PURPOSE OF THIS NOTICE
SKSi are committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of data protection legislation and regulations including Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) (PECR), and General Data Protection Regulation ((EU) 2016/679) (“GDPR”), which came into effect on 25 May 2018 (“Data Protection Legislation”), and any applicable national laws, regulations and secondary legislation in the UK relating to the processing of personal data and the privacy of electronic communications, as amended, replaced or updated from time to time.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
SKSi is a company incorporated and registered in England & Wales (Reg:09342312) and is a registered member of the Institute of Chartered Accountants in England & Wales (ICAEW).
Insolvency Practitioners acting as administrators contract as agents of the company in administration and without personal liability.
M R Phillips - J A Swan – S Talby – S Hamilton are licensed to act as insolvency practitioners in the UK by The Institute of Chartered Accountants in England and Wales and is subject to the ICAEW Code of Ethics.
C A James is licensed to act as an insolvency practitioner in the UK by The Insolvency Practitioners Association and is subject to the IPA Code of Ethics.
We are a Corporate Recovery & Insolvency practice and for the purpose of the Data Protection Legislation and this notice, we are a ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you and we are required, under the Data Protection Legislation, to notify you of the information contained in this privacy notice.
We are registered as a data controller with the Information Commissioners Office (“ICO”) as follows:
|P C Recoveries Ltd||ZA042560|
|PCR (London) LLP||Z2891559|
|PCR (Bristol) LLP||ZA218197|
In addition to our firm’s registration, the following individuals are also registered with the ICO as data controllers:
|Insolvency Practitioner||Registration No.|
Should you require any further details regarding this privacy notice or our treatment of personal data, please contact our data protection manager, Julie Swan.
WHAT DATA DO WE COLLECT AND HOLD?
When conducting business with our firm we will need to collect information from you in order to provide you with our services.
The categories of your personal data that we may collect includes, but is not limited to, the following:
- Contact details (including names, postal addresses, email addresses and telephone numbers) ;
- Professional information such as company name and number of employees;
- Details of your visits to this web site including, but not limited to, traffic data, location data, weblogs and other communication data.
If you contact SKSi through this website we will ask you for basic information outlining details relating to your situation.
Sensitive personal data includes gender, race or ethnic origin, political opinions, religious or other beliefs, trade union membership, physical or mental health, sexual life or criminal records. We do not solicit sensitive personal data through the Site.
We understand the importance of protecting children's privacy especially in an online environment. This Site is not intentionally designed or directed at children 13 years of age or younger.
The information we hold about you may include the following:
- your personal details (such as your name and/or address) as above;
- details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you make to us;
- information from research, surveys, and marketing activities;
- information we receive from other sources, such as publicly available information, information provided by your employer OR our clients or information from our member network firms.
HOW IS THE DATA COLLECTED?
Your personal data may be collected by us in a number of ways, including:
- through our provision of services to you;
- during the course of dealings with you;
- when you provide information to us by filling in forms on this web site (e.g. information provided at the time of registering for newsletters on this web site, or when completing the priority enquiry form;
- when you contact us for these and any other reason, we may monitor and keep a record of that correspondence (in whatever form) ;
- when we collect publicly available information about you or your business (including through electronic data sources) ; and
- when we collect your personal data from third parties (e. g. our clients or other financial institutes).
SECURITY AND RETENTION OF DATA
We are committed to ensuring that your information is secure. For this purpose, we will not hold your personal data for any longer than is reasonable. Further, we have taken reasonable steps to protect your information against unauthorised access and against unlawful processing, accidental loss, damage and destruction. Nevertheless, any personal data submitted by you is at your own risk.
We will not transfer your personal details to any third party for the purpose of direct marketing without your permission. We use certain third party service providers who may have access to your personal data so that they can provide services to us. When this occurs, we have a data protection compliant contract in place with these third parties. If you provided your details through our website then Moore Legal Technology who manages our online strategy will have access to your details.
Cookies are small files saved to the user’s computer’s that track, save and store information about the user’s 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 onto their device they can block all our cookies using the cookie control system that is shown in the cookie permission bar at the base of the website that is made available upon their first visit. If users wish to subsequently amend their cookie choices at any time, they can do so using the buttons underneath the table shown below.
MEASURING WEBSITE USAGE
We use Google Analytics software to collect information about how you use this website. We do this to help make sure the site is meeting the needs of its users and to help us make improvements.
Google Analytics stores information about:
- the pages you visit
- how long you spend on each page
- how you got to the site
- what you click on while you’re visiting the site
We don’t collect or store your personal information (for example your name or address) so this information can’t be used to identify who you are. We don’t allow Google to use or share our analytics data.
SHARING YOUR DATA
We do not sell, rent or exchange your private personal information with any third party for marketing or any other commercial reason.
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Trusted contractors that assist SKSi in providing our technology, including this website and email services, are subject to contractual confidentiality and security obligations to protect your data.
All third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
From time to time, we may, in the ordinary course of business, be required to share your personal data outside of the EEA. All third-party service providers (agents, solicitors, subcontractors) are required to take commercially reasonable and appropriate security measures to protect your personal data. As stated above, we only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
WHERE IS YOUR DATA HELD?
We store your private information in both electronic and paper form. All information is kept in accordance with the Data Protection Act 2018 and GDPR at our offices. Access to your information is restricted to professional staff that are dealing with your case and is always under the control of a partner.
Data collected from you when completing and submitting a website enquiry form is sent electronically to SKSi and is also retained for a time on webservers which are in secure locations within the UK.
WHAT DO WE DO WITH THE INFORMATION?
We may use the personal information gathered in our normal course of business as follows:
- To confirm identification when you contact us.
- To provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes.
- For purposes necessary for the performance of our contract with you, your employer or our clients and to comply with our legal obligations (for example to carry out our obligations arising from any agreements between you, your employer or our clients and us for the provision of our service).
- For the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client (for example to carry out our obligations arising from any agreements entered into between our clients and us, for the provision of our services).
- For the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
- To seek your thoughts and opinions on the services we provide to help us improve and monitor our customer service to you.
- To notify you about any changes to our services.
- For statistical analysis and to track activity on our website.
- For record-keeping purposes.
- For the prevention of crime and fraud.
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.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
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.
*As an insolvency practice, together with other legislation, we are governed by the Insolvency Practitioners Regulations 2005 (as amended). This legislation requires us to preserve records as follows:
- Our case files – for a period of 6 years following the Insolvency Practitioner’s release or discharge.
- Books and records – for a period of 15 months after the closure of a liquidation or administration and for a period of 12 months after closure for a compulsory liquidation or bankruptcy subject to there being no other legal requirements.
You can change your preferences for receiving marketing emails, general updates and other information from us or you have the right to ask us not to process your personal information for marketing purposes at any time.
LAWFUL BASIS FOR PROCESSING
We process personal data on the following legal grounds:
- Our legitimate interest - processing data in ways which you would reasonably expect, where processing is necessary in the lawful operation of our business and where our interests do not affect your interests, rights and freedoms.
- To satisfy any legal and regulatory obligations to which we may be subject to.
- To fulfil any contractual obligations under any contract PCR have with you.
We do not rely on consent as a legal basis for processing your personal data, other than in relation to sending direct marketing communications to individuals via a personal email address.
When we collect contact information from you (for example, when you provide us with your business card), we may add your details to our contacts database and to our mailing lists.
In all other cases, we will usually inform you (before collecting your information) if we intend to use your information for marketing purposes.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
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 know. 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.
ACCESSING, AMENDING OR DELETING YOUR DATA
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
- Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
- Request correction of the personal data that we hold about you.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible..
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
If you have previously agreed to receive informational emails from SKSi you can at any time remove your details from our email list though the website here.
CALL TRACKING AND RECORDING
We use telephone tracking numbers to link a user’s call to the marketing channel that they originated from. This is done using cookies - you can choose to decline cookies, as explained above, if you would prefer not to be tracked.
DOWNLOADS AND MEDIA FILES
Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available, users are advised to verify their authenticity using third party antivirus software or similar applications.
We accept no responsibility for third party downloads and downloads provided by external third-party websites and advise users to verify their authenticity using third party antivirus software or similar applications.
EXTERNAL WEBSITE LINKS AND THIRD PARTIES
SOCIAL MEDIA USAGE
While we may have official profiles on social media platforms, users are advised to verify authenticity of such profiles before engaging with, or sharing information with such profiles. We will never ask for user passwords or personal details on social media platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.
There may be instances where our website features social sharing buttons, which help share web content directly from web pages to the respective social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You can find further information about some social media privacy and usage policies in the resources section below.
RESOURCES AND FURTHER INFORMATION
You also have the right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner's Office,
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns
This privacy notice was last updated 9 March 2021.
This policy will be reviewed annually. Unscheduled reviews will take place in the event of significant change.