This document sets out our privacy policy in response to the General Data Protection Regulations effective from 25 May 2018. SCC Chartered Accountants Ltd (“SCC”) considers data privacy and protection an essential part of our professionalism and therefore set out our policy below.

SCC Chartered Accountants Ltd is a data controller within the meaning of the GDPR and a data processor. Our contact details are as follows:

Sean Cavanagh
SCC Chartered Accountants Ltd
17 College Street, Armagh, Co Armagh, BT61 9BT

Where we act as a data processor on behalf of a data controller (for example, when processing payroll),we provide an additional schedule setting out required information as part of that agreement. Thatadditional schedule should be read in conjunction with this privacy notice.

Data Collection

This statement refers to the personal data you provide to us. We will collect information such as name, address, telephone number, family background, financial information, CVs and employment history. We will also request copies of passport or driving licence together with copies of utility bills to comply with regulatory requirements.

Given the nature of some of our assignments i.e. insolvency appointments we may from time to time be provided information from 3rdparties which is personal in nature. We will typically seek to verify this with you unless to do so would prejudice the outcome of any insolvency process you are involved in or are the subject of.

During the course of our work we may collect personal data on employees, creditors, debtors and other parties who have engaged with our clients. We process this information for the purpose of the engagement and in our duty as an officer of the court (if appointed as an Insolvency Practitioner). This information is held on our systems and in a database; we only use it for the purposes of our engagement/role. From time to time we may engage a 3rdparty to assist with this and they are bound by the same standards as SCC and will process any data under our explicit instruction.

We will process your personal data for the purpose of providing our services to you as agreed for the engagement, because this processing is necessary for us to fulfil our obligations under our contract with you. If you have given us consent, we may also use your contact information to market our services to you in the future.

We have policies and procedures in place to ensure that your personal information is secure, accurate, up-to-date and kept only for so long as is necessary for the purpose for which it is needed. We will retain your personal data for seven years because we believe that we have a legal responsibility to retain it for this period arising from this engagement. Following this, we will destroy the data unless we have a separate obligation to retain the data for a further period.

How We Collect Data

We may collect data from you directly. Where you are a client or prospective client, we may also collectdata from representatives or people who are providing you with other services.

We collect data from the following sources:

• From you or your representatives directly where you complete forms on our website or when youcorrespond with us in other ways such as by email, in-person, post or over the phone. This maybe where you are seeking further information on our services or where you are registering toattend events facilitated by us.
• From relatives, agents or third parties where you may be involved in a matter we are instructedin for example as a beneficiary, trustee, buyer, seller, debtor, creditor, employee or employer.
• From other organisations which have referred you to us, for example, solicitors, accountants,financial advisers, insurance companies, financial institutions.
• Online public sources or registers such as Companies House.
• Where you apply for a position with us, we may receive information about you from a recruitmentagent, your current and/ or former employers and/ or referees.
• Devices you use when you use our service via cookies.

Website

We use the personal data you have provided to us to respond to your queries when you contact us. If you become a client, your personal data will be stored on your file with us. If you do not become a client, we will delete your personal data when deemed appropriate.

Data Sharing

The data will not be shared with any third party, except where we have a legal or professional duty to do so, or where we engage a third party to store data on our behalf within the European Economic Area (ie. a cloud computing provider). We will put in place and maintain adequate physical, procedural and electronic safeguards to maintain the integrity and confidentiality of the data stored by us and we will take reasonable steps to ensure that safeguards of an adequate standard are put in place by any third party engaged by us to store this data.

We share your personal data with our IT service providers, including our accounting software provider. These providers are not permitted to use this data, except on our behalf. We may share your personal data with advisors who are subject to rules of confidentiality. We may also be obliged to provide access to your personal data to regulators, including our professional body.

Your Rights

In accordance with GDPR, you have certain rights in relation to the information we hold about you:

• certain circumstances you have the right to erasure of your personal data
• You may restrict the processing of your data, object to the processing of your data and to portability of your data; and
• Where we have relied on your consent to process your personal data, you have the right to withdraw your consent.

Automated Decision-Making

We do not intend to use automated decision-making in relation to your personal data.

Complaints (UK)

We seek to resolve directly all complaints about how we handle personal information. Please send your data protection queries to us at info@scc-ca.com. You also have the right to lodge a complaint with the Information Commissioner’s Office, whose contact details are as follows:

Information Commissioner’s Office
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire.
SK9 5AF

Telephone 0303 123 1113 (local rate) or 01625 545 745
Website https://ico.org.uk/concerns

Complaints (ROI)

We seek to resolve directly all complaints about how we handle personal information. Please send your data protection queries to us at info@scc-ca.com. You also have the right to lodge a complaint with the Data Protection Commissioner, whose contact details are as follows:

Data Protection Commissioner
Canal House,
Station Road,
Portarlington,
Co. Laois,
R32 AP23,
Ireland.

Telephone +353 (0761) 104 800 | LoCall 1890 25 22 31 | Fax +353 57 868 4757 |
Website https://dataprotection.ie/docs/Home/4.htm
Email: info@dataprotection.ie
We may amend this privacy notice from time to time. If we do so, a copy of our current privacy notice canbe found on our website at www.scc-ca.com.