1 Information about us
This policy sets out the basis on which we, Danny Dartnaill and Antony Nygate, process any personal data in our capacity as joint administrators for OneSelect Limited (“OneSelect”) as agents for OneSelect and without personal liability.
2 What information do we collect?
The personal data we may process as joint administrators will be basic details about OneSelect customers so that we can carry out our functions.
The type of personal data we may hold is likely to be:
· Date of Birth
· Email Address
· Phone Number
· Employment Details
· Financial Information
This information will be held as part of the records of OneSelect so we can carry out our statutory and regulatory requirements.
3 How do we collect information?
4 Why do we collect this information?
Our lawful basis for processing your information will fall into one or more of the following categories:
· compliance with a legal obligation under insolvency or other legislation;
· the processing is necessary to perform a task in the public interest or our official function, and that task or function has a clear basis in law; and
· the processing is necessary for our legitimate interests, for example, the compliance with our regulatory obligations or for defending or bringing a legal claim.
5 How do we use this information?
We process personal information to enable us to carry out our work as joint administrators which includes processing data that was held by companies or individuals before our appointment, together with data collected during an insolvency procedure.
6 Do we share your information with anyone else?
We may share personal data with third parties where we are under a legal or regulatory duty to do so, or it is necessary for the purposes of undertaking our work as joint administrators. We may also share personal data to the police or other law enforcement agencies with the prevention and detection of crime or otherwise as permitted by the law.
Examples of third parties with whom we may share personal data are:
· government organisations such as the Insolvency Service, the Redundancy Payments Service, Ofgem and HMRC;
· external service suppliers including Gentrack;
· Together Energy Limited, as the new service supplier to customers of OneSelect; and
· any organisation to which we are legally obliged to share personal data with.
We do not transfer your personal data outside the EEA.
7 How long do we keep your information for?
Insolvency practitioners are required to maintain records relating to insolvency appointments for a minimum period as specified in the Insolvency Practitioner Regulations 2005. This specifies that certain records must be maintained until the later of:
(a) the sixth anniversary of the date of the grant to the insolvency practitioner of his release or discharge in that case; or
(b) the sixth anniversary of the date on which any security or caution maintained in that case expires or otherwise ceases to have effect.
We may retain other types of records for a longer period to comply with other legal or regulatory requirements, but in any event, we will not keep your information for longer than is necessary to achieve these purposes.
8 How do we protect personal information?
We take appropriate technical and organisational measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
9 Your Rights
You have a right to ask us to confirm whether we are processing information about you, and to request access to this information (‘right of access’).
You may ask us, or we may ask you, to rectify information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate or complete information which is incomplete (‘right to rectification’).
You have a right to obtain your personal data from us and reuse it for your own purposes, perhaps for another service, without hindering the usability of the data (‘right of portability’).
You have a right to seek the erasure of your data (often referred to as the ‘right to be forgotten’). You may wish to exercise this right for any reason, for example where it is no longer necessary for us to continue holding or processing your personal data. This right is not absolute, as we may need to continue processing this information, for example, to comply with our legal obligations, or for reasons of public interest.
You have a right to ask us to restrict our processing of your information (‘right to restriction’) if:
· you contest its accuracy and we need to verify whether it is accurate
· the processing is unlawful and you ask us to restrict use of it instead of erasing it
· we no longer need the information for the purpose of processing, but you need it to establish or defend legal claims
· you have objected to processing of your information being necessary for the performance of a task carried out in the public interest, or for the purposes of our legitimate interests. The restriction would apply while we carry out a balancing act between your rights and our legitimate interests.
If you exercise your right to restrict processing, we would still need to process your information for the purpose of exercising or defending legal claims or for public interest reasons.
If you would like to exercise any of your rights above, please let us know using the contact details at the end of this policy. We will act in accordance with your instructions as soon as reasonably possible and there will be no charge.
You have a right to report any of your concerns about our use of your data to the Information Commissioner’s Office. You may do so by calling their helpline at 0303 123 1113.
10 Changes to this policy