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At MPH Recovery, we always strive to provide a professional and efficient service. However, I recognise that it is in the nature of insolvency proceedings for disputes to arise from time to time. Therefore, should you have any comments or complaints regarding the administration of this case, then you should contact me at the address given below in the first instance.

If you consider that I have not dealt with your comments or complaint appropriately, please provide details of your concerns in writing to our complaints officer, Lydia Weil, MPH Recovery, City Mills, Peel Street, Morley, Leeds, LS27 8QL. This will invoke our complaints procedure and we will endeavour to deal with your complaint under the supervision of a senior member of staff unconnected with the appointment.

However, in the event that you have exhausted our complaints procedure and you are not satisfied that your complaint has been resolved or dealt with appropriately, you may ask for the complaint to be referred to the appropriate regulatory body that licences the Insolvency Practitioner concerned. Any such complaints should be addressed to IP Complaints, The Insolvency Service, 3rd Floor, 1 City Walk, Leeds, LS11 9DA. The name of the Insolvency Practitioners licencing body will be contained in any formal correspondence from him.

Further information in regard to the service regulations can be found at www.mph4recovery.com/service-regulations

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Licensing Body

Martin Paul Halligan is licensed to act as an Insolvency Practitioner in the United Kingdom by the Association of Chartered Certified Accountants.

Martin Paul Halligan is a member of The Association of Chartered Certified Accountants.

Rules Governing Actions

All IPs are bound by the rules of their professional body, including any that relate specifically to insolvency. The rules of the professional bodies that licence the IP of MPH Recovery can be found at http://www.insolvency-practitioners.org.uk/]. In addition, IPs are bound by the Statements of Insolvency Practice (SIPs), details of which can be found at https://www.r3.org.uk/what-we-do/publications/professional/statements-of-insolvency-practice.

Ethics

All IPs are required to comply with the Insolvency Code of Ethics and a copy of the Code can be found at www.gov.uk/government/publications/insolvency-practitioner-code-of-ethics.

Professional Indemnity Insurance

MPH Recovery’s Professional Indemnity Insurance is provided by QBE Insurance (Europe) Limited, Plantation Place, 30 Fenchurch Street, London, EC3M 3BD. This professional indemnity insurance provides worldwide coverage, excluding professional business carried out from an office in the United States of America or Canada, and any action for a claim brought in any court in the United States of America or Canada.

VAT

MPH Recovery is registered for VAT under registration no.921 7056 40.

Bribery Act 2010

MPH Recovery is committed to applying the highest standards of ethical conduct and integrity in its business activities. Every employee and individual acting on MPH Recovery’s behalf is responsible for maintaining our reputation and for conducting company business honestly and professionally.

MPH Recovery take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate.

MPH Recovery requires all those who are associated with it to observe the highest standards of impartiality, integrity and objectivity.

MPH Recovery prohibits anyone acting on its behalf from:

• bribing another person. A bribe includes the offering, promising or giving of any financial or other type of advantage;
• accepting a bribe. This includes requesting, agreeing to receive or accepting any financial, or another kind of advantage;
• bribing a foreign public official; and
• condoning the offering or acceptance of bribes.

MPH Recovery will:

• avoid doing business with others who do not accept our values and who may harm our reputation;
• maintain processes, procedures and records that limit the risk of direct or indirect bribery;
• promote awareness of this policy amongst its staff, those acting on its behalf and entities with which it has any commercial dealings;
• investigate all instances of alleged bribery, and will assist the police, and other authorities when appropriate, in any resultant prosecutions. In addition, disciplinary action will be considered against individual members of staff;
• review this policy regularly and update it when necessary.

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INTRODUCTION & TERMS

A Privacy Statement is a document explaining to you, if you are an individual, how your personal data will be used by us and what your rights are.

MPH (GB) Limited T/A MPH Recovery (“MPH Recovery”) and Martin Paul Halligan (when acting as office holder under insolvency legislation) are committed to protecting and respecting your personal data and privacy. This privacy policy relates to our use of any personal data we collect from you from any of our services or when Mr. Halligan is acting in person. Whenever you provide such information, we are legally obligated to use this information in line with the Data Protection Ac 1998, The General Data Protection Regulations 2016 and other subsequent laws (“DP Laws”).

Please read the following carefully to understand our practices regarding your personal data

CONTACT

Any Company or Individual for whom we act is a Data Controller in their own right. When MPH Recovery is instructed to perform services under a contract which requires it to process personal data, it is also a data controller. Due to the nature of our work, a licensed insolvency practitioner who is an office holder under insolvency legislation can also be considered a data controller in their own right in respect of the cases over which they are appointed as they are required to process personal data by statute. In accordance with this, both MPH Recovery and the relevant insolvency practitioners employed by it, are registered with the Information Commissioners Office. Further information about this or our privacy policy can be requested by contacting:-

Martin Halligan, MPH Recovery, City Mills, Peel Street, Morley, Leeds LS27 8QL

Email: info@mph4recovery.com

Telephone: 01132531445 – Ask for the Privacy Officer

PERSONAL DATA

Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data – the information we use to identify you, which may include data contained in photographs.
• Contact Data – the information we use to contact you.
• Financial Data – details of your income and expenditure, assets and liabilities and ancillary data such as your bank account details
• Transaction Data – includes details about payments to and from you
• Communications Data – your communication preferences, for example any opt out exercised by you under Insolvency legislation.

We may collect some ‘special category’ personal data from you including (but not restricted to) details of your health, or whether you are a member of a Trade Union, where this is necessary to meet our legal or regulatory obligations. We may also collect information about criminal convictions and offences and whether you have been previously involved in any personal or corporate insolvency proceedings.

HOW WE COLLECT PERSONAL DATA

The personal data we initially used to contact you was provided by the Company or Individual on whose instructions the Company is acting or in relation to which Mr Halligan has been appointed as Office holder. Your personal data may also be collected from the following sources:

• Records that our client or the insolvent Company or individual already holds about you.
• Questionnaires and Forms completed and submitted by you, for example to the Redundancy Payments Service or to us.
• Correspondence and other communications or meetings between you and the Firm, including via our website or on social media
• Information provided to the Firm by third parties in relation to an appointment, for example your bank, your professional advisers or the Insolvency Service.
• Information held in the public domain (for example, at Companies House and the Land Registry).

Other data controllers (including clients) may also provide your personal data to us.

HOW WE USE PERSONAL DATA

Most processing is carried out to comply with the Office holder’s legal and regulatory obligations or to enable MPH Recovery to provide a service in accordance with its contractual terms. Personal data will be used to verify identity (where this is required), for communications, to maintain records and process transactions. It may also be used to facilitate the performance of investigations (including the prevention of fraud), the realisation of assets and the agreement and settlement of financial claims. Your personal data may therefore be used for more than one purpose.

DISCLOSURE OF YOUR PERSONAL DATA

Mr Halligan and MPH Recovery have a legal obligation, in certain circumstances, to disclose personal data to:

• Mr Halligan’s regulatory body, the Association of Chartered Certified Accountants and its subcontractors.
• The Secretary of State (including, but not restricted to, the Official Receiver).

Mr Halligan and MPH Recovery may also be under an obligation to provide your personal data to other third parties who have a statutory right to request it (for example, HMRC and Law Enforcement Agencies) or who have obtained an appropriate court order.

We may also share your personal data with:

• Our accountants, solicitors, insurers and sub-contractors
• Other Governmental or relevant regulatory bodies.
• Third parties who support us in providing our IT systems, including our website, e mails, data backup and storage.
• Third parties who archive our paper records
• Third party professional service providers instructed on a case by case basis by the Office holder or the Firm, including (but not restricted to) accountants and tax advisers, solicitors, valuers, debt collection agencies and service providers who may assist with the calculation of employee claims or pension deficits and contributions. They will only process your data on our instructions and they are under a professional duty of confidentiality.

PROTECTION OF YOUR PERSONAL DATA

Policies and commercially reasonable and appropriate procedures are in place to safeguard your personal data from loss, misuse and improper disclosure.

• Relevant training
• Digital personal data is held in secure data centres potentially located worldwide (and therefore potentially outside of the EEC).

• Paper personal data is held at the Firm’s offices in Morley, or, if the case has been closed, in a secure off-site third party storage facility.

We also have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

All our third-party service providers are required to take appropriate security measures to protect your personal information. We only allow third-party service providers to process your personal information for specified purposes and in accordance with our instructions.

YOUR RIGHTS

Informed

MPH Recovery must make this privacy notice available with the emphasis on transparency over how we process your data.

Access

You are entitled to find out what details we hold about you and why.

Rectification

We are obliged to correct and update your details.

Erasure

The request to be forgotten. This right does not apply when we hold your data under a legal obligation.

Restrict Processing

You have the right to block or suppress the processing by us of your personal data. This right does not apply when we hold your data under a legal obligation.

Data Portability

You have the right to obtain and reuse your personal data that you have provided to us. This right does not apply when we hold your data under a legal obligation.

Object

You have the right to object us processing your data in relation to direct marketing and or profiting only. This right does not apply when we hold your data under a legal obligation.

DATA RETENTION

We will only retain your personal data for as long as necessary. This necessity includes the purposes of satisfying any legal, accounting, regulatory or reporting requirements.

In line with these requirements personal data will generally be held for no longer than 6 years after the closure of an assignment or insolvency appointment.

If you have opted out of receiving future correspondence from us, your contact details will remain on our opt-out list to prevent you from receiving any further correspondence from us except where we are obliged to contact you by insolvency legislation.

DATA DELETION

Your have the right to erasure under specific circumstances. A request for deletion of your personal data will be adjudicated upon on a cases by case basis and any request must be submitted in writing, as detailed above.

DATA CORRECTION

MPH Recovery will correct or update your data without delay provided you make the request in writing to the contact details provided in this policy, clearly specifying which data is incorrect or out of date.

DATA INSPECTION

We strive to be as open as we can be in terms of giving people access to their personal data. Individuals can find out if we hold any of their personal data by making a formal request under the Data Protection laws. Such requests must be in writing to the details set out in this policy. If we hold personal data we will respond in writing within one calendar month of your request, where requested in accordance with the policy. The information we shall supply will:

• Confirm that your data is being processed;
• Verify the purpose of the processing;
• Categories of personal data being processed;
• Confirm the type or recipient to who the personal data have been or will be disclosed, and
• Let you have a copy of the data in an intelligible form.

You willl need to provide identification in order to prove who you are to access your data.

In the first instance, and if you agree, we will try to informally deal with your request by providing you with the specific information you need over the telephone.

In the instance that we do not hold information about you, we will also confirm this at the earliest opportunity in writing.

COMPLAINTS

You have the right to complain about the processing of your personal data. Please contact us using the details above. If you are still dissatisfied you have the right to complain to The Information Commissioners Office.

GENERAL

We may amplify this Privacy Statement at the point of data collection.

We may change the terms of this Privacy Statement from time to time and will place any updates on our website www.mph4recovery.com/gdpr. This version is dated 25 May 2018.

Paper copies of this Privacy Notice can be obtained free of charge by written request to our offices at the address given above.

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