This notice describes how we collect and use Personal Data about you, in accordance with the General Data Protection Regulation (“GDPR”), the Data Protection (Bailiwick of Guernsey) Law, 2017 (“Law”) and any other relevant implementing laws, regulations and secondary legislation, as amended or updated from time to time, in Guernsey collectively (“Data Protection Legislation”). Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.
The Company provides liquidation and restructuring services to a wide range of clients.
Depending on the work we are performing we are classed as either a Processor or Controller under Data Protection Legislation. Where we act as a Controller, we are responsible for deciding how we hold and use Personal Data we process about you.
Where we act as a Processor, another Controller is responsible for deciding how we hold and use Personal Data about you.
This Privacy notice primarily deals with our role of Controllers of Personal Data. As a Controller, Data Protection Legislation requires us to notify you of the Personal Data we process. This privacy notice seeks to meet this obligation.
For further information regarding to our roles as Processor for other Controllers Personal Data, please contact our Data Protection Officer.
Please note that we have a specific employee privacy statementsfor potential, current and past employees, which is available to these parties on a request basis. Sharifah Morris is the Company’s Data Protection Officer (“DPO”) and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your Personal Data.
Sharifah Morris can be contacted as follows: Email: sharifah@solvegroup.gg Tel: +44 (0)7839 106789
We obtain Personal Data about you, for example, when:
We usually collect this data directly from yourself however on occasion we do collect this data from third parties.
We do not use automated means to collect or process any Personal Data.
Our website uses anonymous cookies, which we use for the purpose of improving your experience on our website and website analytics. By continuing to use the service, you agree to our use of anonymous cookies. If you prefer not to allow the use of cookies, simply log in to your browser settings and turn off the use of cookies for all sites or specific websites. For anti-spamming purposes, we also capture the IP address of online communications via our online forms. We regularly delete this information once that communication has been verified as legitimate.
The information we hold about you may include the following:
We may hold limited data classed as Special Category under the Data Protection Legislation including sickness data and criminal records checks. If you would like more information about the Special Category data we hold, please contact the DPO.
We may process your Personal Data for purposes necessary for the performance of our contract with you and/or to comply with our legal or regulatory obligations.
We may process your Personal Data for the purposes necessary for the performance of our contract with our clients. This may include processing your Personal Data where you are an employee, subcontractor, supplier or customer of our client. In this instance, we may be a Processor and not a Controller of this Personal Data.
We may process your Personal Data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of Personal Data. This includes processing for marketing, business development, statistical and management purposes.
We may process your Personal Data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your Personal Data then you have the right to withdraw your consent to processing for such specific purposes. Please note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using your Personal Data.
Situations in which we will use your Personal Data
In some circumstances, we may anonymise or pseudonymise the Personal Data so that it can no longer be associated with you, in which case we may use it without further notice to you. If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your Personal Data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your Personal Data, we take into consideration:
Our retention policy is available on request.
Where we need to use your Personal Data for another reason, other than for the purpose for which we collected it, we will only use it for a reason that is compatible with the original purpose. Should it be necessary to use your Personal Data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
We may share your Personal Data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT, cloud services, data management system, and accounting packages, professional advisory services, administration services, marketing services and archiving. All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your Personal Data. We only permit our third-party service providers to process your Personal Data for specified purposes and in accordance with our instructions.
We may share your Personal Data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your Personal Data with a regulator or to otherwise comply with the law.
We use the following sub processors in our day to day business operations:
Some of these Processor systems are hosted in the USA. Our controls in place over the processing on your data by these sub-processors is available on request.
We have put in place commercially reasonable and appropriate security measures to endeavour to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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 have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
It is important that the Personal Data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Under certain circumstances, by law you have the right to:
If you want to exercise any of the above rights, please email our Data Protection Officer. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. We will need to adequately verify your identity before we can assist you with any of the above. This ensures that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Data Protection Officer.
Once we have received notification that you have withdrawn your consent, we will no longer process your Personal Data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so under Data Protection Legislation.
Any changes we may make to our privacy notice in the future will be updated on our website www.solvegroup.gg This privacy notice was last updated on 13 December 2021.
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your Personal Data, please email our Data Protection Officer, Sharifah Morris or telephone our office on +44 (0)7839 106789
