Privacy Policy
The following information is provided to comply with the requirements of the General Data Protection Regulation and sets out how Smart Insolvency Solutions Ltd uses and protects any information that you provide.
The policy is subject to change, from time to time, and as such we would recommend that you periodically review this page to ensure that you are apprised of, and happy with, any updates made.
This policy is effective from 21 August 2018.
The Data Controller
Insolvency Appointments
Where Colin Nicholls and/or Andrew Shackleton, Insolvency Practitioners of Smart Insolvency Solutions Ltd, are appointed as office holder/s and the data processed is done so as part of their statutory duties, the office holder/s are the data controllers.
Smart Insolvency Solutions Ltd’s Insolvency Practitioners may be contacted by:
Non-Insolvency Engagements
In relation to engagements where an Insolvency Practitioner is not appointed as an office holder, the data controller is the company or individual on whose instructions Smart Insolvency Solutions Ltd is acting.
Smart Insolvency Solutions Ltd may be contacted by:
Jon Lewis, Director of Smart Insolvency Solutions Ltd acts as its data controller.
How your personal data is collected and used
Smart Insolvency Solutions Ltd is committed to ensuring your personal data is protected and would only use the same when permitted to by law. The most common reasons for which your data may be used include to:
Where Smart Insolvency Solutions Ltd has been engaged to provide a service, it will be necessary to process data to provide the service in accordance with the contractual terms.
Personal Data
Any reference in this policy to either personal data or personal information refers to information about an individual which allows for that person to be identified.
The types of personal data we hold
In the ordinary course, information that we hold will include:
We do not collect any Special Category Data, as a matter of course; however during the course of an insolvency appointment, the office holders may hold Special Category Data that is required to administer the case in line with their statutory obligations.
For more information in relation to Special Category Data, please visit –
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data/.
Personal Data Disclosure Requirements
Personal data disclosed to third parties is done so in the strictest confidence and we request that the information is treated in accordance with the law.
At times it may be necessary for us to disclose your information to any/all of the following:
We do not give authority for third party service providers to use your personal data for their own interests.
Length of Data Retention
Information is retained for as long as necessary to fulfil the purpose for which it was collected.
In any event, for tax purposes, it is necessary for us to keep client information for six years after such time as they cease to be a client.
Access To Personal Data (Data Subject Access Request)
You are able to request access to the personal data held by the data controller. To make such a request, please contact the relevant data controller/s as detailed above.
All requests will be dealt with within 28 days of receipt.
Withdrawal of Consent
If there is no reasonable reason for your data to continue to be processed, you are able to request that it be deleted from our records. For example, if you no longer wish to receive notification of upcoming events.
In some instances, personal data received was not given as a result of your consent to do so and as such, your right of withdrawal does not apply.
In the event that there is a legal reason which prevents us from dealing with your erasure request, you will be notified accordingly.
Updates To Personal Information
In the event that you wish to update personal data that you have provided to Smart Insolvency Solutions Ltd, please submit this by email to [email protected].
Complaints Regarding Use of Personal Data
In the event that you wish to complain about the use of your personal data, please contact the relevant data controller, using the contact details provided above.
Furthermore, you also have the right to complain to the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/).
The following information is provided to comply with the requirements of the General Data Protection Regulation and sets out how Smart Insolvency Solutions Ltd uses and protects any information that you provide.
The policy is subject to change, from time to time, and as such we would recommend that you periodically review this page to ensure that you are apprised of, and happy with, any updates made.
This policy is effective from 21 August 2018.
The Data Controller
Insolvency Appointments
Where Colin Nicholls and/or Andrew Shackleton, Insolvency Practitioners of Smart Insolvency Solutions Ltd, are appointed as office holder/s and the data processed is done so as part of their statutory duties, the office holder/s are the data controllers.
Smart Insolvency Solutions Ltd’s Insolvency Practitioners may be contacted by:
- Address at 1 Castle Street, Worcester, WR1 3AA;
- Telephone on 01905 888 737; or * Email to [email protected].
Non-Insolvency Engagements
In relation to engagements where an Insolvency Practitioner is not appointed as an office holder, the data controller is the company or individual on whose instructions Smart Insolvency Solutions Ltd is acting.
Smart Insolvency Solutions Ltd may be contacted by:
- Address at 1 Castle Street, Worcester, WR1 3AA;
- Telephone on 01905 888 737; or * Email to [email protected].
Jon Lewis, Director of Smart Insolvency Solutions Ltd acts as its data controller.
How your personal data is collected and used
Smart Insolvency Solutions Ltd is committed to ensuring your personal data is protected and would only use the same when permitted to by law. The most common reasons for which your data may be used include to:
- communicate with you by post, email or telephone;
- provide you with information which you have either requested or that we consider may be of interest/assistance to you;
- contact you to discuss your requirements in relation to the provision of advice that may be required;
- request that a third party advisor contact you if we feel it necessary to assist with your enquiry;
- comply with any legal or regulatory requirements;
- maintain the accuracy of records;
- carry out our obligations arising from any contracts entered into between you and Smart Insolvency Solutions Ltd; and/or
- notify you of changes to our website and/or services.
Where Smart Insolvency Solutions Ltd has been engaged to provide a service, it will be necessary to process data to provide the service in accordance with the contractual terms.
Personal Data
Any reference in this policy to either personal data or personal information refers to information about an individual which allows for that person to be identified.
The types of personal data we hold
In the ordinary course, information that we hold will include:
- Identification data (title, first names, surname, date of birth, gender)
- Contact information (address, telephone number, email address)
- Financial information (bank account details)
- Marketing data (preferences regarding information which we send to you)
We do not collect any Special Category Data, as a matter of course; however during the course of an insolvency appointment, the office holders may hold Special Category Data that is required to administer the case in line with their statutory obligations.
For more information in relation to Special Category Data, please visit –
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/special-category-data/.
Personal Data Disclosure Requirements
Personal data disclosed to third parties is done so in the strictest confidence and we request that the information is treated in accordance with the law.
At times it may be necessary for us to disclose your information to any/all of the following:
- Third party professional advisors (e.g. solicitors)
- Third party organisations that provide us with a service or information (e.g. external IT support provider)
- Law enforcement or other government agencies.
We do not give authority for third party service providers to use your personal data for their own interests.
Length of Data Retention
Information is retained for as long as necessary to fulfil the purpose for which it was collected.
In any event, for tax purposes, it is necessary for us to keep client information for six years after such time as they cease to be a client.
Access To Personal Data (Data Subject Access Request)
You are able to request access to the personal data held by the data controller. To make such a request, please contact the relevant data controller/s as detailed above.
All requests will be dealt with within 28 days of receipt.
Withdrawal of Consent
If there is no reasonable reason for your data to continue to be processed, you are able to request that it be deleted from our records. For example, if you no longer wish to receive notification of upcoming events.
In some instances, personal data received was not given as a result of your consent to do so and as such, your right of withdrawal does not apply.
In the event that there is a legal reason which prevents us from dealing with your erasure request, you will be notified accordingly.
Updates To Personal Information
In the event that you wish to update personal data that you have provided to Smart Insolvency Solutions Ltd, please submit this by email to [email protected].
Complaints Regarding Use of Personal Data
In the event that you wish to complain about the use of your personal data, please contact the relevant data controller, using the contact details provided above.
Furthermore, you also have the right to complain to the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/).