OUR POLICIES

PRIVACY POLICY

Who we are

Compass Financial Recovery & Insolvency Limited is a Limited Company, registered in England and Wales (number 05641548) whose registered office is Prospect House, 11-13 Lonsdale Gardens, Tunbridge Wells, Kent, TN1 1NU. Compass Financial Recovery & Insolvency Limited is registered as a Data Controller at the Information Commissioner’s Office under registration number Z9349213.

We are committed to protecting and respecting your privacy. This policy explains what personal information we may collect from you and how we will use it.

Information that we may collect, how we will use it and why

We may also collect and process personal information about you as follows:

• If you contact us with a prospective business opportunity enquiry, we will use the information provided to deal with that enquiry, on the basis that we have a legitimate interest to do so (e.g. to follow up prospective business opportunities as well as for ancillary record keeping and internal management purposes).
• If you contact us by any other means (e.g. email or telephone), we may keep a record of that contact and the information you provide at that time. Information which we collect under these circumstances will be used to follow up prospective business opportunities or to perform our contractual obligations in accordance with our contract with you.

• If you contact us to make a complaint, we will use the information provided to respond to the complaint, on the basis that we have a legitimate interest to do so (e.g. to enable us to ensure that you are satisfied with our services and to ensure that our business remains competitive in the market).

• If you ask to be added to our contacts database we will collect your name, the name of your company/organisation (if any), email address and your preferences as to the types of marketing information you would like to receive from us. We will use your details on the basis of your consent to send marketing information to you in accordance with your stated preferences (as you may update them from time to time).

• If you are a shareholder or director of a company for which we are providing pre-appointment advice or a shareholder or director of a company for which we are administering the affairs, we will collect your name, address and a copy of your passport and/or your photocard driving licence together with a recent utility bill or bank statement. We will use your contact details to perform our contractual obligations.

• If you are a creditor of a company for which we are providing pre-appointment advice or a creditor of a company for which we are administering the affairs, we will collect your name, address and details of any dividends distributed to you. We will use your contact details to perform our contractual obligations.

 

 

• If you are an employee of a company for which we are providing pre-appointment advice or a creditor of a company for which we are administering the affairs, we will collect your name, address, payroll details and national insurance number. We will use your contact details to perform our contractual obligations.

• If you engage us to provide you with services, we will collect your billing address, email address and telephone numbers. We will also collect information about your assets and intellectual property rights, transaction details about payments to and from you and other details of services you have purchased from us including any testimony you are willing to write about us and our performance. We will use this information to perform our contractual obligations and for ancillary internal management purposes which are compatible with the original purpose.

• If we engage you to provide us with services or goods, we will collect your billing address, email address and telephone numbers. We will also collect details of your rate cards, your quotations, transaction details about payments to you and other details of services or goods we have purchased from you. We will use your contact details to perform our contractual obligations including but not limited to the processing of payments to you in accordance with our contract with you.

• If your personal data is on publicly available sources (such as LinkedIn and Companies House) then we may collect your personal data that is available on these sources. Information which we collect from publicly available sources (such as LinkedIn and Companies House) will be used in connection with matters on which we are formally engaged.
• If you submit job applications to us, we will collect your contact details and any other information you provide in the application. We will process job applications and CVs submitted to us on the basis that we have a legitimate interest to do so (to fill vacancies and to grow our business).
• We may also collect sensitive personal information that may include offences and alleged offences, criminal proceedings and sentences, for example, records under the Company Directors Disqualification Act 1986.

• We may use information which is provided to us to fulfil our legal obligations, e.g. making HMRC payments.

• If you visit our website we may also collect personal data about your visit through the use of website cookies in order to improve your user experience (for more information see the section below entitled Cookies).

We will not use your personal information for any purpose not explained in this privacy policy.

Other information collected via our website and cookies

If you visit our website, we may collect information about your visit, namely IP address, traffic data, location data and the resources that you access.

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. For more information on cookies, please visit https://www.aboutcookies.org/ .

We use traffic log cookies provided by Google to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website so it can be tailored to customer needs. We only use this information for statistical analysis purposes.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Our website uses the following Cookies:

Log in / Registration - Where we provide log in mechanisms for site users a cookie is created at login, for the duration of the session. Each cookie contains a unique reference number only (no personal information) which is used to confirm you are authorised to adjust / update your details.

Google Analytics - to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

Who do we share your personal information with?

From time to time, Compass Financial Recovery & Insolvency Limited will require third parties to process to personal data on its behalf, either pursuant to a contractual obligation or because it has a legal obligation or legitimate interest to do so.

Roles performed by third parties may include performing debt collection and tracing services, managing shareholder registers, processing credit reference checks and processing anti-money laundering searches, processing pension claims and IT matters, and any other roles performed by an agency in connection with a formal engagement.

Compass Financial Recovery & Insolvency Limited takes reasonable steps, in accordance with the GDPR’s requirements for controller/processor contracts, to control any third-party processing and to ensure that the third party processors have appropriate procedures in place to safeguard the security and integrity of the personal data they are processing.

From time to time third parties processing personal data on behalf of Compass Financial Recovery & Insolvency Limited may contact you directly.

We may disclose your personal information to third parties if we are under a duty to disclose or share it to comply with any legal obligation.

Except as set out above, we will not share your personal information with any other party.

How long will we keep your personal information?

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Type of personal information held	How long do we keep it?
Information relating to directors, shareholders, debtors, employees and creditors held on our case files.	6 years after the closure of the case
Company records relating to formal appointments (e.g. employee, creditor and debtor details)	12 months after dissolution of the company
To receive marketing information	Until the customer asks to be removed from the contacts database
All other personal information	6 years after the end of the business relationship

 

Where do we store your personal information and how is it kept secure?

All information you provide to us is stored on our secure servers located in the United Kingdom. No information you provide to us is transferred to, or stored at, a destination outside the European Economic Area.

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 are committed to ensuring that your information is secure. To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. However, please be aware that despite the security measures we have in place, no computer system is completely secure and there is always some degree of risk whenever personal information is transferred by electronic means.

Physical documentation is stored in a secure location.

Links to other websites

Our website may, from time to time, contain links to other websites which may be of interest to you. If you follow a link, please note that the other websites will have its own privacy policy and you should check this before you submit any personal data to that website.

Your rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. To do this, please contact us by any of the means referred to below (under the section entitled Contacting Us). Your personal data will be provided free of charge (unless the request is unreasonable or excessive in which case a small fee may be charged or we may limit the level of information provided) and within 30 days in accordance with the GDPR requirements.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your Personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Contacting Us

If you have any queries about this privacy statement or any complaints about the way in which we handle your personal data, please contact us using one of the following options:

• Website: www.compassfri.com
• E-mail: guide@compassfri.com
• Post: Company Secretary, Compass Financial Recovery & Insolvency Limited, Prospect House, 11-13 Lonsdale Gardens, Tunbridge Wells, TN1 1NU
• Telephone: 01892530600

We will investigate any complaint promptly with a view to resolving the matter as swiftly as possible.

Complaints

You have the right to complain to the Information Commissioner about the way in which we collect and use your personal data: www.ico.org.uk/concerns or telephone 0303 123 1113.

Changes to this privacy policy

This policy is effective from 25 May 2018. We may change this privacy policy from time to time by updating this webpage.