BRI Privacy Notice

The following information is provided to comply with the requirements of the UK General Data Protection
Regulation.

This privacy statement describes why and how we collect and use personal data and provides
information about individuals’ rights. It applies to personal data provided to us, both by individuals
themselves or by others. We may use personal data provided to us for any of the purposes described
in this privacy statement or as otherwise stated at the point of collection.

Identity and contact details of the controller and where applicable, the controller’s representative and the data protection officer

Where an Insolvency Practitioner of PKF Smith Cooper is not appointed as office holder, the data controller is either the company/individual on whose instructions PKF Smith Cooper is acting or it is PKF Smith Cooper.
The contact details of PKF Smith Cooper are: St Helen’s House, King Street, Derby, DE1 3EE, tel no. 01332 332021 and email [email protected].

Where an Insolvency Practitioner of PKF Smith Cooper is appointed as office holder and the data processing is carried out as part of their statutory duties, the office holder(s) may be the data controller(s). The Insolvency Practitioner(s) can be contacted at: PKF Smith Cooper, St Helen’s House, King Street, Derby, DE1 3EE, tel no. 01332 332021 and email [email protected].

How we use your personal information

The purpose for which personal information is processed may include any or all of the following:

Lawful basis for the processing

Most processing is carried out to comply with our legal obligations under statute and other regulatory obligations related to the insolvency process. We also believe our processing is for the legitimate interests of all stakeholders in the insolvency process, as they are entitled to be kept informed and may wish to engage in the insolvency process. Where PKF Smith Cooper has engaged with a client to perform a service, we will be required to process data to provide the service in accordance with the contractual terms.

What personal information we hold

The categories are: contact details, financial information and location. In rare cases, we may hold some special category data, e.g. trade union membership or information about individuals’ health, which will be
necessary to administer the insolvency process in line with our legal obligations.

Who we share our data with

Our firm may have offices outside of the UK. We may also use third parties 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 clients are located. This includes countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data internationally are done lawfully. Where we transfer personal data internationally to a country not providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the UK GDPR requirements for the transfer of personal data internationally.

Personal data held by us may be transferred to:

Other member firms and/or Other offices

Details of our member firm/other office locations are available on our website. We may share personal data with other member firms/other offices where necessary for administrative purposes and to provide
professional services to our clients.

Third party organisations that provide applications/functionality, data processing or IT services to us

We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We currently employ the services of SmartCredit Limited t/a SmartSearch, a credit reference agency, to assist us with performing
identification checks on our clients for the purposes of compliance with the Money Laundering Regulations. Any personal information received from SmartCredit Limited t/a SmartSearch will be processed only to
confirm your ID to us for the purposes of preventing money laundering or terrorist financing. You can access SmartCredit Limited t/a SmartSearch’s privacy policy at ttp://www.smartsearchuk.com/privacypolicy/ where you will find more information regarding SmartCredit Limited t/a SmartSearch’s data processing activities.

Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged
crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

How long we retain your personal information

We retain personal data for as long as is necessary to achieve the purpose listed above and for any other permissible related purpose. For example, we retain most records until the time limit for claims arising from
the activities has expired or otherwise to comply with statutory or regulatory requirements regarding the retention of such records.

Your rights

The GDPR provides the following rights for individuals:

Right to inform

This privacy notice meets our requirement to inform you of our processing of your data.

Access to personal data

You have a right of access to personal data held by us as a data controller. This right may be exercised by contacting us at PKF Smith Cooper, St Helen’s House, King Street, Derby, DE1 3EE, tel no. 01332
332021 and email [email protected]. We will aim to respond to any requests for information promptly, and in any event within one month.

Amendment of personal data

To update personal data submitted to us, you may email us at [email protected] or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.

Rights that do not apply in these particular circumstances

Not all of the rights under the UK GDPR are available as one of the reasons we are holding your data is on the basis of it being a legal obligation and therefore the right to erasure, data portability and to object
do not apply.

Right to withdraw consent

The data received was not based upon obtaining consent and therefore the right to withdraw consent does not apply.

Changes to our privacy statement

We keep this privacy statement under regular review and will place any updates on our website. Paper copies of the privacy statement may also be obtained by writing to us at PKF Smith Cooper, St Helen’s House, King Street, Derby, DE1 3EE.

This privacy statement was last updated on 01/09/2021.

Complaints

Should you want to complain about our use of personal data, please contact us at PKF Smith Cooper, St Helen’s House, King Street, Derby, DE1 3EE.You also have the right to lodge a complaint with the Information Commissioner’s Office (“ICO”) (the UK data protection regulator). For further information on your rights and how to complain to the ICO, please refer to the ICO website.

Who provided the personal data

Except where your personal data was provided by you or your representative, the personal data we have used to contact you was provided by the company/individual (or persons acting on their behalf) on whose instructions we are acting or in relation to which our insolvency practitioner has been appointed. We also access information from the Registrar of Companies and other similar public-access data providers.