WHO WE ARE
Clear Path Insolvency Limited collects, uses and is responsible for certain personal information about you. When we do, we are regulated under the Data Protection laws which apply to this jurisdiction including but not limited to the Data Protection Act 2018 and we are responsible as “controller” of that personal information for the purposes of those laws.
OUR INFORMATION COMMISSIONS’ OFFICE (ICO) REGISTRATION NUMBER
Clear Path Insolvency Limited is registered with the Information Commissioners Office (ICO) registration number ZB492990.
THE PERSONAL INFORMATION WE COLLECT AND USE
The personal data we collect from you in the course of advising you may comprise of, but is not limited to, the following Information collected by us:
- Personal information via telephone and website enquiry; or face to face meeting
- Website usage information from cookies.
- Credit reference agencies.
The personal information we collect includes;
- Name (including former names), address and all contact details.
- Date of birth.
- The number and age of any dependents.
- Your current and any former marital status.
- Your current and any former residential property occupation and ownership.
- Your current and former employment details.
- Your involvement in any form of business including any Limited Company or Partnership.
- Your current and historical banking arrangements, and transactions
- Your current and historical assets position including disposals of assets.
- Your current and historical liabilities to creditors.
- Your current income and expenditure.
- Your current status in terms of any ongoing legal proceedings.
- Your information and explanations in relation to your becoming insolvent and any steps that you have taken to deal with such insolvency.
- Any information provided to us by authorised third parties such as partners; civil partners spouses friends or relatives who may be assisting you and us in the provision of our insolvency services to you.
- Your current and historical tax affairs.
- Any other information we may need in order to assist you in advising you on seeking to find, finding, proposing and/or implementing a debt solution to your debt situation.
HOW YOUR PERSONAL DATA IS COLLECTED
We collect this information from you in a variety of communication mediums including but not limited to telephone, e-mail, post, in person or through our websites.
We may collect information from publicly accessible sources such as the Insolvency Service Register (or equivalent); Companies House; HM Land Registry and credit reference agencies.
We may collect information from private accessible sources with your verbal or written permission.
We may also collect information from authorised third party case management; document management and e-mail systems.
HOW AND WHY WE STORE AND USE YOUR PERSONAL INFORMATION
Under Data Protection law, we can only store and use your personal data if we have a proper reason for doing so.
We use your personal information:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract; or
- For our legitimate interests or those of a third party.
We use your personal data primarily to provide services to you but also for related purposes including:
- Conducting any necessary checks to identify you, verify your identity and screen for financial or other sanctions.
- Gathering and providing information required by or relating to audits, enquiries, and investigations by regulatory bodies.
- Complying with professional, legal, and regulatory obligations that apply to our business.
- Ensuring business policies are adhered to e.g., policies covering security and internet use.
- Operational reasons, such as improving efficiency, training, and quality control.
- Statistical analysis to help us manage our practice. (e.g. in relation to financial performance, client base, work type and other efficiency measures)
- Preventing unauthorised access and modifications to systems.
- Preparing and filing statutory returns.
- Staff administration and assessments, monitoring staff conduct and disciplinary matters.
- Marketing our services.
- Any necessary credit reference checks via external credit reference agencies.
- External required audits and quality checks e.g. Lexcel, ISO or Investors in People accreditation.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We will routinely share your personal information with:
- The Insolvency Service or equivalent in any other jurisdiction for registration of an approved IVA or other debt solution in any jurisdiction.
- Our case management system software providers to enable your case to be stored and maintained on our case management system.
- Our insurers and auditors.
- Our legal representatives or other claims representatives or agents who need your personal information to assess and if appropriate pursue, any legal or other claims as part of our services to you.
- Our bonders where we are required to register any debt solution and pay a bonding fee.
- Your Creditors where the need arises.
- The Courts Service where the need arises.
- Bailiffs and other enforcement officers where the need arises.
- Any third party who you authorise to deal with us in both providing and being party to your personal information such as partners; civil partners spouses friends or relatives who may be assisting you and us in the provision of our insolvency services to you.
- Law enforcement agencies; government agencies or our professional regulatory body where we are required to do so.
- Any third party we need to share your personal information with, in order to advise you, propose for you or implement any debt solution for you.
- Any third party who, with your verbal or written permission, you authorise us to pass your Personal Data to, such as parties who may be able to assist you with your debt situation where we are unable to help you.
This data sharing enables us to perform our insolvency services to you under the terms of the contract between us.
We may also need to share some personal data with other parties regarding our business. Usually, such information will be anonymised, but this may not always be possible. The recipient of any such information will be bound by confidentiality obligations.
WHETHER INFORMATION HAS TO BE PROVIDED BY YOU AND IF SO WHY
In order for us to carry out the services to you in a full and comprehensive manner; we need you to provide all required personal information.
This Personal Data is required by us to enable us to provide our service to you. If you do not provide the Personal Data we ask for; this may delay or prevent us from being able to provide our service to you.
HOW AND IN WHAT FORM IS YOUR PERSONAL DATA HELD
Information and data may be held at various locations and on various mediums including our offices; by authorised third parties, service providers connected to our services to you; in our e-mail systems; storage providers of our files; accounts and case management systems.
HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will hold the information identified above for longer of the period that we are required to retain this information by applicable UK Tax Law (currently 6 years) and the period for which we are required by the regulator of our insolvency services, to retain a copy of your file containing such information. This is normally 6 years from completion of your matter.
REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
TRANSFER OF YOUR INFORMATION OUT OF THE EEA
We will only send your data outside of the European Economic Area (EEA) where it is necessary to service your agreement utilising one of our outsourcing partners.
If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
- Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website.
Under Data Protection law you have a number of important rights free of charge. In summary, those include rights to:
- Fair processing of information and transparency over how we use your personal information.
- Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address.
- Require us to correct any mistakes in your information which we hold.
- Require the erasure of personal information concerning you in certain situations.
- Receive the personal information concerning you which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit such data to a third party in certain situations.
- Object at any time to processing of personal information concerning you for direct marketing.
- Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
- Object in certain other situations to our continued processing of your personal information.
- Otherwise restrict our processing of your personal information in certain circumstances.
- Claim compensation for damages caused by our breach of any Data Protection laws.
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individual’s rights on the website for the Information Commissioner’s Office.
If you would like to exercise any of those rights, please:
- E-mail, call or write to the Data Protection Officer, at the e-mail address email@example.com; by calling 01615232860 or by writing to; Compliance, Clear Path Insolvency Limited, 128 City Road, London, EC1V 2NX.
- Let us have enough information to identify you (your name and address).
- Let us have proof of your identity (photo ID of your passport or driving licence with separate recent utility bill).
- Let us know the information to which your request relates.
If you would like to unsubscribe from any marketing including SMS and e-mail alerts you should make contact via the methods described immediately above. It may take up to 48 hours for this to take place.
KEEPING YOUR PERSONAL INFORMATION SECURE
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your Personal Data will do so only in an authorised manner and are subject to the duty of confidentiality.
We also have procedures in place to deal with any suspected data breach. We will notify you and any applicable regulator of a suspected data breach where we are legally required to do so.
If you want detailed information from “Get Safe Online” on how to protect your personal information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org Get Safe Online is supported by HM Government and leading businesses.
COOKIES USED FOR MARKETING
We use Google for paid advertising. When you visit this site by that channel, a cookie is stored on your device (subject to your privacy settings), which allows us to re-target you with ads once you leave this site and visit other websites which use Google to display ads. You may opt-out of this method of advertising from Google – visit https://policies.google.com/technologies/ads?hl=en-GB&gl=uk
HOW TO COMPLAIN
We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your personal information.
Data Protection law also gives you the right to lodge a complaint with a supervisory authority, in particular, in the European Economic Area state where you work; normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns/ or telephone 0303 123 1113.
CHANGES TO THIS PRIVACY NOTICE
HOW TO CONTACT US
If you wish to contact our Data Protection Officer; please send an e-mail to to firstname.lastname@example.org ; write to us at our registered office noted on our stationery or call 0161 523 2860.
DO YOU NEED EXTRA HELP?
If you would like this notice in another format (for example, audio, large print, braille; please contact our Data Protection Officer).