Privacy Policy
Our Privacy Policy (“Policy”) is detailed below.
Your personal information will be held by Johnson Geddes Limited and our two Insolvency Practitioners Paul Johnson and Paul Keeley.
In the privacy notice, “We” “Our”, “Us” and “They” are Johnson Geddes Limited, Paul Johnson and Paul Keeley.
How we use your personal information and data
This privacy notice is to detail how we endeavour to look after your personal information and data.
This notice explains how we do this and tells you about your privacy rights and how the law protects you, in accordance with the General Data Protection Regulation (“GDPR”) (EU) 2016/679.
Our Privacy Promise
We promise:
- To keep your personal information and data safe and private.
- Not to sell your data.
- To give you ways to manage and review your personal information and data at any time.
Who we are
Johnson Geddes Limited is a firm of Insolvency Practitioners who provide insolvency advice and debt solutions, together with debt advice services to consumers.
Paul Johnson and Paul Keeley are Licensed Insolvency Practitioners They are licensed and authorised to act in the UK by the Insolvency Practitioners Association..
If you have any questions or want more details about how we use your personal information and data, you can call our office on 0161 486 9372.
Who collects your personal information and data
Johnson Geddes Limited, Paul Johnson and Paul Keeley are classified as data controllers. This means they are responsible for how they hold and use personal information that they hold.
The current Data Protection registrations are summarised below:
- The Data Protection registration number for Johnson Geddes Limited is Z1766611.
- The Data Protection registration number for Paul Johnson is ZA149486.
- The Data Protection registration number for Paul Keeley is ZA149482
How the law protects you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
We can only use your personal information and data if we have proper reasons to do so. This includes sharing your information outside of Johnson Geddes Limited. One or more of the following must apply to hold your personal information:
- To fulfil a contract we have with you, or
- When it is our legal duty, or
- When it is in our legitimate interest, or
- When you consent to it.
We are obliged to process personal data to comply with the Data Protection legislation and therefore have a legal duty to use your personal information and data.
We rely on our legal obligations under the Insolvency Act 1986 and its associated legislation together with the Insolvency (Northern Ireland) Order 1989 and its associated legislation.
For what purposes do we hold and use your personal information and data
We hold and use your personal information and data for a number of key purposes:
- To provide debt and insolvency advice
- To propose and assist in the preparation of Individual Voluntary Arrangements
- To work with other companies that provide services to us and our clients
- To fulfil our legal and contractual obligations
- To detect, investigate, report upon (as required) and seek to prevent financial crime
- To respond to and seek to resolve complaints under our Complaints Policy
- To fulfil our additional legal duties and corporate responsibilities including business capability, corporate governance and audit
What information will we collect
There is certain information we will collect that is essential to fulfil our legal and contractual obligations, and to both identify and communicate with you. It is not possible for you to opt out of providing this information. This information includes inter alia the following:
- Your full name, age and date of birth
- Key identification data as required which will typically include a certified copy of your passport or driving licence. We will endeavour to complete this verification electronically
- Your address and evidence of that address. Again we will endeavour to complete this verification electronically
- Further contact details including available telephone numbers, mobile telephone numbers and email addresses
- Your complete financial details and profile to include your assets, liabilities, income & expenditure, state benefits, bank statements & bank account details, wage slips, tax returns, credit history & credit reference information. This list is not exhaustive and will depend on individual circumstances. We cannot fulfil our legal and contractual obligations without this full and honest disclosure
- Your marital status and number of children / dependents
- Your employment status to include occupation, salary, pay dates and any professional qualifications. For self-employed clients financial accounts, forecasts and tax returns as required.
- Via your specific written consent, if disclosure is considered beneficial to you, details of any vulnerabilities including physical and mental disabilities. Vulnerabilities are specifically defined in detail by the Financial Conduct Authority.
- With your consent an electronic signature which will include details of your IP address
- National Identification codes and numbers as required, to include National Insurance Numbers, passport numbers and Unique Taxpayer References (UTR)
- Public record information such as the Electoral Register and The Insolvency Register
How we collect your personal information and data
Your personal information and data is collected from a number of sources:
Information and data you provide to us:
- When you use our website
- When you speak to us on the phone
- Via mobile and mobile application devices including WhatsApp and Dropbox
- Via emails
- Documents and information you send through postal services
Information and data we collect when you contact us and use our services. This includes profiles made and electronic information collected via cookies and other internet tracking software.
Information and data provided from third parties we either contract with, access information or use their services. This may include:
- Your creditors
- Organisations that you introduce to us and have already contracted with including other debt advice, financial advisers, other introducers and claims management companies
- Credit reference agencies
- Information provided from Anti Money Laundering checks
- Social networks
- Fraud prevention agencies
- Our Regulatory bodies
- Payroll service providers
- Public information such as Companies House and The Insolvency Register
- Agents working on our behalf
- With your consent health professionals
- Government and law enforcement agencies.
Sharing your personal information and data
We may share your personal information and data with other parties to assist in providing advice, preparing your Individual Voluntary Arrangement and in complying with our legal and contractual duties.
We also use the services of various credit reference agencies and Anti Money Laundering checks to verify your identity. This may leave a ‘soft search’ on your credit file. We will share your personal information with credit reference agencies and they will give us information about you. The data we exchange can include:
- Name, address and date of birth
- Details of any shared credit
- Financial situation and history
- Public information, from sources such as the electoral register and Companies House.
The credit reference and Anti Money Laundering checks will assist in the following:
- Verifying and providing further detail on your financial
- Help detect and prevent financial crime
- Preparing and proposing your Individual Voluntary Arrangement
Under legal, regulatory and contractual obligations we may share your information with our regulatory bodies, the Police and a number of government bodies.
Only with your consent will we share your information with a person appointed to act on your behalf such as an adviser, family member or medical professional. Specific written consent will be required.
Who we may share your personal information and data with
Your personal information and data may be shared with the following:
- Your creditors
- Other third parties we use to assist with your Individual Voluntary Arrangement or we may at our discretion
- Credit reference agencies
- Our Regulators and Anti Money Laundering authorities
- The Insolvency Service
- HM Revenue & Customs, regulators and other authorities
- Organisations that you introduce to us including other debt advice, financial advisers, other introducers and claims management companies
- Our Insurers
Security of your personal information and data
We use all our reasonable efforts and safeguards to protect the personal information and data we collect.
If at any time we believe there has been any breach or compromise of your personal information and data we will notify you immediately.
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information and data
Subject to our legal, Regulatory and contractual obligations you may ask us to either delete, restrict the use of, remove or stop using your personal information and data.
Following your request and subject to our legal, Regulatory and contractual obligations we will comply as far as we are able.
If you believe your personal information and data is incorrect we will investigate as soon as possible and restrict as far as is possible the use of that personal information and data.
How long we keep your personal information and data
We will keep your personal information and data for as long as we are providing a service to you and in the event that you enter into an Individual Voluntary Arrangement for 6 years following completion.
In certain circumstances we may keep your data for longer than the specified 6 years if we cannot delete it for legal, regulatory or other reasons including research or statistical purposes. In exceptional circumstances the information may also be retained to assist in collecting assets that are due into your Individual Voluntary Arrangement.
How to get a copy of your personal information and data
You can formally request a copy of your personal information and data that we hold by writing to us at this address:
Johnson Geddes Limited
Landmark House
Station Road
Cheadle Hulme
Cheshire
SK8 7BS
Phone: 0161 486 9372
This will initially be provided free of charge and within one month. We reserve a right to charge a reasonable fee for further requests or additional copies.
How to complain
You have a right to complain about the use of your personal information and data. Please use the contact details above.
You also have a right to complain to the Information Commissioner’s Office that covers data protection. Details of their procedures are held at www.ico.org.uk.
