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Privacy statement – administrator appointments

The Insolvency Practitioner appointed as administrator over the company by the court / directors of the company / shareholders of the company or the qualifying floating charge holder acts as joint controller, with Grant Thornton (NI) LLP, in respect of your personal data.  Both parties have agreed that Grant Thornton (NI) LLP shall be responsible for operating the insolvency appointment.  We want to protect the privacy of all parties whose personal data we process in the course of our appointments.

Please read the following statement; it will help you to understand how we use your personal data.

About us

In this privacy statement “we”, “our”, and “us” refers to Grant Thornton (NI) LLP, and the Insolvency Practitioner appointed over the company collectively.

Contact details are set out below.

What personal data do we collect?

In addition to the personal data that you may provide directly to us, we may process the following personal data about you that we receive from third party sources:

  • Biographical Details – name, date of birth
  • Contact Details – address, email address and telephone number(s)
  • Personal Identification – copies of official identification for the directors of the company to comply with anti-money laundering legislation (e.g. passport)
  • Details of Assets of the Company – details of the assets owned by the company (e.g. any properties owned and / or managed by the company, including details of the tenants of the properties)
  • Employment records – if you are an employee of the company we will hold your human resources records (e.g. information including name, address, date of birth, length of service, wage, pension)
  • Company Information – including financial statements and accounts for the company (including information about directors remuneration and payment of shareholders dividends and pension funds)
  • Creditors and Debtors information – details of all outstanding debts owed to the company, and also all the companies creditor information

What are the sources of your personal data?

Personal data may be obtained from you directly.  In addition, personal data will be provided to us by the directors of the company and from review of the company records, accounts and files. We may also be provided with personal data by a charge holder, financial institutions, financial service providers and / or creditors of the company. We may also consult publically available records in relation to the company over which we are appointed.

Why do we process your personal data?

We process your personal data in order to conduct the administration of the company.  This involves; acting as administrator, and complying with duties, such as reporting to the court.

Our processing of your personal data in these circumstances is on the basis that it is necessary for the purposes of pursuing our legitimate interests and the legitimate interests of the company.  The legitimate interests that we pursue are our interests in performing our appointment and operating our business.  The legitimate interest of the company is the successful completion of the administration process so that the company may continue to trade into the future or cease to trade through an appropriate exit route. We may also be required to process your personal data in order to comply with our legal obligations.

To whom might we disclose your personal data?

  • Third Party Software Providers – Vision Blue (Insolvency management software), iManage (document management software)

We may be required in certain circumstances, by law or by regulations or by Professional Bodies, located both within the UK and the European Economic Area (EEA), to make reports to regulatory and law enforcement authorities or to such bodies, or to disclose documents or information or take other action, as a result of information received by us or matters which come to our attention during the course of our engagement. We may also be required to provide Regulatory Bodies, Grant Thornton International Limited or Professional Bodies with access to our work papers in order to facilitate monitoring inspections.

Transfers abroad

We are an all-Ireland firm and therefore data is processed in all offices (ROI/NI) for the legitimate interest to ensure efficient running of the business.

Whilst we store personal data on servers both in Dublin and the UK, in line with the above, we may need to transfer personal data outside the UK. This includes to countries that are not recognised by the Government of the UK as providing an equivalent level of protection for personal data as in the UK (also known as having adequacy). Where we do so, we ensure that appropriate measures are in place to comply with our obligations under data protection legislation. This can include entering into an agreement governing the transfer containing the ‘standard contractual clauses’ (also known as ‘model clauses’) approved for this purpose by the Government of the UK.

Our retention of your personal data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

You have the right, subject to certain exemptions:

  • to obtain a copy of any personal data we hold about you,
  • to request rectification or erasure of such data,
  • to request restriction of processing or to object to processing,
  • data portability.  

If you wish to exercise these rights, please contact us using the details below.

Our contact details

If you would like to contact us, please write to us or email us using the contact details below:

Registered office address: Grant Thornton (NI) LLP, 12-15 Donegall Square West, Belfast, BT1 6JH, Northern Ireland.

Email address: dataprivacy@ie.gt.com

Complaints

You also have the right to lodge a complaint with the Information Commissioner’s Office, or another supervisory authority.