Phoenix Insolvency Practitioners Limited (Phoenix Insolvency) is committed to preserving and respecting your privacy. Please read the following privacy policy to understand how we use and protect the information that you provide to us. This privacy policy will apply to you if you provide your personal information to us, even if you subsequently decide not to proceed. It is also used by all companies within the Phoenix Insolvency group and our affiliate companies with whom we may share information (see below for further details). This privacy policy sets out how we will use your personal data to provide our service to you.
By registering on this site, you consent to the collection, use and transfer of your information under the terms of this policy.
We promise:
The information we collect from you depends on the product or service you apply for, or the service that we provide to you. We will only collect information that we actually need, or where we’re required to collect the information to enable us to perform our legal, regulatory or contractual obligations necessary to provide you with the products or services, or where we have your permission.
This will likely include the collection of:
Data protection law defines some personal information as “special categories of data”. This includes information about physical or mental health, sexual life, religious beliefs, race or ethnic origin, political opinions, trade union membership or biometric data. This information may be necessary to collect when understanding the reason for your financial circumstances, or where it may help us to provide a better service to you and obtain a better understanding of your financial situation. For example, a period of ill health could have caused you to fall behind with your regular payments to your creditors.
Where we need to collect and process this type of data about you, by providing this information to us you give your explicit consent for us and any other third party to process this special data as set out in this privacy policy, unless we have a legal obligation to process this type of data.
Any personal information about you relating to criminal convictions or offences may only be used by us when authorised by law.
If you provide personal information about someone else, for example when a joint application is made, you must do so with the permission of the other person. If you enter into a service jointly with another person (for example, a joint Individual Voluntary Arrangement), your personal information and any information about the service provided to you will be shared with the other person.
We will use the personal information about the other person in the ways as described in this privacy policy.
We may obtain personal information from you in a number of ways:
We can only use your personal information where it falls into one or more of the following categories:
Where you make an application or enquiry for one of our products or services, we’ll use your information to provide you with appropriate information to recommend a suitable debt solution. If you cannot provide this information, we may not be able to progress with your application or enquiry.
We may also use this information to contact you about and process your application, for example, sending you an email, text message or letter to welcome you to our services. We will process the personal data we collect about you for the purposes set out below at Purposes for Processing your Personal Data.
After you have made you initial application/enquiry, if you also decide to go ahead with any of the products or services that we offer, the sections below explain how we will also process your data when we provide that particular product(s) or service(s).
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Debt Advice:
Where we give you advice regarding an Individual Voluntary Arrangement, we will process your
personal information to administer the service we provide. This may include contacting you where
we may need further information or sending you updates on the progress of the service we provide
to you.
The information below specifically explains how and why your personal data will be used so that the
service can be provided to you. When providing you with debt advice we collect and use your
personal information under the lawful basis of our legitimate interest and is necessary to enable us
to provide you with the best advice possible.
WHAT PERSONAL DATA WILL WE NEED TO COLLECT:
To be able to provide you with advice regarding insolvency solutions we need to collect certain
categories of personal data. This will include:
• Contact details – Your full name, address, contact number, e-mail address etc. This is so we can
contact you about and process your enquiry
• Personal and financial details – Your date of birth, gender, any previous names that you were
known by, your living arrangements, employment details, details of any dependants, details of any
assets you hold and your payment information. We need this so that we can decide whether an IVA
is appropriate for you and so that we can draft and send a proposal to your creditors. Once you
enter into an IVA, we need this information to ensure that we can collect payments and take any
changes in circumstances into consideration when administering the IVA.
• The people you owe money to and your property and assets – creditor details (including the names
of your creditors, reference numbers and balances). This is so we fully understand your financial
situation and give you personalised advice that’s tailored to you
• Your Income and expenditure – – Details of your financial position including all sources of income
and your household expenditure. This is so we can accurately work out what you can afford to pay
towards your debts and make sure the solution we recommend is the right one for you
• Call Recordings, Chat Logs and E-mails: When you contact us by telephone, your call may be
recorded for training and monitoring purposes. We also keep any e-mail correspondence and online
chat logs to help us to manage your IVA.
• Special personal information – only with your permission and where this is relevant to your
financial situation and how a debt solution needs to work for you, or where we have a legal right to
do so. With your permission, we may use information from your credit file to confirm certain
information, including about your lenders, balances, account numbers, your account, address and
insolvency history and details of any county court judgments (CCJ). We will also use this information
to confirm your identity and to comply with anti-money laundering legislation.
WHO WILL THE DATA BE SHARED WITH?
We may share your information with our Debt Solution Providers/partners. i.e. IVA companies who
provide and / or administer the plan on our behalf. We will only share your information with them if
they’ve agreed to keep it confidential.
In addition, you information may be shared with:
• Your Creditors and their Representatives: Your personal data will be shared with your creditors,
their agents, debt collectors, bailiffs and solicitors dealing with the debts. This is key to allow us to
provide the service we have agreed to provide you and also ensures that we comply with our
regulatory obligations.
• Our regulators, such as the Insolvency Practitioners Association and the Institute of Chartered
Accountants in England and Wales, the Information Commissioner’s Office or any other regulatory
body or authority may request certain information as part of supervising us. We have a legal or
regulatory obligation to provide this.
• The Insolvency Service: If your IVA is accepted then details about you and your IVA will be
recorded on the Insolvency Register which is accessible by the public. The information we share
includes your name, gender, date of birth and address. We have a legal obligation to supply this
information.
• If you have provided your authority, if we have a legitimate interest to do so or where we may be
legally entitled to, we will share information with credit reference agencies (CRAs) to obtain
information about your financial history or your credit commitments. For further information on
how CRAs may use your personal information you can view the Credit Reference Agency Information
Notice here or from the three main CRAs – TransUnion (formerly Callcredit); Equifax; and Experian.
• Solicitors: We may from time to time need to instruct solicitors to assist with the administration of
your IVA or to assist us with legal, regulatory and contractual obligations.
• IT Providers: We use third-party software companies to help manage your data. These include, The
insolvency Link, a case management system, Secured Trading, a payment processor, Telephony
companies, so we can communicate with you, external printing company who print correspondence
that we send to you.
These companies help us to provide our service to you. We have contracts in place with all providers
to ensure that they comply with their data protection obligations and ensure that they have
appropriate security measures in place.
HOW LONG WILL YOUR DATA BE STORED FOR?
If you continue to be our customer and we give you advice, we will keep a record of your personal
information to ensure that we provide you with the best service possible and where we’re required
to keep your data to meet our legal and regulatory obligations. This will normally be kept for at least
6 years, starting from the date when we are no longer providing you with a service. Telephone calls
will be retained for at least 6 years from the date the call was made.
If you do not go ahead with any product or service offered by us, your personal information will
normally be deleted after 2 years (except for any recorded telephone calls) unless we have another
reason to keep your personal information, for example, if you have given your consent to receive
marketing or promotional messages from us.
After this time, we will delete the information or anonymise the data so that it cannot be linked back
to you.
OTHER PURPOSES FOR PROCESSING YOUR PERSONAL DATA
Websites and marketing
To help us understand you better and provide you with information about other products which may
be suitable and relevant, we will use your personal information to create a profile of you and your
circumstances. This allows us to provide more relevant, accurate and tailored services to you. For
example, we may assess your income and expenditure to determine whether you would be eligible
for a debt solution through us. We believe we have a legitimate interest to do this and that it is not
against your rights.
However, if you don’t want us to profile your personal information this way, to then better enable us
to tailor any marketing communications to you, you can contact us to let us know that you wish for
your personal data not to be used in this way.
Reviews and Market Research
Where we have a copy of your personal information we may contact you to ask you to provide a
review about the services you’ve received or where we are carrying out market research which may
help us design future products and services or to help improve our current services. Although this
information would really help us, you wouldn’t be required to provide us with this information
unless you were happy to. We consider that this is in our legitimate interests to contact you in this
way for market research purposes.
Legal or Regulatory Obligation
We are required to process your personal information where we have a legal or regulatory
obligation to do so, for example, to adhere to anti-money laundering or our regulatory obligations.
Responding to complaints or enquiries
If you make an enquiry or complaint with us, we will use your personal information to investigate
the complaint and deal with your enquiry. We have a legal and regulatory obligation to deal with
your complaint appropriately.
Internal Analysis
As part of our legitimate interest to develop our business and our products we will use your personal
information to assess our performance as a business and for statistical analysis. We will use your
personal information to assess our performance as a business and for statistical analysis. We will use
as little personal data as we can to achieve this.
WHO DO WE SHARE YOUR INFORMATION WITH?
We may also share your personal information with the following organisations:
• IT Service Providers who provide IT platforms or other IT services • Advertisers and social media
companies such as Facebook, Google and Twitter for our social media accounts or where we can
contact you using your social media account
• Payment Service companies that process transactions for us (e.g. Direct Debits and card
transactions)
• Communication providers (e.g. telephone line providers, and email and text service providers.
• This Party administrators who provide ongoing support with the administration of your plan •
Third parties who may have introduced you to our services
We may also share your personal information where we have your consent to do so or where we’re
required to do so under a legal or regulatory obligation or court order, such as the police, local
authorities or the courts.
Fraud Prevention and Law Enforcement Agencies
The personal information we have collected from you may be shared with law enforcement agencies
and fraud prevention agencies who will use it to prevent fraud, money-laundering and terrorist
financing and to verify your identity. If fraud is detected, you could be refused certain services,
finance or employment. Further details of how your information is used by us and these fraud
prevention agencies, and your data protection rights, can be found by contacting us at the following
address:
Phoenix Insolvency Practitioners Limited
Earl Business Centre
Dowry Street
Oldham
OL8 2PF
Social Media
We use publicly available social media platforms to promote our services, to provide updates and to
share any news and promotional updates. We may collect personal information from these social
media platforms, for example, if you post a message on our Facebook page. By providing any of your
information to us through these platforms you should be aware that:
• The social media web pages are publicly available and you must not provide any personal or
sensitive information on our pages that are accessible to the public, such as your account
information. We may ask you for your account information via a private message to identify you and
to service any request you make; and
• Each social media platform will process any personal information you provide through the
platform and will be processed in accordance with its own privacy policy. The privacy policies are
available to view on each social media platform.
Sharing your information outside of the EEA
We will only share your personal information outside the European Economic Area (EEA), where we
have your consent; to comply with a legal obligation; or where we work with a business partner to
enable us to provide you with our services, and they process information outside of the EEA.
If we do share your information outside of the EEA we will make sure that it is protected in the same
way as if it was being used in the EEA to ensure appropriate safeguards are in place. This may
include putting in place a contract with the business partner that means they must protect the
personal data to the same standards as the EEA (this may include defined model clauses), or only
share the data to a business partner in a non-EEA country where the privacy laws provide the same
protection as within the EEA or where they are part of a Privacy Shield.
More information on this can be found on the European Commission Justice Website.
SECURITY
We take the protection of personal information very seriously and we will maintain appropriate
measures to maintain the confidentiality, integrity and availability of the information you have
provided. Such measures include:
• Company security policies and standards
• Staff security awareness Role-based and biometric access controls to prevent unauthorised access
to the information
• Encryption and anonymisation technology
• Anti-malware technologies
• Security monitoring
• Security testing
• Secure archiving and deletion
• Compliance with industry regulation and legislation
HOW WE MAY CONTACT YOU ABOUT THE PRODUCTS AND SERVICES WE PROVIDE TO YOU
To help us keep you up to date about the products and services that we provide to you, and to
ensure that you’re kept fully informed, we may contact you by letter, telephone, email, text
message, push notifications, social media or may send you messages by any online customer
platforms or other electronic means.
If you start an application for a product or service through us we will attempt to contact you shortly
after if you were unable to complete your application for whatever reason.
If you do not want to be contacted in a particular way then you can request this at any time, but if
we are providing a service to you, we do need to be able to send you communications. This can
often be due to a legal or regulatory requirement.
It is important that you keep us up to date when you change your contact details to ensure that we
use your up to date contact information.
RECORDING CALLS
We record any telephone calls you make to us or we make to you or any other third party. This is for
training, monitoring and quality purposes and to meet our legal and regulatory obligations. Some
telephone calls may be observed by staff for training and development purposes.
We may keep a copy of the telephone calls for up to 6 years from the date the telephone call was
made.
YOUR RIGHTS
Access to your personal information
You have the right to request from us a copy of the personal information that we may hold about
you. This is often called a “Data Subject Access Request”. You can request this information by
contacting us as set out below. We won’t charge you to provide you with this information.
Before providing this information to you or to another person or company where you have
requested this personal information to be sent to, we may ask for proof of identity or ask sufficient
questions to enable us to locate the information and ensure that we’re only providing it were you
have given your agreement.
Right to have your personal information corrected
If the personal information we hold about you is incorrect you have the right to request that we
correct this.
Right to stop or limit the processing of the data we carry out
You may request that your personal information is deleted or that we stop processing the
information if we’re no longer entitled to process it. There may be occasions where we are unable to
delete the data due to our legal or regulatory obligations. We will however discuss this with you if
you request for your information to be deleted.
Portability
In some cases you may be able to request for your information to be provided to you or to another
company in a format that can be processed electronically by you or the other company. If you want
to request this you’ll need to contact us.
CONTACT US
If you have any questions or queries about how we use your personal information you can contact
us or our Data Protection Officer using the address:
Data Protection Officer
Phoenix Insolvency Practioners Limited
Earl Business Centre
Dowry Street
Oldham
OL8 2PF
COMPLAINT
If you are not happy with our response, or wish to raise a complaint regarding your data. You can
make a complaint to the Information Commissioner’s Office (ICO) or get advice from the ICO.
https://ico.org.uk/make-a-complaint
UPDATES TO THIS PRIVACY POLICY
Any updates to this privacy policy will be found on this page. If we make any important or significant
changes to the way we may collect and use your personal information we will endeavour to notify
you of this change.
COOKIES
When using this website, some information may be collected automatically using ‘cookies’. These
are small text files that facilitate the processing of your data and enable us to analyse how the
website is being used. Cookies can be temporary or permanent.
Temporary cookies form part of the security process while you are using the website; permanent
cookies identify the link you used to find our website, check your browser so that we can make sure
that our website and services work well with your computer and to help us monitor traffic on our
website.
What are cookies?
Cookies are small text files that are placed in your computer or mobile device when you visit a
website. These are small text files that facilitate the processing of your data and enable us to analyse
how the website is being used.
There are two types of cookies, in regard to its lifespan:
• Temporary Cookies: These cookies form part of the security process and expire when you close
your web browser
• Permanent Cookies: These cookies stay in your device for a longer period of time or until you
manually delete them
• Regarding the Entity that sets the cookies, there are two types of cookies:
• First-party Cookies: These are cookies set by the website that you are visiting, either by us or by a
third-party at our request
• Third-party Cookies: These are cookies set by a third-party rather than the provider of the website
that you are visiting
Why are cookies used?
They help visitors. Cookies allow sites to do things like provide personalised content and remember
their log-in details and settings. You can turn them off – this won’t stop a website from working, but
it might mean it won’t work as well as it could, or that you have to do the same thing more than
once.
They help website owners. Cookies tell website owners things like, what search engine a visitor used
to find the website, how often they’ve visited it, how long they’ve spent on it, and so on. Except for
essential cookies, all cookies will expire after 10 years.
Disabling/Enabling cookies
You have the ability to accept or decline cookies by modifying the settings on your browser. Please
remember though that disabling certain cookies may affect the functionality of our website.
Further information on the use of and managing cookies can be found at https://allaboutcookies.org