets out how Rachel Fowler Advisory uses and protects information received either through its web-site or in the course of our work. Protection of personal data is important to us and a matter we take seriously. If you have any concerns please contact Rachel Fowler directly. The policy outlines how and why we collect and use personal data from clients, employee candidates, public record and other members of the public.
Questions or Complaints
If you have any questions or complaints in respect of this policy or our process please refer them to firstname.lastname@example.org in the first instance. In addition you have the right to make a complaint to the Information Commissioner’s office (ICO).
If you notice an inaccuracy in any of the information we hold or your circumstances change please let us know immediately. Failure to do so may effect the advices given and could lead to delays in conclusion of matters.
RFA from time to time will collect personal data, this means information on an individual from which that person can be identified. This does not include information where identity has been redacted or removed.
We will collect information from clients when we are contacted in respect of a proposed or actual engagement. This includes clients where our appointment is instructed by the Court or Official Receiver. We will collect information such as name, address, telephone number, employment history, family background, financial information. We may also request copies of identification such as passport or driving licence and copy utility bills to comply with regulatory requirements. We may carry out searches of public record such as Companies House. On occasion we may collect sensitive information including health records, nationality or ethnic origin.
Given the nature of some of our assignments i.e. Insolvency appointments we may from time to time be provided information from 3rd parties which is personal in nature. We will typically seek to verify this with you unless to do so would prejudice the outcome of any insolvency process you are involved in or are the subject of.
During the course of our work we may collect personal data on employees, creditors, debtors and other parties who have engaged with our clients. We process this information for the purpose of the engagement and in our duty as an officer of the court (if appointed as an Insolvency Practitioner). This information is held on our systems and in a database; we only use it for the purposes of our engagement/role. From time to time we may engage a 3rd party to assist with this and they are bound by the same standards as RFA and will process any data under our explicit instruction.
RFA do not currently hold a marketing database. If however during the course of our engagement or after we come across something we deem may be relevant to you or of interest we may send it to you. If you ever feel this is inappropriate or do not wish to receive such communications please notify email@example.com.
RFA may obtain personal data from candidates applying for a role advertised or from someone who has provided a CV. When submitting this information or applying you consent to us processing your personal data (this includes information provided in the application or submission and through interview stages). RFA will not share this information with third parties with the exception of any sub-contractor engaged to support the recruitment process. You will be notified of the identity of any 3rd parties engaged in this process. This information is used to assess your suitability for the role and fit with the Company culture. We may seek 3rd party references from parties nominated by you.
Use and processing of data
Data is used to provide the services we are engaged to do or in the case of Insolvency processes as appointed by the Court, Creditors or the Official Receiver. We may process this data in order to comply with our legal, statutory or professional responsibilities. We will need to retain evidence to demonstrate compliance. We use data for our legitimate business interest and do so without prejudicing your interests, rights or freedoms. We may seek consent to use data for particular purposes.
Disclosures of personal data
We do not sell information about current or former clients to third parties. We will not disclose information to third parties other than in the following circumstances:
- You have given consent;
- We consider we are under a legal or regulatory obligation to disclose;
- It is necessary in carrying out our engagement for example communications with creditors, banks, solicitors, grant funding providers, the Insolvency Service, the Court or other advisors;
- Where we are instructing other professionals on your behalf;
- If we are required to enforce the terms of any agreement.
We do not transfer data outside EEA unless necessary in providing our service. This may for example be due to you having dealings with parties in other jurisdictions. Where recipient countries are not recognised to have adequate data protection laws we will take reasonable steps to safeguard your data and protect your privacy rights.
We have appropriate security measures to prevent your personal data being lost, used or accessed in an unauthorised way. We limit access to 3rd parties who have a need to know. All 3rd parties processing personal data do so on our instruction and are subject to confidentiality.
We retain information for as long as necessary to fulfil the purposes for which it was collected. Note in fulfilling our legal obligations or those to our regulatory body we may be required to retain records for up to 6 years after our engagement ceases.
You have rights under data protection laws in relation to the personal data we hold, these are:
- A right to request a copy of personal data held;
- You may request that we update personal data, to correct inaccuracies or omissions;
- You can have a right to request that we delete personal information, note this will only be done if it does not prejudice our legal or regulatory responsibility;
- You may object to us processing your personal information;
- You can request a transfer of your personal information to another person or organisation;
- You have a right to withdraw consent where we rely on it to process personal data.
Rachel Fowler, Rachel Fowler Advisory Ltd, Scottish Provident Building, 7 Donegall Square West, BELFAST. BT1 6JH
firstname.lastname@example.org | 028 9091 2937