Restructuring privacy policy

Purpose of policy

This policy describes how RSM UK Restructuring Advisory LLP, RSM Northern Ireland (UK) Limited, RSM UK Creditor Solutions LLP (collectively “the Firm”) and Office-Holders (defined below) collect and process your personal data in the provision of their services.

In this policy:

An “Office-Holder” is a partner or employee of the Firm who holds one of the following (or similar) appointments:

Administrative Receiver.
Administrator.
Fixed Charge Receiver.
Interim Liquidator.
Liquidator.
LPA Receiver.
Nominee or Supervisor of a Voluntary Arrangement.
Provisional Liquidator.
Special Manager.
Trustee in Bankruptcy.
Trustee of a Protected Trust Deed.
Trustee of a Sequestrated Estate.

The “Company” is the legal entity over which the Office-Holder is appointed.

It is important that you read this policy together with any other privacy policy/notice or fair processing notice we may provide on specific occasions when we are collecting or processing your or our clients’ personal data. This policy supplements the other policies/notices, and our Terms and Conditions of Business, and is not intended to override them.

You should also refer to any privacy policy that the Company may have.

We may change the terms of this policy from time to time. This version is dated 1 November 2021.

Data Controller and Privacy Officer

Depending on the circumstances, the data controller may be any of the following:

The Company, where the data has been collected and processed by it. The Company may be contacted via the Office-Holder.
The Office-Holder, where he/she has collected and processed data pursuant to his/her duties under the relevant applicable insolvency legislation or instrument of appointment. If you do not already hold contact details for the Office-Holder, he/she may be contacted via david.punt@rsmuk.com.
RSM UK Restructuring Advisory LLP, RSM Northern Ireland (UK) Limited or RSM UK Creditor Solutions LLP where that entity is engaged to provide services to you. The relevant entity may be contacted via david.punt@rsmuk.com.

RSM has appointed a Privacy Officer to deal with questions relating to this policy who can be contacted at: david.punt@rsmuk.com.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data includes, in relation to you or a family member, first name, maiden name, last name, username or similar identifier; marital status; title; date of birth; gender; data contained on a passport, photocard driving licence or other identity card; and data contained in photographs, videos and CCTV images.
Contact Data includes home address and billing address (if different), email address and telephone numbers.
Financial Data includes income, personal expenditure, charitable donations, taxation and other financial-related details; investments and other financial interests; bank account and payment card details; pension details; and data relating to the membership of professional bodies.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our products and services.
Marketing and Communications Data includes your preferences in receiving marketing material from us and your communication preferences as well as usage information through email web beacons.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this policy.

We may collect special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We may also collect information about criminal convictions and offences.

How is your personal data collected?

Your personal data may be collected from the following sources:

Records that the Company already holds about you.
Questionnaires submitted by you to the Redundancy Payments Service.
Questionnaires completed by you and others and returned to the Firm.
Correspondence between you and the Firm.
Notes from meetings held between you and the Firm’s staff.
Information provided to the Firm by third parties in relation to an appointment.
Information held in the public domain (for example, at Companies House and the Land Registry).

You may also give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

engage us to provide services;
subscribe to our publications;
request marketing material to be sent to you;
enter a competition, promotion or survey;
complete one of our enquiry forms; or
provide us with feedback.

Other data controllers (including clients) may also provide your personal data to us.

How we use your personal data

The precise way in which your personal data is used will depend on the basis on which you interact with the Firm. The most common examples are set out below.

I am an Employee of a business over which the Office-Holder has been appointed

Your personal data is used primarily to fulfil the Office-Holder’s duties under the relevant applicable insolvency legislation.