The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website comply’s to all UK national laws and requirements for user privacy.
Cookies are small files saved to the users computers hard drive that track, save and store information about the users interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
Other cookies may be stored to your computers hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Contact & Communication
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed in the Data Protection Act 1998. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.
This website and its owners use any information submitted to provide you with further information about the products / services they offer or to assist you in answering any questions or queries you may have submitted. This includes using your details to subscribe you to any email newsletter program the website operates but only if this was made clear to you and your express permission was granted when submitting any form to email process. Or whereby you the consumer have previously purchased from or enquired about purchasing from the company a product or service that the email newsletter relates to. This is by no means an entire list of your user rights in regard to receiving email marketing material. Your details are not passed on to any third parties.
This website operates an email newsletter program, used to inform subscribers about products and services supplied by this website. Users can subscribe through an online automated process should they wish to do so but do so at their own discretion. Some subscriptions may be manually processed through prior written agreement with the user.
Subscriptions are taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions are held securely and in accordance with the Data Protection Act 1998. No personal details are passed on to third parties nor shared with companies / people outside of the company that operates this website. Under the Data Protection Act 1998 you may request a copy of personal information held about you by this website’s email newsletter program. A small fee will be payable. If you would like a copy of the information held on you please write to the business address at the bottom of this policy.
Email marketing campaigns published by this website or its owners may contain tracking facilities within the actual email. Subscriber activity is tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity [this is by no far a comprehensive list].This information is used to refine future email campaigns and supply the user with more relevant content based around their activity.
In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003 subscribers are given the opportunity to un-subscribe at any time through an automated system. This process is detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.
Although this website only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout this website.
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Adverts and Sponsored Links
This website may contain sponsored links and adverts. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.
Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
Shortened Links in Social Media
This website and its owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy url’s [web addresses] (this is an example: http://bit.ly/zyVUBo).
Users are advised to take caution and good judgement before clicking any shortened url’s published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine url’s are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Insolve Plus is a trading style of Insolve Plus Ltd in incorporated in England and Wales no. 08640857 Registered Office: Allan House, 10 John Princes Street, London W1G 0AH
A list of members names is open to inspection at the registered office.
Insolvency Licence Holders
When acting as Administrators or Administrative Receivers our executives act as agents for the relevant company and do so without personal liability.
All Insolvency Practitioners working within the firm are licensed to act as Insolvency Practitioners by the Insolvency Practitioners Association in the United Kingdom.
All Insolve Plus Insolvency Practitioners hold the relevant general bond and professional indemnity insurance cover as required by insolvency legislation.
If a party is not satisfied with any work undertaken by Insolve Plus Limited or its directors or staff they should set out in writing the nature of the complaint and address this to the relevant insolvency practitioner concerned. A copy of the complaints policy will be made available on request. If you are not satisfied with any issues relating to an insolvency practitioner’s regulated work, then you may, at any stage of your complaint, contact the Insolvency Service at https://www.gov.uk/complain-about-insolvency-practitioner. A complainant is encouraged by the Insolvency Service to seek to resolve the complaint with the relevant Insolvency Practitioner prior to submitting a complaint to the Complaints Gateway.
Bribery Act 2010
Insolve Plus Ltd is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on Insolve Plus Ltd’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.
Insolve Plus Ltd take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.
Insolve Plus Ltd requires all those who are associated with it to observe the highest standards of impartiality, integrity and objectivity.
Insolve Plus Ltd prohibits anyone acting on its behalf from:
- bribing another person. A bribe includes the offering, promising or giving of any financial or other type of advantage;
- accepting a bribe. This includes requesting, agreeing to receive or accepting any financial, or another kind of advantage;
- bribing a foreign public official; and
- condoning the offering or acceptance of bribes.
Insolve Plus Ltd will:
- avoid doing business with others who do not accept our values and who may harm our reputation;
- maintain processes, procedures and records that limit the risk of direct or indirect bribery;
- promote awareness of this policy amongst its staff, those acting on its behalf and entities with which it has any commercial dealings;
- investigate all instances of alleged bribery, and will assist the police, and other authorities when appropriate, in any resultant prosecutions. In addition, disciplinary action will be considered against individual members of staff;
- review this policy regularly and update it when necessary.
General Data Protection Regulation – GDPR – Privacy Notice
Use of personal Information
How the law protects you
The law states we must have one or more of these reasons for using your data:
- To fulfil a contract we have with you to provide our services
- Where it is our legal duty
- When it is in our legitimate interest
- When you consent to the use of the data
A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Under the GDPR your rights are:
- To be informed – we must make available this privacy notice with the emphasis on transparency over how we process any personal data
- Access– you are entitled to find out what details we may hold about you and why
- Rectification– we are obliged to correct or update your details
- Erasure of information we hold– also known as the right to be forgotten. You have the right to require us to delete personal data – in certain circumstances
- Restrict processing – you have the right to ‘block’ or suppress the processing by us of personal data
- Data portability– you have the right to obtain and reuse your personal data that you have provided to us in a structured, commonly used and machine-readable format
- Object – you have the right to object to us processing personal data in relation to direct marketing and/or profiling
The data we collect
- Personal data we process may include your (or your employer’s) name, address, date of birth, family relationships and email address and telephone number. We may also process details relating to your employment (including National Insurance Number, salary, pension arrangements, personal tax details etc).The data collection may also include your IP address and cookies (website)
- We may have reason to collect personal data from you in relation to the provision of our services as insolvency practitioners, including your financial details, details relating to your assets, tax affairs, bank accounts, investments, payroll information, accounting records and other statutory returns
- We may require documentary details from you such as a driving licence, passport or birth certificate, in order to comply with our obligations under identification, money laundering and anti-terrorism legislation.
- Our collection methods are:
- via our website;
- through engagement (or potential engagement) of our services;
- by communications, including email, telephone, post or social media;
- through engagement of service providers;
- via third parties and/or publicly available resources (for example from your employer, HMRC or from Companies House, Linkedin profile etc).
- When using our digital services, such as our website or other digital services, we may gather data from you using cookies and other internet tracking software, the purpose of which is to understand how you are using our services, and to provide you with better and enhanced information.
What we use personal data for
We use information held about you to:
- conduct checks to identify clients and verify identity
- provide services to you as set out in a Letter of Engagement between us or where appointed as an Insolvency Practitioner, to fulfil our obligations under statute or regulation including completion of statutory returns
- update and enhance client and contact records
- provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes or by Legitimate Interests
- notify you about changes to our services
- fulfil our legal obligations including money laundering and identification checks, complying with anti-terrorism financing and Criminal Finances Act legislation
- enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen
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.
We also embrace the use of social media and may wish to process any comments made public by you.
How we may use your personal data
Under data protection law, we can only use personal data of we have a proper reason for doing so, e.g.
- to comply with our legal and regulatory obligations when acting as insolvency practitioners
- as part of other services offered to you
- for our legitimate interests, where we have a business or commercial reason to use personal information, so long as an individual’s own rights and interests are protected
- to provide data to other professional advisors who we instruct eg accountants and lawyers, mortgage providers, H M Land Registry in the case of a property transaction or Companies House, banks, employers, insurers or brokers, IT providers (the list is not exhaustive)
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
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.
Under GDPR you have the right to request that under specific circumstances personal data we hold be deleted. A request for this will be decided on a case by case basis and must be submitted in writing to the contact details provided in this policy.
We will correct or update your data at the earliest opportunity provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.
We have put in place commercially reasonable and 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 use it. 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We strive to be as open as we can be in terms of giving people access to their personal data. A Subject Access Request (SAR) under the GDPR is your right to request a copy of the information that we hold about you. SAR requests must be in writing to the contact details provided in this policy. If we do hold your personal data, we will respond in writing within one calendar month of your request (where that request was submitted in accordance with this policy).
The information we supply will:
- confirm that your data is being processed
- verify the lawfulness and the purpose of the processing
- confirm the categories of personal data being processed
- confirm the type of recipient to whom the personal data have been or will be disclosed, and
- let you have a copy of the data in an intelligible form
Please note that you may need to provide identification, in order to prove who you are in order to access your data. If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.
In the instance that we do not hold information about you we will also confirm this in writing at the earliest opportunity.
Withdrawal of consent
Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time. Please inform us immediately if you wish to withdraw your consent. However, please note that:
- The withdrawal of consent does not affect the lawfulness of earlier processing
- If you withdraw your consent, we may not be able to continue to provide services to you
You have the right to complain about the processing of your personal data. Please contact us using the details provided. If you are still dis-satisfied you have the right to complain to the Information Commissioners Office. www. ico.org.uk/concerns