1. Who are we?
Our contact details are:-
Griffin & King Limited
26/28 Goodall Street
T: 01922 722205
F: 01922 639480
2. Who can you contact for privacy questions or concerns?
You may contact the UK Information Commissioner's Office at https://ico.org.uk/concerns/handling/ to report concerns you may have about our data handling practices.
3. How do we collect personal data?
Directly - We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us their business card, complete our online forms, subscribe to our newsletters, register for competitions, attend meetings or seminars we host, visit our offices or apply for open roles. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract, or through our hosted software applications.
Insolvency services - We obtain personal information in our insolvency work, initially to enable us to assess the insolvency options available to you or your employer and subsequently, to enable us to deliver insolvency services to our clients and meet our legal responsibilities which is a legitimate interest. This will involve us sharing your personal data or personal data you or the client control, as part of the provision of those insolvency services. For example, we will review payroll and pension data, and we often need to use personal data to fulfil our legal obligations. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms and policies.
Indirectly - We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients. We may attach personal data to our customer relationship management records to better understand and serve our business clients, subscribers and individuals, satisfy a legal obligation, or pursue our legitimate interests.
Public sources - Personal data may be obtained from public registers (such as Companies House), news articles, sanctions lists, and Internet searches.
Social and professional networking sites - If you register or login to our websites using social media (e.g., LinkedIn, Google, or Twitter) to authenticate your identity and connect your social media login information with us, we will collect information or content needed for the registration or login that you permitted your social media provider to share with us. That information may include your name and email address and depending on your privacy settings, additional details about you, so please review the privacy controls on the applicable service to set how much information you want shared with us.
Online financial review - If you complete and submit a financial review request, we will collect this information with the legitimate purpose of assessing the insolvency options available to you, and communicate these options to you using the details provided.
Subscription to Newsletters - If you subscribe to our newsletter or receive our e-bulletin, we will collect this information with the legitimate purpose of providing insolvency news and other relevant topical material.
Recruitment services - We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
4. What categories of personal data do we collect?
Personal data. Here is a list of personal data we commonly collect to conduct our legitimate business activities.
- Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
- Professional details (e.g., job and career history, educational background and professional memberships, published articles).
- Employee payroll & pension details (e.g., name, address, date of birth, employment start date, personal email address, dates of breaks in employment and relevant information required to facilitate insolvency claims).
- Family and dependents (e.g., ages).
- Financial information (e.g., tax and accounting records, payroll, pension records, investment interests, finance arrangements, assets, bank details and relevant information to facilitate our work as insolvency practitioners).
- Where CCTV is operational at our sites we may collect images of visitors. Our policy is to automatically overwrite CCTV footage within 30 days.
Sensitive personal data. We typically do not collect sensitive or special categories of personal data about individuals. When we do need to process sensitive personal data, it is with the consent of the individual unless it is obtained indirectly for legitimate business purposes. Examples of sensitive personal data we may obtain include:
- Information provided to us by our clients in the course of a professional insolvency engagement.
- Dietary restrictions or access requirements when registering for in-person events that reveal religious beliefs or physical health.
- Personal identification documents that may reveal race or ethnic origin, and possibly biometric data of private individuals, beneficial owners of corporate entities, or applicants.
- Expense receipts provided as part of financial information provided by a client for insolvency engagement that reveal affiliations with trade unions or political opinions.
- Adverse information about potential or existing clients and applicants that may reveal criminal convictions or offences information.
- Diversity and equal opportunity information volunteered by participants in certain professional training.
Child data. Although we do not intentionally collect information from individuals under 13 years of age, we may occasionally receive details about children attending events we host with their parents or guardians (e.g., sport hospitality events, presentations or award ceremonies).
Location-based data. We may process geographical locations you enter on our website when seeking an office near you or when you call one of our regional offices.
5. What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
Contract - We may process personal data in order to perform our contractual obligations.
Consent - We may rely on your freely given consent at the time you provided your personal data to us.
Legitimate interests - We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These include:
- Delivering insolvency services to our clients - To deliver the professional services our clients have engaged us to provide.
- Direct marketing – To deliver timely market insights and speciality knowledge we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
- Legal obligations & regulatory and public interests - We may process personal data in order to meet regulatory and public interest obligations or mandates.
6. Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
- Providing professional insolvency advice, delivering reports on restructuring and other professional services. Our services may include reviewing client financial and other records, which may involve processing personal data.
- Complying with legal and regulatory obligations of the Insolvency Act 1986, the Employment Rights Act 1996 and the Company Director Disqualification Act 1986 together with associated legislation and Rules.
- Complying with legal and regulatory obligations relating to countering money laundering, terrorist financing, fraud and other forms of financial crime.
- Promoting our professional services, products and capabilities to existing and prospective business clients.
- Sending invitations and providing access to guests attending our seminars, events and webinars or our sponsored events.
- Personalising online landing pages and communications we think would be of interest based on interactions with us.
- Administering, maintaining and ensuring the security of our information systems, applications and websites.
- Authenticating registered users to certain areas of our sites.
- Seeking qualified candidates, and forwarding candidate career inquiries to our HR department, which may be governed by different privacy terms and policies.
- Processing online requests, including responding to communications from individuals or requests for advice and quotations.
- Contacting journalists regarding company press releases, invitations to annual seminars, highlighting messages that may be of interest on specific industry topics.
7. Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
- Griffin & King associate entities, where necessary for administrative purposes and to provide professional services to our clients (e.g., when providing services involving both corporate and personal insolvency advice and services).
- Parties that support us as we provide our services (e.g., providers of telecommunication systems, copier & mailroom support, IT system support, document archiving & destruction services, specialist insolvency software providers, website hosting service providers).
- Our professional advisers, including solicitors, accountants and insurers.
- Our professional insolvency licencing body and enabling bond provider.
- A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger/acquisition of part or all of a client’s business or assets, or any associated rights or interests.
- To law enforcement officials, law courts and government and regulatory authorities:
- (a) if we believe disclosure is required by any applicable law, regulation or legal process; or
- (b) to protect and defend our rights, or the rights or safety of third parties, including to defend against legal claims based on our legitimate interests
- In exceptional circumstances, to third parties to protect your vital interests if you fell ill or suffered an injury at one of our events or on our premises
- Payroll bureau service providers (e.g., payroll and pension scheme advisers)
- Payment services providers (e.g., banking facilities, chip & pin providers)
- Marketing services providers.
- Other government and regulatory agencies (e.g., HMRC, the Insolvency Service) or to other third parties as required by, and in accordance with, applicable law or insolvency regulation.
- Recruitment service providers.
8. Do we transfer your personal data outside the European Economic Area?
We store personal data on servers located at our registered office in Walsall (in the European Economic Area (EEA)). We do not transfer personal data to any third party or organisation situated outside the EEA. If the need arises specific consent will be sought if we have a business reason to engage such a third party or organisation. Each organisation is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.
10. What are your data protection rights?
Your data protection rights are outlined below:
- Access - You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
- Correction - You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
- Erasure - You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
- Processing restrictions - You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
- Data portability - In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if it is technically feasible.
- Automated Individual Decision-making - You can ask us to review any decisions made about you which we made solely based on automated processing, including profiling, that produced legal effects concerning you or similarly significantly affected you.
- Right to Object to Direct Marketing including Profiling - You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
- Right to Withdraw Consent - You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
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 helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
11. What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information.
We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
If you have access to parts of our websites or use our services, you remain responsible for keeping your user ID and password confidential. Please be aware that the transmission of data via the Internet is not completely secure. Whilst we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site, any transmission is at your own risk.
12. How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these uses, we retain personal data for seven years after termination of our insolvency business relationship. We will delete / dispose of personal data in a secure manner when we no longer need it.
We will delete / dispose of your personal data if no formal insolvency appointment was undertaken, or there has been no adequate contact activity with you for 3 years. It is unlikely that your data will be relevant for the purpose it was collected after this period.
We will delete / dispose of your personal data if you were not employed following a recruitment drive after three years. It is unlikely that your data will be relevant for the purpose it was collected after this period.
We will give you the opportunity to opt out of receiving marketing communications from us when we first contact you. Also, you can change your marketing preferences at any time by clicking on the "unsubscribe link" in any of our marketing communications or by visiting your preference settings page.
13. Do we link to other websites?