Evolve IS Ltd privacy and fair processing notice
Your guide to how we handle personal data (information that could identify you).
Key message: We take care with personal data. We don’t share details with anyone except where we need to do so to fulfil contracts with clients and suppliers, operate our business, or comply with the law.
This privacy notice applies to data we process (handle) as both data controller and data processor.
Where we handle personal data for the purposes of running our business and communicating with you, we are acting as data controller.
Where we process personal data under your instruction for the purposes of providing services to your business, you are the data controller and we are acting as data processor.
To ask us what personal data we hold on you or are handling as data processor for your organisation, email hello@w59.7c7.myftpupload.com or call 0121 333 1295.
If you have any complaints about how we have treated your personal data, you can contact the UK Information Commissioner at https://ico.org.uk/
Data controller
Evolve IS Ltd.
What data we collect and handle
As data controller, we handle names, contact details and job titles of individuals working for client, potential client and supplier businesses, organisations and authorities we deal with in the course of providing our services, and other businesses we are in contact with for the purpose of running our business.
We also handle Evolve IS Ltd’s employee and job applicant personal data, including name, contact details, NI number, date and place of birth, nationality, contract and salary details, bank details, past employment records, any criminal records, employment and disciplinary records, sickness and absence records, education and training details, next of kin/emergency contact, social media account details, CVs and application letters, and equal opportunities monitoring information.
If you sign up for our newsletter, we may collect your email address, name and company name.
If you browse our website, we may collect anonymous browsing information.
As data processor, we handle personal data passed to us for the purposes of delivering services to insolvency practitioners acting for insolvent businesses.
Data subjects include but are not limited to bankrupts, employees, directors, debtors, creditors, and associates or spouses of directors and bankrupts. The data includes but is not limited to name, contact details, NI number, date of birth, and rates and amounts of pay, bank details, health and employment records and any other data held on file by the insolvent business about the individual.
Where we collect data from
As data controller, we collect data directly from individuals at the businesses and organisations we work with, from our employees, from people applying to work for us, from people who sign up for our newsletter, and from organisations enquiring about our services.
We may also collect personal data indirectly from publicly available sources including social media and from third party sources such as background check/reference providers and other employees.
As data processor, we collect personal data via the instructing insolvency practitioner, from the directors of the insolvent business, from employees of the insolvent business, from the accountants of the insolvent business, and directly from individuals concerned.
How we use personal data
As data controller, we use personal data to enter into business contracts, to communicate in relation to providing our services and running our business, and to undertake due diligence checks on client and supplier organisations.
We use employee data to enter into employment contracts, to meet our obligations under those contracts, to run our business and to protect employee vital interests.
As data processor, we use data purely for the purposes of performing our services to the insolvency practitioner acting for the insolvent business and only in accordance with the insolvency practitioner’s instructions.
Who we share personal data with
We do not share personal data except as needed in order to run our business, deliver our services and comply with the law.
As data controller, we share personal data with third party organisations who provide services to support our business. These include our IT support provider, our email host, our accountants, cloud software providers, and our bank. We also share personal data with statutory authorities including HMRC and the Redundancy Payments Service (Insolvency Service). We may share relevant employee data with third parties seeking references.
We may, with consent, give supplier and client details to others who might be interested in the services or products their business provides.
As data processor, we share personal data with the insolvency practitioner who has instructed us, with organisations and statutory authorities as needed for the purposes of delivering our services, and with cloud-based software providers.
Third-party providers are subject to change. You can ask us for current details by emailing hello@w59.7c7.myftpupload.com or calling 0121 333 1295.
Any third-party organisation may in turn share personal data with other companies who act as sub-processors in providing support services to them.
We share personal data with the police if we have reason to suspect fraud or other criminal activity.
Where we store personal data and how we protect it
We store digital personal data on our own server and on the Turnkey and Case Pro cloud-hosted insolvency practitioner services. Paper-based data is stored in a locked room.
We destroy all personal data we hold when we no longer need it.
We use appropriate security measures to keep data stored on our own equipment secure. We may transfer data outside the European Economic Area (EEA) if necessary for business purposes or if cloud software we are using hosts data elsewhere.
We take organisational measures to ensure a level of security appropriate to the risks presented by the processing. All staff who have access to personal data are aware of the requirement to keep data secure.
The organisations we share personal data with are compliant with GDPR and have agreed to use personal data only for the purposes of helping us operate our business or as required by law.
Employee information is kept securely by our accountants. Payslips are sent electronically from our accountants and are password protected.
Legal basis for handling personal data
We rely on the legal basis of contract for handling insolvency case personal data and for handling client and supplier personal data in relation to delivering our services and procuring services and goods. We may also rely on the legal basis of legitimate interest for business development activities. For using personal data for any email marketing, we rely on the legal basis of consent.
How long we keep personal data
As data controller, we keep personal data for as long as needed in the operation of our business. We keep data connected with financial transactions for 7 years as required by HMRC. We may keep Evolve IS Ltd employee data indefinitely. We only keep personal data provided under the legal basis of consent for as long as we hold that consent.
As data processor, we keep insolvent business personal data until the case is closed. At this point we send the data back to the insolvency firm acting for the case or destroy it if requested to do so by the firm.
What happens if you do not provide personal data
We cannot provide our services unless we have the personal data necessary.
What to do if you want us to stop contacting you
If you have signed up for our newsletter you can click the unsubscribe link. If you do not want us to contact you as part of our wider business development activity, email hello@w59.7c7.myftpupload.com or call 0121 333 1295
What to do if you want us to delete your personal data
If you want us to delete your personal data, email hello@w59.7c7.myftpupload.com or call 0121 333 1295. We will let you know if we can delete the data. We can’t delete data that we need in order to file tax or other financial returns or data that must be kept for our own tax and accounting purposes.
