1. GRIFFINS

Griffins are a partnership trading at Tavistock House North, Tavistock Square, London, WC1H 9HR

Kevin Goldfarb and Stephen Hunt are licensed to act as Insolvency Practitioners in the UK by the Institute of Chartered Accountants in England and Wales.

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2. CLIENT ENGAGEMENT

Advice is given and services are provided to clients on the basis of the relevant engagement letter and the firm’s terms of business. By instructing the firm clients confirm their agreement to the firm’s engagement letter and terms of business.

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No responsibility is assumed and no liability is accepted for information supplied or services rendered to someone who is not a client of the firm (including someone using this website) unless in writing we have expressly agreed otherwise. Please do not provide us with confidential, sensitive or legally privileged information before we have carried out a conflict check unless we ask you to do so.

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3. MONEY LAUNDERING OBLIGATIONS

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 require us to conduct due diligence on all new clients and on-going monitoring of all existing clients.

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We are required to verify and document the identity and address of every client of the firm (including the beneficial owner or effective controller of a company or trust and anyone purporting to act on behalf of a client). Sometimes we are able to verify and document the identity of a client through publicly available electronic data sources. If this is not possible, we will ask the client to provide us with the necessary information and documents. Periodically, or if their circumstances change, we may ask a client to provide us with up-to-date evidence of identity. If we are unable to obtain satisfactory evidence of identity, we will not be able to act, or continue acting.

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We are also required to identify the source of all monies that will be paid to or controlled by the firm. We cannot accept funds unless the source has previously been disclosed to us and identified to our satisfaction. If payment is made to us in breach of this legal requirement, the funds may be frozen until their source and provenance has been established. 

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The legislation which governs money laundering, and the financing of terrorism has placed all professional advisers, including Insolvency Practitioners, under a legal duty in certain circumstances to disclose information to the National Crime Agency. Where an Insolvency Practitioner knows or suspects that a transaction involves money laundering or the financing of terrorists, he or she may be required to report their knowledge or suspicion to the National Crime Agency. If this happens, we will not be able to inform you that a disclosure has been made or of the reason for it, for legal reasons. We accept no liability for any loss, damage, costs or expenses that you incur by reason of such disclosure.

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4. BRIBERY, CORRUPTION AND TAX EVASION POLICY

Insolvency Practitioners are bound by the Insolvency Code of Ethics when carrying out all professional work relating to an insolvency appointment. Our firm is committed to carrying on its business fairly, openly and honestly. Our business culture is one where bribery is never acceptable.

We always try to conduct our own business and our clients’ matters in compliance with applicable laws and regulations and to the highest ethical standards. We will never knowingly commit or advise or assist a client or someone acting on behalf of a client to commit, an illegal act, including, without limitation, bribery, corruption or tax evasion.

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We operate policies and procedures which comply with the United Kingdom’s anti-bribery and corruption laws and anti-tax evasion laws. They apply to all firm members and to anyone else who is working for or on behalf of the firm. We expect our own suppliers and the other professional advisers with whom we work from time to time to have similar policies and procedures in place.

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Our policies prohibit the criminal facilitation of tax evasion. They also prohibit, either directly or via a third party, the offering, promising or giving of anything of value for an improper purpose or to gain a business advantage. The prohibition extends not only to financial rewards, but also to gifts, donations and services, and to entertainment of an unusual or excessive nature. Dealings with foreign government officials and other politically exposed people are subject to particular rules.

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5. WARNING ABOUT FRAUDS, SCAMS AND CYBERCRIME

You should be alive to the possibility that a fraudster might for criminal purposes deliberately misrepresent himself or herself as a member of, or as someone acting on behalf of or working with, this firm. Such scams normally originate by email. Often such an email will either promise the recipient a share of a large sum of money in return for paying a modest sum up front (an advance fee fraud) or request personal or financial information about the recipient or the recipient’s bank account allegedly in order that money can be paid to them (an identity theft fraud). In an attempt to give legitimacy or respectability to the scam, sometimes the email will direct the recipient to a false website that intentionally replicates the look of a legitimate website (a cloned website) or without their knowledge or permission use the name of a legitimate organisation or person (including that of an insolvency firm or insolvency practitioner).

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We only practice under the firm name ‘Griffins. If you receive an email or other communication purporting to come from or mentioning a firm which has a similar but not identical name to us, it will not have come from us and will be nothing to do with us. If you receive an email or other communication purporting to come from Griffins or someone holding themselves out as being a member or agent of Griffins, or if you are directed to a website which purports to Griffins’ website, and you have doubts or concerns about the provenance of the email, other communication or website, before taking any action please either contact the firm member you normally deal with or email Client.Services@griffins.net and they will tell you whether the email or other communication came from us or whether it is our website.

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6. COMPLAINTS HANDLING PROCEDURE

Griffins place a high priority on client service and are keen to ensure that the quality of this is maintained. We are committed to providing a professional, fair, efficient and courteous service to all participants in the insolvency process, whether they are creditors, directors, shareholders, bankrupts or debtors.

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In the event that you are dissatisfied with the service you are receiving then we want you to contact us immediately in order that we can and we will try to resolve your complaint.

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In the first instance, please try to resolve your complaint with the individual with whom you have been dealing, or the case manager. It is suggested that the initial approach should be made by telephone as in some cases a simple misunderstanding can be cleared up successfully in this manner.

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In the event that this does not resolve the issues you have raised to your satisfaction then please put your complaint in writing to the duly appointed Insolvency Practitioner, this may be the Liquidator, Trustee, Administrator or Supervisor of the case.

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In order to assist us with dealing with your complaint as quickly and efficiently as possible, your letter of complaint should include as much detail as possible and, in all cases, the following information:

• Your name and address;

• The full name of the insolvency case together with the Court name and number if applicable;

• Copies of any relevant correspondence and documents relating to the complaint;

• The name of the person or persons against whom your complaint is made;

• Full details of your complaint;

• An explanation of how you would like us to resolve your complaint.

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As the process continues, please let us know as soon as possible if your circumstances or expectations change or if any of the information provided with your letter of complaint changes or ceases to become applicable.

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In the unfortunate event that it is not possible for Griffins to resolve your complaint, you can refer the complaint to The Insolvency Complaints Gateway, “www.gov.uk/complain-about-insolvency-practitioner”. The Insolvency Complaints Gateway will review the complaint and decide whether it is appropriate to refer the matter to the partner’s authorising body, The Institute of Chartered Accountants in England and Wales.

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Please note that the Insolvency Service, the body responsible for running the Insolvency Complaints Gateway, encourages a complainant, in the first instance, to attempt to resolve any complaints via the internal complaints process of the firm in respect of which the complaint is being made.

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7. PROFESSIONAL INDEMNITY INSURANCE

Griffins maintains professional indemnity insurance in an amount which exceeds the minimum level of cover required by the Provision of Services Regulations 2009. The policy covers professional services which the firm provides in the United Kingdom and worldwide and it extends to acts or omissions arising out of such services wherever they occur.

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Griffins professional indemnity lead insurer is PartnerRe Ireland via Nexus Underwriting Ltd, 150 Leadenhall Street, London, EC3V 4QT.

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8. ELECTRONIC COMMUNICATIONS

Electronic communication carries with it certain risks. Such communications might not be secure, might be intercepted, might carry viruses, might distort during transmission or might arrive late or not at all. Unless in writing we inform you otherwise, any emails we send to you will not be encrypted.

By using email or fax to communicate with us you consent to us communicating with you in the same manner. Unless in writing you expressly prohibit electronic communication, we may use email and/or fax to communicate with you and others involved in your matter.

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Anyone who communicates with us electronically or who does not expressly prohibit such communication will be assumed to accept the associated risks. We accept no liability for any inadvertent breach of confidence or privilege, or for any loss or damage that occurs, as a result communication by email or fax.

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We use anti-virus software, which is updated regularly, but we accept no liability for viruses. We expect you to use, and to rely on, your own anti-virus software. We recommend that you scan all emails and any attachments for viruses before opening them. We also advise you to confirm any advice received by email before acting on it.

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We monitor electronic communications (including email) in order to protect our business and our clients and to ensure that our legal and regulatory obligations and our internal policies and procedures are being complied with.

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9. DATA PRIVACY NOTICE

Griffins respects your right to privacy. We put in place security measures for your personal data and manage your personal data in accordance with applicable data privacy regulations.

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The principles set out in this Data Privacy Notice apply to all instances in which Griffins receives your personal data as a Data Controller for the purposes described in this notice.

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General Data Protection Regulation (GDPR) 

The GDPR forms part of the data protection regime in the UK, together with the new Data Protection Act 2018 (DPA 2018). The main provisions of this apply, like the GDPR, from 25 May 2018.

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The GDPR is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. It also addresses the transfer of personal data outside the EU and EEA.

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The legislation aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. It focus on the protection, collection and management of personal data, and it applies to all businesses who hold or otherwise process personal data of people in EU Member States.

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Personal Data

Personal data relates to a living individual (data subject) who can be identified from the data or from data and any other information which is in, or likely to come into, the possession of the data controller.

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Sensitive Personal Data

GDPR provides a separate definition for “sensitive personal data”. This relates to information concerning a data subject’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetics, biometrics (where used for ID purposes), physical or mental health, sex life, or sexual orientation.

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The GDPR rules for sensitive (special category) data do not apply to information about criminal allegations, proceedings or convictions.

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Data Controller

A “data controller” is an organisation or a person who (either alone or jointly or in common with other persons) decides the purpose for which any personal data is to be processed and the way in which it is to be processed. For the purposes of the DPA and the GDPR the data controller is Griffins, Tavistock House North, Tavistock Square, London WC1H 9HR.

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Data Processor

A “data processor”, in relation to personal data, means any person (other than an employee of the data controller) who processes the data on behalf of the data controller.

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Use, legal basis, retention periods and sharing of personal data

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Website

We automatically collect data about visitors to our website (for example on browsing patterns) by using cookies (please also see our website cookies policy). This data is used only in an anonymous form to create a statistical report on website activity; no individual is identified.

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We log your Internet Protocol (IP) address in order to receive and send information from and to you over the internet.

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When you register with us, visit our website, use our services or make an enquiry, you may be asked to provide some personal data such as your name, address, telephone number and e-mail address. This personal data may be transferred to the Partnership’s Client Relationship Management (“CRM”) database (see below).

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We only collect such personal data as is provided voluntarily by visitors to our website and is necessary in the circumstances. We will use your personal data only for the purpose for which it was collected and will retain the data only for the period required to deal with your request.

We will not share your data with third parties outside of the Griffins without your prior consent.

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The website contains third party links to other websites over which Griffins have no control. Griffins does not accept responsibility or liability for the operation or content of such websites.

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Telephone Recording

We have a telephone system that is capable of recording conversations. Like many other organisations, this is a standard practice that allows the recording of telephone calls for quality monitoring, training, compliance and security purposes.

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Both incoming and outgoing calls may be recorded by Griffins Staff. Call recording facilities will only be used in the following circumstances

• The people involved in the call have given consent to be recorded

• Recording is necessary for the fulfilment of a contract

• Recording is necessary to fulfil a legal requirement

• Recording is necessary to protect the interests of one or more participants

• Recording is in the public interest, or necessary for the exercise of official authority

• Recording is in the legitimate interests of the recorder, unless those interests are overridden by the interests of the participants in the call

 

We do not record telephone calls routinely or without necessity. Notice that a call is being recorded may not be given if, in the opinion of the staff member recording the call, this has the potential to prejudice the reason why the recording is being made.

 

Personal data collected in the course of recording activities will be:

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• Adequate, relevant and not excessive;

• Used for the purpose(s) stated above and not used for any other purposes;

• Treated confidentially;

• Accessible only by authorised personnel;

• Stored securely;

• Only kept for as long as deemed necessary and securely destroyed

 

We shall ensure that the use of these recordings is fair and that we comply with the requirements of the relevant legislation. This includes:

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• The Regulation of Investigatory Powers Act 2000

• The Telecommunications (Lawful Business Practice) (Interception of Communications Regulations) 2000

• The Telecommunications (Data Protection and Privacy) Regulations 1999

• The General Data Protection Regulation 2018

• The Data Protection Act 2018

• The Human Rights Act 1998.

 

Contact Relationship Management (CRM)

We use a CRM database to store personal data for the purposes of developing relationships with current and prospective clients. Where permitted in our legitimate interest or with your prior consent (where required by law), we use your personal data to provide you with information about events and our services by email, letter, telephone, or using our website.

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If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” you will be added to our suppression list to ensure we do not accidentally send you further marketing information. You can exercise the right at any time to “opt out” of receiving marketing information from us by contacting us at  data.services@griffins.net. We may still need to contact you for administrative or operational purposes, but we will make sure that those communications don’t include direct marketing.

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We never share your name or contact details with third parties for marketing purposes.

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Contract Information and Other Information

We use personal data received in the course of providing professional services in order to perform duties under a contract with you or to take steps to enter into a contract with you, or for the purposes of the legitimate interests pursued by us as a data controller.

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When you enter into a contract with us (or someone does so on your behalf) there will be correspondence with us about the contract and personal data about you relating to that contract such as:

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• Your name and contact details

• Your delivery address

• Your payment details

• Information to verify your identity and other information for us to carry out anti money laundering checks

 

You must provide this in order to enter into a contract with us (or as required under that contract), if you do not, we may not be able to carry out our contract with you.

 

Other correspondence or interaction (for example by email, telephone, post or via our website) between you and us, may include personal data, such as enquiries, reviews, follow-up comments or complaints lodged by or against you and disputes with you or your organisation.

 

We may also collect details of phone numbers used to call us and the date, time and duration of any calls. Please note that we may record calls to or from in line with the section on Telephone Recording.

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Where your information relates to a contract, it is kept for a period of up to 7 years after your account is closed to enable us to deal with any enquiries or claims and as required for tax purposes. Any contract information is kept for reference purposes in our archive for as long as our business purpose requires.

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Employee Information

If we have a business relationship with you or your organisation, we may receive personal data about you from your organisation.

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The personal data we collect about you may include your contact information, details of your employment and our relationship with you. This information may be collected directly from you, or provided by your organisation. Your organisation should have informed you that your information would be provided to us, and directed you to this policy. We use this as necessary for our legitimate interests in managing our relationship with your organisation.

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Information Collected At Our Premises

We use personal data as necessary for our legitimate interests in administering your visit, ensuring site security and visitor safety, and administering parking.

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We may record information on your visit, including the date and time, who you are visiting, your name, employer, contact details and vehicle registration number. If you have an accident at our premises, this may include an account of your accident. Visitor information is kept for a period of up to 12 months. If you have an accident on our premises, our accident records are retained for a period of up to 3 years.

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We operate CCTV at our premises which may record you and your activities. We display notices to make it clear what areas are subject to surveillance. We only release footage following a warrant or formal request from law enforcement agency, or as necessary in relation to disputes. CCTV recordings may be kept for a period of up to 35 days (unless there an incident occurs and it is necessary for us to keep recordings for longer to properly deal with it).

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Job Applicants

We will collect and hold personal data on job applicants, including information you provide to us in your application, or provided to us by recruitment agencies, as well as personal data from any referees you provide. We use this as necessary to enter into an employment contract with you, and for our legitimate interests in evaluating candidates and recording our recruitment activities, and as necessary to exercise and perform our employment law obligations and rights.

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You must provide certain information (such as your name, contact details, professional and educational history) for us to consider your application fully. If you have not provided all of this information, we may contact you to ask for it. If you do not wish to provide this information, we may not be able to properly consider your application.

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If you are successful in your application, your information will be used and kept in accordance with our internal employee privacy notice. If you currently work for us, or used to work for us, you can request a copy of this from us. If you are not successful in your application, you information will be held for up to 12 months after the hiring decision.

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If you are listed as a referee by an applicant, we will hold your name, contact details, professional information about you (such as your employer and job title) and details of your relationship with the applicant. We will use this information as necessary for our legitimate interests in evaluating candidates and as necessary to exercise and perform our employment law obligations and rights. Your information will be kept alongside the applicant’s information.

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If you are listed as an emergency contact by someone who works for us, we will hold your name, contact details and details of your relationship with that worker. We will use this to contact you as necessary to carry out our obligations under employment law, to protect the vital interests of that worker, and for our legitimate interests in administering our relationship with that worker. Your information will be kept until it is updated by that worker, or we no longer need to contact that worker after they have stopped working for us.

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Legal Claims

Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal data as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. How long we keep this information for will depend on the nature of the claim and how long we consider there to be a risk that we will need to defend or bring a claim.

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Insolvency Appointments

In the UK, only a licensed Insolvency Practitioner (IP) can be appointed in relation to formal insolvency procedures for individuals and corporate entities. IP’s are licensed to provide advice on, and undertake appointments in, all formal insolvency procedures.

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The functions of an IP are governed by:

• The Insolvency Act 1986 (as amended)

• The Insolvency Rules 2016 (as amended)

• The Insolvency Practitioners Regulations 1990

• The Insolvency Practitioners Regulations 2005

• The Insolvency Practitioners (Amendment Regulations) 2015

• The Insolvent Companies (Report on Conduct of Directors) (England and Wales) Rules 2016

• The Insolvent Companies (Report on Conduct of Directors) (Scotland) Rules 2016

• The Small Business, Enterprise and Employment Act 2015 (as amended)

• The Deregulation Act 2015

• The Provisions of Services (Insolvency Practitioners) Regulations 2009

• The Insolvent Partnership Order 1994

• The Insolvency Amendment (EU 2015/848) Regulations 2017

• The Insolvency (Regulations (EU) 2015/848) (Miscellaneous Amendments) (Scotland) Regulations 2017

• Statements of Insolvency Practice

 

In carrying our duties as IP’s we collect and uses personal data in order to:

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• Provide professional advice to try to prevent insolvency

• Negotiate with the creditors, and other parties, of a company or individual

• Realise the assets of an individual or company for the best possible return to creditors after marketing to a wide range of potential buyers

• Carry out all statutory duties as required by law

• Provide regular reports to creditors on the progress of insolvency procedures

• Investigating company affairs and director conduct, where necessary, and file a report to the Insolvency Service.

 

The personal data we control will include your name, email address, postal address, telephone number, date of birth and financial details. The precise nature of personal data we hold will be dependent upon the unique circumstances of the case, but may include (although not limited to) Griffins acting as the data controller in respect of:

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• Investigations undertaken as a consequence of:

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017(MLR 2017)

  • The Bribery Act 2010

  • Proceeds of Crime Act 2002

  • The Terrorism Act 2000, and related anti-terrorism legislation

  • The Criminal Finance Act 2017

  • Company Directors Disqualification Act 1986

• Conflict and Ethical checks

• Case file notes

• Internal meeting notes

• Diary entries

• Bank and Credit / Debit card records

• Case management reviews

• Correspondence with third parties

• Correspondence with employees

• Correspondence with shareholders

• Correspondence with former office holders (IP’s)

• Correspondence with clients / debtors / directors and other individuals

• Personal asset searches

• Land Registry searches

• Books and Records (Including Tax and VAT records)

• Debtor / Director Questionnaire

• Income Payment Agreements / Income Payment Orders

• Bankruptcy Restriction Orders

• Asset searches

• Agent Reports and Valuations

• Legal documents

• Dividend Notices

• Pension Notices

• PPI documentation

• Creditor Proxies

• Reports to creditors and members

• Meeting attendance registers

• Creditor claims and proofs of debt

• Creditor committees

• Creditor correspondence

• DVLA searches

• Mortgage records

• Insurance policies

• Medical records

• Family records

• Employment records

• Case time recording

 

The legal basis on which we process personal data when acting as data controller on insolvency appointments will be dependent upon the unique circumstances of the case, but will include at least one of the following:

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• A legal obligation to which the Data Controller is subject;

• The performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;

• For the purposes of the legitimate interests pursued by a Data Controller;

• The establishment, exercise or defence of legal claims.

• Processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;

• Processing relates to personal data which are manifestly made public by the data subject;

• Processing is necessary for reasons of substantial public interest.

 

We will keep your personal data for no longer than reasonably necessary. However, The Insolvency Practitioners Regulations 2005 (as amended) require us to preserve records until the later of:

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• The sixth anniversary of the date of the grant to the insolvency practitioner of his release or discharge in that case; or

• The sixth anniversary of the date on which any security or caution maintained in that case expires or otherwise ceases to have effect.

 

This data is retained to show and explain:

• The work the insolvency practitioner and their staff undertake in the course of the ‘administration’ of an insolvency appointment; and

• The decisions that may ‘materially affect’ the appointment.

 

We adopt the Insolvency Practitioners Regulations 2005 (as amended) as our policy for the retention of all personal insolvency data retained by an IP in the course of conducting their duties.

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Insolvency Books and Records

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• Trustee in Bankruptcy

The IP will seek authorisation from the Official Receiver for permission to destroy all books and records 12 months after the IP’s release from office, subject to there being no historical value, legal requirement or other specific reason to retain a document for a longer period.

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• Liquidator

An IP acting as a liquidator is not a data controller within the meaning of s 1(1) of the DPA in respect of the data processed by a company prior to its liquidation. All rights relating to the control of data belonging to, or being controlled by a company at the time it entered into liquidation remains vested in the company at and following its liquidation.

The IP will seek permission from the Official Receiver on Compulsory Liquidations to destroy all books and records 12 months after the IP’s release from office, subject to there being no historical value, legal requirement or other specific reason to retain a document for a longer period.

Where an IP is appointed as Liquidator in a Creditor Voluntary Liquidation the IP will destroy all books and records 12 months from the date of dissolution, subject to there being no historical value, legal requirement or other specific reason to retain a document for a longer period.

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• Administrator

The powers of an IP acting as an Administrator are set out in Schedule B1 of the Insolvency Act 1986. The administrator of a company may do anything necessary or expedient for the management of the affairs, business and property of the company. Paragraph 69 of Schedule B1 states that in exercising their powers, the administrator is deemed to act as the company’s agent. An Administrator is not therefore a data controller within the meaning of s 1(1) of the DPA, in respect of the data processed by a company prior to their appointment.

Where an IP is the last administrator of a company which has been dissolved the IP will destroy all book and records 12 months from the date of dissolution, subject to there being no historical value, legal requirement or other specific reason to retain a document for a longer period.

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• Administrative Receiver (“Receiver”)

Where an IP is appointed as a Receiver they are deemed to act as the company’s agent and are not a data controller within the meaning of s 1(1) of the DPA, in respect of the data processed by a company prior to their appointment.

All books and records will either be returned to the company’s directors or if the company is in liquidation, to its liquidator when the receiver ceases to act.

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• Supervisor of voluntary arrangement

An IP acting as the supervisor of a voluntary arrangement is charged with supervising the implementation of a proposal for a composition in satisfaction of the company’s / individuals debts or a scheme of arrangement of its affairs. The terms of each particular proposal will determine the extent to which it will impose responsibilities upon them under the DPA.

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How Long We Keep Your Information For?

We have set out above indications of how long we generally keep your personal data. In some circumstances, it may be necessary to keep your information for longer than that in order to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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

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In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

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Sharing personal data

We will not share your data with third parties outside of Griffins unless we are obliged to do so, by law, or we have an appropriate legitimate interest in doing so, for example where personal data is required by an agent or solicitor who has a case related need to know the information.

All third parties with whom personal data is shared will have agreed to comply with our required data security standards, policies and procedures and put adequate security measures in place. All third party transfers will comply with applicable cross border transfer restrictions.

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Data Security

As well as the measures set out above in relation to sharing of your personal data, we have security measures in place designed to prevent data loss, to preserve data integrity, and to regulate access to personal data.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.

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Your rights

Where we act as the Data Controller, you have the following rights with respect to your personal data:

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• The right to be informed about the collection and use of your personal data;

• The right to access your personal data and supplementary information;

• The right to request that we corrects any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary for us to retain such data;

• The right to withdraw your consent (where consent has been obtained) to the processing at any time;

• The right to data portability, allowing you to obtain and reuse your personal data for your own purposes across different services. The right of data portability only applies:

  • to personal data an individual has provided to a controller;

  • where the processing is based on the individual’s consent or for the performance of a contract; and

  • when processing is carried out by automated means.

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to the processing of personal data, (where applicable);

• The right to lodge a complaint with the Information Commissioners Office

 

Changes to this Data Privacy Notice

We reserve the right to change this Data Privacy Notice at any time without notice to you so please check back regularly to obtain the latest copy of this Privacy notice. We last revised this Data Privacy Notice on 22 November 2019.

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This Data Privacy Notice does not override any applicable national data privacy laws and regulations in countries where Griffins operates.

 

Contact Details

To exercise all relevant rights, queries of complaints or to remove your information from our system, please contact the data privacy team at data.services@griffins.net or by telephone 03330 416 250.

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You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

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10. WEBSITE COOKIES POLICY

A cookie is a small file which is placed on your computer’s hard drive and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We only use cookies to monitor the performance of our website, to improve user experience and to provide information about usage of our site (including Google Analytics _utma, _utmb, _utmc, _utmz, which stores information used by Google Analytics to track user activity on the site).

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A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. We only use this information for statistical analysis purposes and then the data is removed from the system.

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There are two types of cookie you may encounter when using this website:

• First party cookies: these are our own cookies, controlled by us and used to provide information about usage of our site.

• Third party cookies: these are cookies found in other companies’ internet tools which we are using to enhance our site, for example Facebook or Twitter have their own cookies, which are controlled by them.

 

While we will endeavour to keep the list of Cookies we use above updated, the Griffins site relies on many third party services and the list may therefore become out of date if those services alter the cookies they use.

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Please note that all of these Cookies exist to enable functionality on the website and not for advertising purposes. If you do not wish these cookies to be tracked you can disable them in your browser, but this may negatively affect your experience on the site.

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Web browsers allow you to control cookies stored on your hard drive through the web browser settings. To find out more about cookies, including what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

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11. TERMS OF USE OF THIS WEBSITE

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Information about this website:

This website is owned and operated by Griffins, who are an Insolvency Practitioners authorised and regulated by the Institute of Chartered Accountants in England and Wales.

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Application and amendment of these website terms:

Use of this website does not create a client-Insolvency Practitioner relationship and is subject to the terms and conditions set out in this policy. These terms of use must be construed, and may be relied on and enforced, independently of each other. We may alter the terms of use at any time by publishing new terms on this website, following which all use of the website will be governed by the new terms. You should check this page from time to time and take note of any changes we make, as they will be legally binding on you.

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Exclusions of liability:

Whilst we believe, and have taken reasonable measures to ensure, that this website is free of viruses, use of the website is at your own risk. All liability for loss or damage arising from your use of this website is excluded to the extent permitted by law. Whilst we have taken reasonable care to ensure that the content of this website and the publications on it is accurate and complete, the information on this website and in those publications is for information only and does not constitute professional advice. All liability for loss or damage arising from reliance on such information is excluded to the extent permitted by law.

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Intellectual property rights:

Copyright in (and any other intellectual property rights that attach to) the content of this website or the publications on it (including, without limitation, the ‘Griffins’, marks, logos and branding) is owned by Griffins. You may download and temporarily store pages from this website for the sole purpose of viewing them. You may print any publication on this website so long as it is a complete copy, no amendment is made to it and it is only for personal use or use within your own organisation. None of the content of this website or the publications on it, whether or not permission is granted for downloading, printing or circulation, may be used for the purpose of commercial exploitation. Any other copying, transmission, distribution or storage of such content is prohibited without Griffins prior written consent.

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Publications:

The publications on this website provide general information only. They must not be relied on as legal or professional advice. The information they contain might not be appropriate for your matter or circumstances. Users located abroad should also be aware that laws and regulations may be different outside England and Wales. Before you act or omit to act, you should take specific advice on any particular matter that concerns you. If you require any advice, please contact us.

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Electronic links:

Electronic links to this website are prohibited without the prior written consent of Griffins. Any links to other websites provided by this website have been included for convenience only. Such links do not imply endorsement by Griffins of the linked website, its provider or its content. We accept no liability for the content of, or for any loss or damage caused by access to, use of, reliance on or software downloaded from, any linked website.

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Governing law:

All issues relating to this website, the content of this website and the content of any publication published on this website are governed by English law. Unless Griffins elects otherwise, any dispute relating to such matters shall be subject to the exclusive jurisdiction of the English courts.

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Accessibility:

We are committed to promoting equality of opportunity and respect for diversity in employment, in our dealings with clients and others and in the way in which we deliver our services. This website is designed to be accessible to as many users as possible by meeting or exceeding the requirements of current United Kingdom accessibility legislation and internationally accepted guidelines.

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Inaccuracies and corrections:

We endeavour to keep your information as accurate and update to date as possible. If your information changes or you are made aware of any errors or inaccuracies, please contact us on client.services@griffins.net

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Other matters:

Please note this site contains links to other sites which are not governed by this privacy statement.

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Assistance:

If you experience any technical or other issues with this website, please email our enquries team on client.services@griffins.net