Privacy Policy

Identity and Contact Details of the Controller and Where Applicable, the Controller’s Representative and the Data Protection Officer

Where an insolvency practitioner of Kennway Francis Limited ("Kennway Francis") is not appointed as office holder, the data controller is either the company/individual on whose instructions Kennway Francis is acting, or it is Kennway Francis itself.

Where an insolvency practitioner of Kennway Francis is appointed as an office holder and the data processing is carried out as part of their statutory duties, the office holder(s) is/are the data controller(s).

Kennway Francis is a UK-based entity and does not require a representative outside of the UK under the UK GDPR.

We are not required to appoint a Data Protection Officer under the UK GDPR. If you have any questions about how we use your data, please contact us using the details below.

The contact details of Kennway Francis are:

• Address: 8 High Street, Brentwood, Essex, CM14 4AB
• Phone: 0207 129 7366
• Email: [email protected]

The insolvency practitioner(s) can be contacted at: Kennway Francis, 8 High Street, Brentwood, Essex, CM14 4AB.

Kennway Francis Limited is a company registered in England and Wales. (If applicable, include company registration number and VAT number here. Example: Company Registration No: 12345678)

How We Use Your Personal Information

The purposes for which personal information is processed may include any or all of the following:

• Deliver services and meet legal responsibilities
• Verify identity where this is required
• Communication by post, email or telephone
• Understand needs and how they may be met
• Maintain records
• Process financial transactions
• Prevent and detect crime, fraud or corruption
• Use data to defend or take legal actions related to the above

Lawful Basis for the Processing

Most processing is carried out to comply with our legal obligations under statute and other regulatory obligations related to the insolvency process. We also believe our processing is for the legitimate interests of all stakeholders in the insolvency process, as they are entitled to be kept informed and may wish to engage in the insolvency process. Where Kennway Francis has engaged with a client to perform a service, we will be required to process data to provide the service in accordance with the contractual terms.

What Personal Information We Hold

The categories of personal data we may hold include:

• Contact Details: such as name, email, phone number, and address
• Financial Information: including bank details and payment history
• Location: where relevant
• Special Categories of Data (Rare Cases): such as trade union membership or health information, if necessary to administer the insolvency process in line with our legal obligations

Who We Share Our Data With

We may share personal data with:

• Other Offices: Details of our other office location is: Registered Office - 8 High Street, Brentwood, Essex CM14 4AB. We may share personal data with other offices where necessary for administrative purposes and to provide professional services to our clients.
• Third-Party Organisations: that provide applications/functionality, data processing, or IT services to us. We use third parties to support us in providing our services and to help provide, run, and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service, identity management, website hosting and management, data analysis, data back-up, security, and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. Where personal data is transferred outside the UK, we ensure that appropriate safeguards are in place, such as UK International Data Transfer Agreements or Standard Contractual Clauses approved by the UK Information Commissioner’s Office.
• Other Third Parties: that assist us in providing goods, services, or information.
• Auditors and Other Professional Advisers: to comply with professional and regulatory standards.
• Law Enforcement or Other Government and Regulatory Agencies: or other third parties as required by, and in accordance with, applicable law or regulation. Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise, or defend legal rights. We will only fulfill requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

How Long We Retain Your Personal Information

We retain personal data for as long as is necessary to achieve the purposes listed above and for any other permissible related purpose. For example, we retain most records until the time limit for claims arising from the activities has expired or otherwise to comply with statutory or regulatory requirements regarding the retention of such records.

Your Rights

The UK GDPR provides the following rights for individuals:

• Right to be Informed: This privacy notice meets our requirement to inform you of our processing of your data.
• Access to Personal Data: You have a right of access to personal data held by us as a data controller. This right may be exercised by contacting Melissa Jackson at Kennway Francis, 8 High Street, Brentwood, Essex CM14 4AB, by telephone on 0207 129 7366 and by email at [email protected]. We will aim to respond to any requests for information promptly, and in any event within one month.
• Amendment of Personal Data: To update personal data submitted to us, you may email us at [email protected] or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.
• Other Rights: You may also have the right in certain circumstances to request the restriction of processing of your personal data, or to object to the processing of your personal data. However, not all of these rights apply in every circumstance. For example, where we are processing your data to comply with a legal obligation, the rights to erasure, data portability, and to object do not apply. We will inform you if your request cannot be fulfilled for legal or other permitted reasons.
• Right to Withdraw Consent: The data we have received was not based upon obtaining consent, and therefore the right to withdraw consent does not apply.

Changes to Our Privacy Statement

We keep this privacy statement under regular review and will place any updates on our website. Paper copies of the privacy statement may also be obtained by writing to us at Kennway Francis, 8 High Street, Brentwood, Essex CM14 4AB.

Last Updated: 20 December 2024

Complaints

Should you want to complain about our use of personal data, please contact Melissa Jackson at [email protected].

You also have the right to lodge a complaint with the Information Commissioner’s Office ("ICO") (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.

Who Provided the Personal Data

The personal data we have used to contact you was provided by the company/individual (or persons acting on their behalf) on whose instructions we are acting or in relation to which our insolvency practitioner has been appointed. We also access information from the Registrar of Companies and other similar public-access data providers.