1. Who are we?
Our contact details are:-
Griffin & King Limited
26/28 Goodall Street
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 fulfill 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.
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:
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:
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:
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:
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:
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?