Leonard Curtis C.I. Limited Privacy Notice for Creditors
This Privacy Notice tells you what to expect when our organisation collects Personal Data and who to contact if you wish to discuss how we handle the data.
Our office in Guernsey is registered as Leonard Curtis C.I. Limited trading as Leonard Curtis with the Office of the Data Authority (notification number DPA6657), which is the Bailiwick of Guernsey’s independent authority that regulates data protection.
Data Controller
LEONARD CURTIS C.I. LIMITED
Contacting us
If you have any questions relating to the processing of your Personal Data, please write to our Privacy Manager at Leonard Curtis, 5th Floor, Grove House, 248A Marylebone Road, London NW1 6BB. Alternatively, our Privacy Manager can be contacted by email (preferred): privacy@leonardcurtis.co.uk or by telephone on 0207 535 7000.
Relevant Data Protection Law
Where data is being shared with organisations outside the Channel Islands, this will always take place in line with the relevant data protection law both locally and remotely. Consideration will be given to the overseas location, particularly:
- Whether the location is in the EU, and regulated under the GDPR legislation.
- Whether the location has a valid adequacy finding from the EU (Jurisdictions with adequacy findings include Jersey and Guernsey).
- If the location is in the USA, whether the organisation is registered under the Privacy Shield scheme.
Where none of the above apply, appropriate risk assessments will be carried out and any necessary controls put in place to ensure that data is protected.
Information we collect and hold about you
By requesting details of your claim in this insolvency, we may collect Personal Data from you, particularly if you are a consumer creditor, a sole trader or are lodging a claim in your personal capacity.
Personal Data is information relating to a living individual. Whenever Personal Data is processed, collected, recorded, stored or disposed of it must be done within the terms of the relevant data protection law. Examples of Personal Data include but may not be limited to your name, address, telephone number and email contact details.
If you do not provide us with the information we require, this may adversely affect our ability to deal with your claim, but we would ask you not to submit more Personal Data than we request from you.
Legal justification for processing your Personal Data
The processing of your Personal Data by us is necessary to enable us to comply with legal obligations under the Companies (Guernsey) Law, 2008 and associated legislation which we are subject to as Insolvency Practitioners.
How we use your information
All information you supply to us is required to enable us to comply with our duties under the Companies (Guernsey) Law, 2008 and associated legislation. It will be used to enable us to assess the extent of the insolvent entity’s liabilities, to allow you to vote on any resolutions, to enable us to communicate with you, to process your claim and to pay any dividends which may be due to you from the insolvent estate.
Who we share your information with
We may be required to share some of your Personal Data with other creditors. The data which will be shared with other creditors will be limited to that specifically required to be disclosed under the relevant legislation.
We may share some of your information with our Data Processors. Data Processors include solicitors, accountants and employment law specialists who assist us with our duties where required. We will only share your information with our Data Processors if we require their specialist advice. All of our Data Processors are subject to written contracts with us to ensure that your Personal Data is processed only in accordance with the relevant data protection law.
How long will we hold your Personal Data for?
We will need to hold your Personal Data for a period of time after the insolvency has been concluded. This is to enable us to deal with any queries which might arise. Our Records Management Policy requires us to destroy our physical files 6 years after closure of the case. Electronic data files will be removed from our Case Management System 6 years after conclusion of the case but may be held on our server for a longer period of time but with restricted access.
Your rights in respect of your Personal Data
You have the right to request access to your Personal Data and to require it to be corrected or erased. You also have the right to request a restriction in the way we process your Personal Data or to object to its processing. You should be aware however that we may not be able to comply with your request if this would affect our ability to comply with our legal obligations.
You have the right to Data Portability. This is a right to have the Personal Data we hold about you to be provided to you in a commonly used and machine-readable format so that you can transfer that Data to another organisation in a way that is not too onerous to upload the Data.
Your right to complain
You have the right to be confident that we are handling your Personal Data responsibly and in line with good practice. If you have a concern about the way we are handling your Personal Data you should contact our Privacy Manager in the first instance.
If you are unable to resolve your concerns with us, you have the right to complain to the Office of the Data Protection Authority. The Office of the Data Protection Authority may be contacted at:
St Martin’s House
Le Bordage
St. Peter Port
Guernsey
GY1 1BR
Web
odpa.gg
Email
enquiries@odpa.gg
Telephone
+44 (0)1481 742074