We are committed to respecting the privacy and confidentiality of personal data and complying with data protection legislation. When we process personal data in the United Kingdom we do so in compliance with the Data Protection Act 2018 and the UK GDPR. When we process personal data in the European Economic Area we do so in compliance with the EU GDPR. Any reference in this policy solely to “GDPR” should be construed as either the UK GDPR as applies in the United Kingdom or the EU GDPR as applies in the European Economic Area.
2 About us
Each company in the Azets group of companies is a separate legal entity and a separate controller of personal data. Some of these companies trade under a trading name that does not include the word “Azets” in the company title, for example, Don’t Fret About Debt. A full list of our legal entities to which this policy applies is available here.
“Azets” (and “we”, “us”, or “our”) refers to Azets Opco Limited, registered in Jersey under registration number FC033952, with registered address at 22 Grenville Street, St Helier, Jersey, JE4 8PX, with United Kingdom establishment registration number BR019040, 16 Great Queen Street, Covent Garden, London, WC2B 5AH and such Azets companies in Europe and their subsidiaries that:
- are a contracting party for the purposes of providing or receiving services, or
- posted a position for which you are applying, or
3 How to contact us - Data Protection Officer, EU representative and UK Representative
If you wish to discuss any data protection matter please contact our Data Protection Officer as described below.
|Data Protection Officer for all Azets companies
|The Data Protection Officer
Azets Opco Limited
45 King William Street
London EC4R 9AN
|Tel +44 (0) 20 7403 1877
DPO@azets.co.uk (in the United Kingdom)
email@example.com (in the European Economic Area)
If you are based in the European Economic Area but serviced by one of our UK entities and wish to discuss our compliance with the EU GDPR please contact our EU representative as described below (all of our UK entities have appointed the following as their EU Representative in writing as required by EU GDPR Article 27).
|EU Representative for Azets companies in the United Kingdom
|The EU Representative
Postboks 342 Sentrum
|Tel +47 40 10 40 18
If you are based in the United Kingdom but serviced by one of our EEA entities and wish to discuss our compliance with the UK GDPR please contact our UK representative as described below (all of our EEA entities have appointed the following as their UK Representative in writing as required by UK GDPR Article 27).
|UK Representative for Azets companies in the European Economic Area
|The UK Representative
Azets Holdings Limited
45 King William Street
London EC4R 9AN
|Tel +44 (0) 20 7403 1877
4 Our role
Our role as a controller or a processor depends upon the nature of our engagement with you. If you are a customer this will be defined in your letter of engagement and associated schedules and Terms of Business which form our contract with you. But generally:
- Where we decide the purpose and means of processing, we are a controller.
- Where we jointly decide the purpose and means of processing with you, we are a joint controller.
- Where we process personal data according to your explicit written instructions, in a contract that satisfies Article 28 of the GDPR, we are a processor.
5 How we obtain your personal data
Personal data is any information relating to an identified or identifiable living person. We only collect such personal data that is necessary for us to perform our services or inform you about our services and we ask customers only to share such personal data as required for that purpose. Where we identify that a customer has provided us with unnecessary personal data, we either return that information to its source or destroy it, considering the customer’s preference wherever possible.
5.1 personal data that you provide to us by:
- Filling in forms on our websites azets.co.uk, www.blickrothenberg.com, www.azets.com, www.dontfretaboutdebt.net, www.idur.se, www.azets.no, www.azets.se, www.azets.dk, www.azets.fi, www.azets.ro, www.legeregnskap.no, www.karabingruppen.no, www.karabin.no, www.sans.as, www.valent.no, www.impello.no, www.isannointiluotsi.fi, www.rantamaki.com, http://duit.as, https://gorillaaccounting.com, www.sagakl.no (including the subdomains of these websites);
- Corresponding with us by telephone;
- Corresponding with us by email;
- Corresponding with us by letter;
- Communicating with us by our secure portal “Cozone”;
- Using the Live Chat facility;
- Personal messaging services such as WhatsApp®, Facebook Messenger® and SMS (although we do not recommend using such services);
- If you visit our offices, you may record your details in a visitors’ book or electronic equivalent or we may do that for you;
- If you visit our offices, you may be recorded by CCTV systems owned by us or our landlord which are deployed for the prevention and detection of crime and to provide a safe working environment for employees and visitors.
5.2 personal data that we collect from publicly available sources
- From credit reference agencies and other company information providers;
- From national business administration authorities, such as Companies House in the UK;
- From social media such as LinkedIn®;
- From our own research activities such as reviewing websites.
5.3 personal data that we receive from referrals
- We may receive unsolicited personal data in the form of a business-to-business referrals. We will seek consent before processing such personal data any further;
- We may receive personal data submitted as a referral from one of our own employees. We will seek consent before processing such personal data any further.
6 The personal data that we process about you
If you are a prospective customer, we process the following:
- First name;
- Last name;
- Job title;
- Company name;
- Web site address;
- Email address;
- Telephone number;
- Dietary requirements (if you are attending an event where food is provided);
- Banking details (if relevant to the service);
- Tax filing details (if relevant to the service);
- Any further personal data that you choose to provide in your initial enquiry;
- Any further personal data that you choose to provide during subsequent discussions whether by phone, email or letter.
If you are a personal or sole trader customer, we may process the following:
- Your name, home address and date of birth;
- Name, home address and date of birth of any family members, advocates or other beneficiaries and connected parties;
- Employment status;
- Financial details such as salary, other income and investments, tax status and debt level.
If you are a business customer, we also process the following:
- Company name and registration number;
- Business type and industry sector;
- Name, business address, job title, email address and telephone number(s) of all employees who may engage directly with us;
- For officers of the company, beneficial owners and persons of significant control:
- Contact details (name, home address);
- Date of birth;
- PEP (Politically Exposed Persons) status;
- SIP (Special Interest Person) status.
If we are providing payroll services or tax return services for your employees, we will process the following personal data concerning your employees:
- Contact details (name and address);
- Unique identification number such as National Insurance (NI) number, unique Taxpayer Reference (UTR) or social security number;
- Salary, tax and deduction information.
If you are a supplier, we process the following:
- Company name and registration number;
- Business type and industry sector;
- Company address(es);
- Company telephone number(s);
- Name, address, job title, email address and telephone number(s) of all employees who may engage directly with us.
If you contact us concerning employment whether by letter, email, LinkedInTM or via our careers pages you may provide:
- Your Curriculum Vitae (CV) containing personal data;
- Further personal data in a covering letter.
If a recruitment agency contacts us concerning employment whether by letter, email or via our careers pages they may provide:
- Your Curriculum Vitae (CV) containing personal data;
- Further personal data in a covering letter.
If you use our secure portal Cozone we collect the following information from you:
- User ID;
- IP address.
If you visit one of our websites, we collect information about your computer:
- IP address (where available);
- Geographic location (if you allow this when prompted by your browser);
- Operating system;
- Browser type;
If you receive marketing emails from us and interact with them, we collect:
- Time you received the email;
- Time you opened the email;
- Device you used to open the email;
- Geographical location when you opened the email;
- Which parts of the email you interacted with.
If you use social media accounts which are registered using the same email address you have provided to us elsewhere our systems enable us to link your social media accounts to your email address and so we process:
- Links to any social media accounts that you use.
7 Special Category Person Data
We do not normally collect special category personal data such as health, race or ethnic origin. However, for certain services or activities (such as wealth management or HR consultancy), and when required by law or with an individual’s consent this may be necessary. We always seek to minimise our processing of special category personal data.
8 Purpose for the processing and the lawful basis for the processing
We provide a wide range of business services. Most of these services require us to process personal data to provide advice and deliverables. The lawful basis for processing personal data for the purpose of providing services to our customers depends upon the context. We use one or more of the following legal bases for processing:
- Processing necessary for the performance of a contract, or steps taken to enter into a contract with our customers;
- To address our legitimate interests;
- To satisfy a legal obligation.
8.1 Complying with any requirement of law, regulation or a professional body of which we are a member
As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We keep records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data. This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence measures to comply with anti-money laundering regulations we carry out searches to identify politically exposed persons and heightened risk individuals and organisations, and to check that there are no issues that would prevent us from working with a particular customer, such as sanctions, criminal convictions (including in respect of company directors and beneficial owners), conduct or other reputational issues. Where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory obligations.
If you wish to become our customer (and periodically thereafter), we have a legal obligation to verify your identity. We do not need to obtain your consent to do this because it is a legal obligation imposed upon us. However, we are obliged to inform you that this will take place. We may achieve this by:
- performing a search with a credit reference agency. This will leave a footprint on your credit file as evidence that the check has taken place. This footprint is not the same as a credit check footprint and has no impact at all on your credit rating. It just leaves a footprint that proves we have satisfied the legal obligation to verify your identity. Even when these identity checks are performed periodically their repetition has no impact on your credit rating; and/or
- evaluation of traditional ID-check documents (passport, drivers’ licence etc) and the use of an electronic signature complying with the European Union Trusted Lists (EUTL).
8.2 Administering, managing and developing our businesses and services
We process personal data to run our business. This processing is necessary for the purposes of the legitimate interests pursued by us to administer, manage and develop our business and services. Such processing includes:
- managing our relationship with customers;
- developing our businesses and services (such as identifying customer needs and improvements in service delivery);
- maintaining and using IT systems;
- hosting or facilitating the hosting of events; and
- administering and managing our websites, systems and applications.
The lawful basis for processing personal data for the purpose of recruitment is our legitimate interest to develop our business.
Personal data collected from unsuccessful employment applicants is retained for 6-12 months (depending upon which part of our group you have applied to) after which it is securely destroyed.
8.4 Business Development and marketing
The initial lawful basis for processing personal data for the purpose of business development is our legitimate interest to develop our business by undertaking sales and marketing activities.
When we first contact an individual or organisation, we will seek consent to process personal data before we proceed any further. We retain evidence of the consent which has been provided.
When sending electronic marketing messages to existing customers concerning similar products or services to those already purchased, we rely on the “soft opt-in” approved by the UK’s Information Commissioner and similar mechanisms in other European countries. Such mechanisms permit us to lawfully send marketing messages to existing customers provided that they contain an “opt out” mechanism.
The lawful basis for sending electronic marketing messages to named individuals is consent. We retain evidence of the consent which has been provided.
We retain personal data collected through our business development processes for as long as we believe our products and services may be of interest to prospective customers. Individuals and organisations can ask to be removed from our business development system at any time.
8.5 Procurement of services from suppliers
The lawful basis for processing personal data for the purpose of procurement is our legitimate interest to maintain efficient and effective procurement processes.
9 Retention of Personal Data
The retention period for the personal data we process is always in accordance with legal, regulatory and contractual requirements.
10 Data Sharing
10.1 Data sharing – introduction
We only share personal data with other organisations when we have a lawful basis to do so. When we share data with other organisations, we put contractual arrangements and security mechanisms in place to protect personal data and to comply with our data protection, confidentiality and security standards.
10.2 Data sharing within the Azets group of companies
Personal data held by us may be transferred to, or disclosed to, other companies in the Azets group of companies (see list here) and our ultimate parent company Hg Capital. We may share personal data with other Azets companies where necessary for administrative purposes and to provide professional services to our customers.
All companies in the Azets group of companies are bound by a Data Sharing Agreement which commits them to share personal data in a secure and lawful manner that respects the rights and freedoms of data subjects.
10.3 Data sharing with other controllers
Depending upon the nature of the service being provided to you we may lawfully share personal data with other organisations. This may change from time to time, so for the latest information please refer to the following: https://www.azets.co.uk/about-us/privacy-policy/data-sharing
We use specialist organisations to provide certain services, such as data hosting. These organisations (defined as processors in data protection legislation) are bound by a written contract which defines their tasks and responsibilities. Azets only employs processors that comply with data protection legislation and processors are subject to audit or certification review to ensure continuing compliance.
The processors used by Azets group companies may change from time to time, so for the latest information please refer to the following: https://www.azets.co.uk/about-us/privacy-policy/processors
11 International Transfers
We are part of a global association of accountants and in common with other professional service providers, we sometimes use organisations located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our customers are located.
We will neither transfer nor process personal data outside the country in which a customer has contracted, nor will we permit personal data to be so transferred or processed by a third party, unless it is under one of the following conditions:
- the territory into which the data are being transferred has an adequacy decision issued by the European Commission (under EU GDPR) or the Secretary of State (under UK GDPR);
- the transfer is made under the unaltered terms of the standard contractual clauses issued by the European Commission (under EU GDPR) or the Secretary of State (under UK GDPR);
- the transfer is made under the provision of binding corporate rules which have been approved and certified by the European Commission (under EU GDPR) or the Commissioner (under UK GDPR);
- the transfer is made in accordance with one of the exemptions set out in GDPR Article 49.
11.1 European Data Protection Board (EDPB) Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data.
Some of our service providers (processors) are ultimately US-owned, but our contracts are with their UK or EU entities, subject to UK GDPR and EU GDPR legislation respectively. We have risk-assessed our continued usage of such US-owned service providers in compliance with the above-mentioned EDPB guidance. We continually keep under review the requirements which are imposed by applicable legislation.
12 Profiling and automated decision-making
We do not perform any profiling based on personal data that has a legal or significant effect upon data subjects.
We do not perform any automated decision-making involving personal data.
13 Information relevant solely to our UK Insolvency and restructuring practice
In the UK the following applies:
Azets staff taking insolvency appointments are licensed in the United Kingdom by the Institute of Chartered Accountants in England and Wales, the Institute of Chartered Accountants of Scotland or the Insolvency Practitioners Association to act as insolvency practitioners.
Work undertaken under insolvency appointments is subject to insolvency law and regulation (primarily the Bankruptcy (Scotland) Act 2016, Insolvency Act 1986, the Insolvency Rules 1986, The Insolvency Regulations 1994 , The Insolvency Practitioners Regulations 2005), court practice notes, Statements of Insolvency Practice in England and Wales and Statements of Insolvency Practice in Scotland.
In addition, insolvency practitioners are subject to the ICAEW’s Code of Ethics D or, for members of those bodies, the equivalent codes set by the Insolvency Practitioners Association or Institute of Chartered Accountants of Scotland. All insolvency practitioners are also expected to comply with the Joint Insolvency Code of Ethics.
When a company undergoes insolvency, one or more Azets insolvency practitioners may be appointed to manage the company’s affairs, business and property.
In the case when an individual is subject to an insolvency, one or more Azets insolvency practitioners may be appointed to manage the individual’s affairs, business and property. Initial advice and the administration of Debt Arrangement Schemes is provided by Azets Debt Solutions Limited which is authorised and regulated by the Financial Conduct Authority registration 799455.
Should the individual wish to proceed with a Trust Deed or Sequestration, Azets Debt Solutions Limited will refer the individual and pass their details to Azets Holdings Ltd. The administration of formal insolvency appointments will be administered by Azets Holdings Ltd.
13.1 Use of personal data in our insolvency and restructuring practice
We process personal data to enable us to carry out our work as insolvency practitioners which includes processing data that was held by companies and individuals before our appointment, together with data collected during an insolvency procedure or a fixed charge receivership. Our legal obligation to process personal data arises from work we are required to carry out under insolvency and other related legislation.
As appointees of a court, licensed insolvency practitioners are defined in data protection legislation as controllers of personal data. Azets Holdings Limited functions as an agent acting on the explicit instructions from such licensed insolvency practitioners about personal data in relation to an insolvency procedure or fixed charge receivership.
Personal data are kept secure and processed only for matters relating to the insolvency procedure being dealt with.
13.2 Personal data processed in the insolvency and restructuring practice
The personal data Licensed Insolvency Practitioners processes are usually basic details that may identify an individual and are typically sufficient to allow us to carry out our work as insolvency practitioners. For example, dealing with the claims of individuals who are owed monies by the companies or individuals over whom we have been appointed.
However, insolvency practitioners may be appointed over entities that process personal data that is considered more sensitive (special category personal data), for example health records and this special category personal data has usually been created before our appointment. Although we take appropriate steps to safeguard special category personal data (or to destroy it where it is appropriate to do so), subject to limited exceptions, for example, where we identify previous conduct and/or action that requires further investigation, we do not process special category personal data.
The company or individual subject to insolvency and the Azets insolvency practitioners process personal data for the purposes of complying with the following legal obligations and/or legitimate interests:
- the provision of references or reports to financial institutions, regulatory authorities, appropriate bodies in connection with the holding of public office;
- analysis for management purposes and statutory returns;
- the provision of business services including the realisation of assets, agreement of claims and the payment of dividends;
- the reasonable and lawful provision of information to interested parties;
- the calculation and analysis of payroll, billing, credit control and other data relating to the company’s finances and the transfer of such data for use by financial personnel and other appropriate independent third parties;
- maintaining security of the company, any personnel and data;
- the prevention and detection of crime or fraud;
- quality and risk management purposes;
- compliance with any request from regulatory authorities or other relevant public authorities or agencies;
- legal proceedings (including prospective legal proceedings);
- obtaining legal advice;
- establishing, exercising or defending legal rights;
- compliance with certain legal obligations to which the company or individual may be subject;
- processing for personal purposes of employees in accordance with the law and the company’s and/or individual’s policies and rules.
The Azets insolvency practitioners may collate, process and disseminate statistics based on an aggregation of data held by them, the company and/or individual provided that any individual is not identifiable from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
13.3 Personal data retention in the insolvency and restructuring practice
Personal data is retained by Azets insolvency practitioners for as long as any legal or regulatory requirement requires it. Typically, this is seven years after the matter has been concluded, after which it is securely destroyed.
14 Your Rights
You have the following rights concerning your personal data:
|Right to be informed
|Right of access
|You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to that personal data.
|Right to rectification
|You have the right to oblige us to rectify inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed by providing a supplementary statement.
|Right to erasure (right to be forgotten)
|You have the right (under certain circumstances, but not all) to oblige us to erase personal data concerning you.
|Right to restriction of processing
|You have the right (under certain circumstances, but not all) to oblige us to restrict processing of your personal data. For example, you may request this if you are contesting the accuracy of personal data held about you.
|Right to data portability
|You have the right (under certain circumstances, but not all) to oblige us to provide you with the personal data about you which you have provided in a structured, commonly used and machine-readable format.
You also have the right to oblige us to transmit those data to another controller.
|Right to withdraw consent
|If the lawful basis for processing is consent, you have the right to withdraw that consent.
|Right to object to direct marketing
|Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for marketing, which includes profiling to the extent that it is related to such direct marketing.
|Rights in relation to automated decision making and profiling
|We do not perform any automated decision-making based on personal data that produces legal effects or similarly significantly affects you.
15 Your right to lodge a complaint with a supervisory authority
If you would like to exercise any of your rights shown above, please contact the Data Protection Officer by post, telephone or by using one of the email addresses at the top of this notice.
If you are not satisfied with the response you receive, you have the right to lodge a complaint with the relevant supervisory authority for the territory in which you are contracted as shown in the table below.
|Information Commissioner’s Office
(t) +44 (0) 303 123 1113
|Datatilsynet / The Norwegian Data Protection Authority
Postboks 458 Sentrum
(t) +47 22 39 69 00
|Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter personal / The National Supervisory Authority for personal data Processing
B-dul G-ral. Gheorghe Magheru 28-30
Sector 1, cod postal 010336 Bucuresti
|Datainspektionen / The Swedish Data Procetion Authority
(t) 08-657 61 00
|Tietosuojavaltuutetun Toimisto / Office of the Data Protection Ombudsman
P.O. Box 800
(t) +358 (0)29 566 6700
|Andmekaitse Inspektsioon / Republic of Estonia Data Protection Inspectorate
39 Tatari St.
(t) (+372) 627 4135
|An Coimisiún um Chosaint Sonraí (Data Protection Commission)
21 Fitzwilliam Square South
Republic of Ireland
(t) + 33 (0)1 7650100
|Datatilsynet / The Danish Data Protection Agency
Carl Jacobsens Vej 35
(t) +45 33 19 32 00