Privacy Policy

Anderson Brookes Ltd is a limited company registered in England and Wales under company number: 04213701 having our registered office at 4^th Floor, Churchgate House, 30 Churchgate, Bolton, Lancashire, BL1 1HL. We are Authorised and Regulated by the Financial Conduct Authority (FCA). We can be identified on the register by our FCA registration number 669796. You can check this at https://register.fca.org.uk/.

We are registered with the Information Commissioner’s Office (ICO); our ICO registration reference number is Z5595675. We will be the ‘data controller’ for the purposes of data protection laws in relation to any personal information we hold about you.

Please address any queries regarding data protection matters to our Information Officer, Neil Batty on 01204 255 051 (telephone), neil@andersonbrookes.co.uk (email) or, by writing to the above address.

To provide you with our services, we will need to process your personal information (data). The purpose of this privacy notice is to confirm what we will do with your information and to explain your legal rights under the General Data Protection Regulations (GDPR) and other data protection laws which may apply.

What information do we collect about you?

We will need to collect personal information about you in order to provide our services. This information will include your:

• Name;
• Date of birth;
• Address (business and personal);
• Telephone number/s;
• Email address;
• Financial details; and
• Details of assets / liabilities

We may also need to collect other details about you that are relevant to the work you want us to do.

Data Protection legislation says that we must have a valid lawful basis for processing your data. The lawful bases for processing your data are set out in Article 6 of the GDPR; in most cases, we will only process your personal data:

• If it is necessary for us to be able to perform duties under a contract we have with you, or because you have asked us to take specific steps before entering into a contract;
• If it is necessary for us to comply with the law (not including contractual obligations); or,
• If it is necessary in the legitimate interests of this firm or the legitimate interests of a third-party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

If none of the above reasons apply, we may ask for your specific permission (consent).

In rare instances, we might also need to collect and process more sensitive or ‘special category’ data. We will only collect or process this data if it is essential for us to be able to provide you with services. If we need any special category data, we will ask you for specific written permission to process this type of information; and tell you why and how the information will be used.

If we collect data about you from a third-party, we will tell you: what that information is and where it has come from (unless you already have that information, the law says we can’t, or it is confidential). If the information is wrong or incomplete, you will be entitled to ask us to correct it.

If it is otherwise legal, we may use your details to contact you with information about services we think may interest you. You can tell us at any time not to send you these messages.

Consent

If we have asked for your consent to have and process your personal information, you can withdraw that consent at any time by contacting Neil Batty on 01204 255 051 (telephone), neil@andersonbrookes.co.uk (email) or, by writing to the above address. This will not affect any processing of your data that was done prior to you withdrawing your consent.

If you want to withdraw your permission for receiving marketing communications, you can do that at any time by contacting us using the above phone number or email address.

Children

We will not usually process children’s personal information (under the age of 13 years). In the unlikely event that it is necessary for us to do so, we will request the permission of the child’s guardian. If the child is over 13 years, we will request the child’s permission.

Sharing your information

It may be necessary for us to pass on your personal information to other people or organisations to provide our services. This may include but not be limited to:

• Licensed Insolvency practitioners;
• Your Creditors, Bank and HMRC
• Solicitors we instruct to act on your case;
• Surveyors and Agents involved in the valuation of your assets;
• Other professional advisers such as Accountants; and
• Courts / Court Representatives
• Regulators such as the FCA and Information Commissioner

Whenever possible, we will only share your personal information with them on a confidential basis. If we sell our business to a third party, or go through a corporate reorganisation, we will transfer personal data to the company that acquires the business.

Our Group Companies

We may share your personal data among Anderson Brookes Group companies. If we do so, then use of the data by those companies will be governed by this privacy notice. A list of relevant Group companies is set out below, although the list may be updated from time to time.

Anderson Brookes Insolvency Practitioners Ltd

Role: Licensed insolvency practice dealing with formal insolvency cases. Trading Address and Registered Office – 4^th Floor, Churchgate House, Bolton BL1 1HL

Anderson Brookes Financial Services Ltd

Role: Provider of various support services relating to debt advice and insolvency business. Trading Address and Registered Office – 4^th Floor, Churchgate House, Bolton BL1 1HL

It is extremely unlikely that it will be necessary for us to transfer your personal information to another country. If this is necessary, we will discuss this with you beforehand.Transferring your information to another country

How long do we keep your information?

We will not retain your personal data for longer than necessary. We will retain your data for different time periods depending on the type of data concerned, the services we have provided and the purpose (or purposes) for which the data was collected. We may need to keep your personal information after we have completed the work you ask us to do.

Your rights

Under the GDPR, as a ‘data subject’, you have the following legal rights:

• Right to be informed – you have the right to be informed about the collection and use of your personal data.
• Right of access – You have the right to access your personal data. This is commonly referred to as subject access; see below for more information on Subject Access Requests.
• Right of rectification – you have a right to have inaccurate personal data rectified or completed if it is incomplete. You can make a request for rectification verbally or in writing. We will respond to a request within one calendar month.
• Right to erasure – you have a right to request for your personal data to be erased. The right to erasure is also known as ‘the right to be forgotten’. You can make a request for erasure verbally or in writing. We will respond to a request within one calendar month.
• Right to restriction of processing – you have the right to request the restriction or suppression of your personal data. When processing is restricted, we are permitted to store the personal data, but not use it. We will respond to a request within one calendar month.
• Right of portability – The right to data portability allows you to obtain and reuse your personal data across different services. The right only applies to information you have provided to us as a controller.
• Right to object – you have the right to object to the processing of your personal data in certain circumstances. You have an absolute right to stop your data being used for direct marketing. In other cases where the right to object applies we may be able to continue processing your data if we have a compelling reason for doing so. You can make an objection verbally or in writing. We will respond to an objection within one calendar month.
• Right to object to important decisions being made about you, profiling or anything about you being evaluated, by an automated process without any human involvement.

Subject Access Requests

You have the right to access your personal data held by Anderson Brookes Ltd, including the right to obtain a copy of the personal data we process. You can submit your request:

• In writing to our Information Officer, Neil Batty at 4^th Floor, Churchgate House, 30 Churchgate, Bolton, Lancashire, BL1 1HL; or
• By calling our Information Officer, Neil Batty on 01204 255 051; or
• By email neil@andersonbrookes.co.uk

We expect to respond to your request within one month of receipt of a request and proof of your identity. To help us establish your identity, you must provide 2 pieces of identification that clearly shows your name, date of birth, and current address.

Requests Made on a Data Subject’s Behalf

In some situations, an individual may submit an access request on someone else’s behalf. For third-party requests, we require proof of:

• The data subject’s identity.
• The requester’s identity.
• The requester’s legal authority to act on the data subject’s behalf, such as:
  • Written consent signed by the data subject;
  • A certified copy of a Power of Attorney; or
  • Evidence of parental responsibility if the data subject is a child.

To help us process your request, please provide as much detail as possible about the personal data you are requesting access to. Please include dates, names, types of documents, or any other information to help us locate your personal data.

We will contact you for additional information if the scope of your request is unclear or does not provide sufficient information for us to conduct a search. We will begin processing your request as soon as we have verified your identity and have all of the information we need to locate your personal data.

If the information you request includes data related to a third party, we will either seek that individual’s consent before responding to your request, or we will redact third parties’ personal data before responding. If we cannot provide you with access to your personal data, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Complaints

If you are not happy with the way in which we are processing your personal information, or you are not satisfied with how we have handled your complaint, you can raise the matter with our Information Officer (Neil Batty), or with the ICO.

Neil Batty
Anderson Brookes Ltd
4^th Floor
Churchgate House
Bolton
BL1 1HL
neil@andersonbrookes.co.uk
01204 255 051

Or,

Information Commissioner
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
www.ico.org.uk/concerns/handling
Phone: 0303 123 1113 or 01625 545 745