IPA Privacy Notice
The Insolvency Practitioners Association (IPA) are committed to protecting your privacy and rights. We strive to be transparent about how your personal information is used and are committed to using your personal information in accordance with all applicable data protection laws. We are the data controller of your data.
Our Privacy Notice Explains:
- What information we collect from you
- Why we collect this information
- With whom we might share this information
- How we will secure your information
- How long we keep hold of your information
- How you can access the information we hold about you
- How changes are made to this policy.
What information we collect from you
The IPA may collect, process and use some of all of the following categories of personal information about you:
- Identity Data such as first name, last name, title, date of birth, and gender;
- Contact Data such as billing address, delivery address, email address and telephone number;
- Profile Data such as your preferences, feedback and survey responses;
- Usage Data such as information about how you use our products and services;
- Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties, and your communication preferences;
- Employment / Education Data (if you are applying to the IPA for a job) such as your employment history, education history, other information provided on your CV, and references.
If personal data is collected as part of the complaints procedure, the data collected may include further information that the complainant deems to be pertinent to the case. Where possible the IPA will look to redact personal information from the case file.
In rare circumstances, where necessary, we may collect special category data such as health data, or criminal offence data such as criminal convictions.
Why we collect, process, and use this information
|Purpose/Activity||Type of data||Lawful basis for processing|
|To verify your information and register your membership||(a) Identity (b) Contact||(a) Performance of a contract with you (b) Necessary for our legitimate interests|
|To provide you with ongoing member services including details of events, professional guidance, learning opportunities, and send you marketing that may be of interest to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests|
|To deal with and respond to complaints||(a) Identity (b) Contact||(a) Necessary for our legitimate interests|
|To process a job application||(a) Identify (b) Contact (c) Employment / Education||(a) Necessary for our legitimate interests|
|To fulfil our regulatory obligations including inspecting and regulating our members||(a) Identity (b) Contact||(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests|
We may also collect and process information where you have given us your consent to do so.
With whom we might share this information
We do not sell your information to any third parties but may share your information with trusted third parties including marketing companies to inform you of our new services or upcoming events. We may also share information with the Insolvency Service and other regulators for the purposes of fulfilling our regulatory obligations, as well as with our service providers and professional advisers (e.g. our lawyers) who are subject to confidentiality obligations.
Where information is collected as part of the complaints procedure, a job application, or for inspection of our members, this information will only be shared internally, with our professional advisors, with the Insolvency Service, and with other regulators.
We may, with your prior consent, publish your details to our website as part of our “Find an IPA member” service. Where you have passed an exam, we may, with your prior consent, publish these results on our website.
How we will secure your information
We ensure that there are appropriate controls in place to protect your personal data. For example our network is protected and routinely monitored. Your personal data will only be accessible by appropriately trained staff whose job roles require such access. All third parties used by us will be subject to contractual confidentiality arrangements which will be periodically reviewed.
How long we retain your information
We will store your personal information only for as long as we consider it necessary to carry out the activities documented above or as is necessary to comply with an applicable law or regulation. In the case of an adverse finding against an insolvency practitioner, this would not normally be longer than ten years. Regular reviews are carried out and where data is found to be no longer relevant, the data is securely deleted or physically destroyed.
Where we have collected data as part of a job application, this data will be stored securely and only accessible by trained staff who require such access. Unsuccessful applicants’ CVs will be retained for a period of no longer than 3 months. Where we wish to retain such an applicant’s CV for longer, we shall contact them direct and obtain consent. All CVs no longer required shall be securely deleted or physically destroyed.
How you can access the information we hold about you
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
Your legal rights include:
- to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you would like further information about the rights you have, or if you would like to make a data subject access request, or if you have any queries regarding this Privacy Notice, please contact our data protection officer, Sarah Munroe, at firstname.lastname@example.org.
If you are unsatisfied with our response to a data subject access request or any other data protection related query or complaint, you have the right to escalate the issue to the Information Commissioner’s Officer.
Changes to this policy
This policy was last updated on 30 January 2023.