Who are we?
The Insolvency Panel Ltd (TIP) treat privacy very seriously and we want you to feel confident about how we process your personal data. This notice outlines how we process your data in accordance with the law. We are a Data Controller registered with The ICO (Reg. No. ZA309410).
We act as an intermediary and technology service between advisors, providers of debt solutions and consumers. We do not directly provide or administer debt solutions.
Advisors and solution providers
that use our services may provide and/or administer popular debt solutions in England & Wales including Individual Voluntary Arrangement (IVA), Debt Management Plan (DMP), Debt Relief Order (DRO) and Bankruptcy. Different solutions are available to Scottish residents and include the Debt Arrangement Scheme (DAS), Protected Trust Deed (PTD) and Sequestration. A recognised Advisor or Provider can provide you with detailed information on debt solutions
Our role is to improve the speed and quality of debt advice and solutions by providing accurate data through technology. We also provide a panel of screened debt solution providers. We monitor the outcomes of debt solutions so that we can improve the quality of debt advice and administration going forwards. We have no say or influence over the outcome of a particular customer’s debt solution.
Our postal address is: – The Insolvency Panel Ltd, Trinity House, Newby Road, Hazel Grove, SK7 5DA
Or you can email – firstname.lastname@example.org
Your Advisor will decide if they wish to use our services to help identify the best debt solution. They may do some or all of the following:-
- Access your Credit Report;
- Access your Bank Transaction data;
- Access your vehicle details for valuation purposes;
- Instruct us to pass your case on to one of the carefully selected debt solution providers on our panel.
The personal data we would like to collect and process on you is:
Personal data type:
Source (where The Insolvency Panel Ltd obtained the personal data from if it has not been collected directly from you, the data subject):
|Name, address, contact details, date of birth, dependents, employment details.||Advisor|
|Financial Information relating to your income, expenditure, assets and debts including account identifiers||Advisor
Credit Reference Agency (credit report including account identifiers)
DVLA Search (vehicle valuation)
Account Score (Bank Transaction Data)
|Special Category Data – Health information relevant to your income, expenditure and your ability to deal with your debts.||Advisor|
The personal data we collect will be used for the following purposes:
- Credit Reports – will be held for access by your appointed advisor and will include the account identifiers (otherwise known as account numbers) to help them provide you with effective debt advice. To achieve this the data provided by you will be provided to the following Credit Reference Agencies to assist with identity verification, prevention of fraud/money laundering, and any other uses that may be mutually agreed upon by the parties from time to time:
a) TransUnion Information Group. You can view the TransUnion Bureau Privacy Notice at https://www.callcredit.co.uk/legal-information/bureau-privacy-notice
b) Experian Limited. You can view the Experian Privacy Notice at https://www.experian.co.uk/consumer/privacy.html
2) Bank Transaction Data (including account identifiers) – will be held for access by your appointed advisor.
3) When we are instructed by your advisor, we will pass your case to one of our debt solution panel members. We will check whether you have specific needs that maybe better suited to a given debt solutions provider, otherwise we will refer your case to the provider due to receive the next case. If a provider declines to deal with your case, we may refer you to another provider on the panel.
a) The provider will use all of your information to decide whether to accept your case. If they accept your case, they will contact you directly and issue you with their own privacy notice. In accepting your case the provider does not guarantee a debt solution will go ahead and you may also need to provide them with further information. To protect you, you will not enter into a debt solution unless and until you sign a further agreement.
4) Should you go ahead with a solution provided by a panel member we will monitor the performance of your solution in the context of monitoring the provider’s overall performance.
- Valid8 IP Ltd shall act as a Processor on behalf of The Insolvency Panel Ltd in relation to the Consumer Data and the terms of this processing shall be covered in a separate agreement between Valid8 IP Ltd and The Insolvency Panel Ltd.
- Valid8 IP Ltd will only share Credit Reports, including the account identifiers, with the debt advisor or Insolvency Practitioner who requested the information.
- Providers we currently refer cases to can be found here https://tipiva.org.uk/panel. We have written agreements in place with the Debt Advice Agencies who refer cases to us and with the Providers we pass cases onto. These agreements include the security arrangements in place to ensure your data is shared securely.
- We will not pass on your personal data to other third parties other than those mentioned.
How we store your personal data
- All information you provide to us is stored on our secure servers.
- We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
- We have put in place 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.
Our legal basis for processing your personal data
- Your consent for initially receiving and processing your data.
- Our Legitimate Interest, once you have taken up a solution with a TIP panel provider.
Legitimate interests pursued by us, or third parties we use, are as follows:
- Monitoring the progress of your solution in the context of the provider’s overall performance.
- We will not use this profiling to make decisions that affect you. We carry out this profiling to improve solutions for all existing and future consumers.
- Your name will not appear in any reports we create or use, you will be identified using a reference number or we will anonymise your data completely.
- We have carried out an assessment of the risks when we pursue our legitimate interest and concluded there is minimal risk to you.
When you complete the consent form you are consenting to this privacy notice. You are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for The Insolvency Panel Ltd to process both types of personal data, but it must be explicitly given. Where your advisor asks for sensitive personal data, they will always tell you why and how the information will be used.
Where we rely on your consent you may withdraw it at any time by completing a Withdrawal of Consent Form. You can get a copy of this form from your Advisor or by emailing email@example.com
- Credit Reports – will be stored for 30 days and then deleted.
- Banking Transaction Data – will be stored for as long as we have your consent.
- Referrals to debt solution providers – The Insolvency Panel Ltd will process your personal data for the time of your debt solution and will store the personal data for one year after the conclusion of your debt solution. If your debt solution does not proceed, we will delete your personal data within one month. This includes when you withdraw consent and you have not taken a debt solution with a member of our panel.
For Advisors & Insolvency Practitioners
When you register on our website, we rely on the need to fulfill a contract to collect and process your name, business email address, and details of your employer. We may also need your business address and telephone number.
How and why we collect your information
We collect your information through the registration form you fill in. We will send you emails with information about TIP detailing how the service is developing. We may also contact you about a specific case if we have questions or we want to return the case to you. We also need your details to process the consumer’s case.
Who we share your information with
We will pass the Advisors details to the debt solution provider every time we pass on a case submitted to us. We will not share your details with anybody else.
Email – We may also, in order to email you, need to transfer personal information you submit to us to countries or jurisdictions outside the EEA. In such instances, we will ensure that we will only transfer personal information to secure organisations with good data protection practices. We will keep the personal information contained in emails to a minimum.
We store the personal data of advisors and debt solutions provider staff for as long as is necessary to manage our relationship. It is up to the advice agency to inform us if an advisor has left their organisation. Please contact us if you need to update the contact details for your agency by emailing the contact details at the top of the page.
At any point whilst we are in possession of, or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Please bear in mind the retention periods mentioned above.
- Right to object/restriction of processing – if you wish us to stop, pause or restrict processing your data please contact us via your advisor or follow the instructions on the Consent Withdrawal Form.
- Right of portability – we can download the data we hold about you into a machine-readable format. Please contact us via your advisor if you require this.
- Right to complain: in the event that The Insolvency Panel Ltd refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the clause below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by The Insolvency Panel Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority.
The details for each of these contacts are:
|Supervisory authority contact details||GDPR Owner contact details|
|Contact Name:||Information Commissioner’s Office (ICO)||Privacy & Data Manager, The Insolvency Panel Ltd|
|Address line 1:||Wycliffe Lane||Trinity House|
|Address line 2:||Water Lane||Newby Road|
|Address line 3:||Wilmslow||Hazel Grove|
|Address line 4:||SK9 5AF||SK7 5DA|
|Telephone:||0303 123 1113||n/a|
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Please note: The Insolvency Panel Limited website contains hyperlinks to websites owned and operated by third parties. These third-party websites will have their own privacy policies, including cookies, and we suggest that you check them. They will govern the use of any personal information which is collected by cookies while visiting these websites. The Insolvency Panel Limited cannot accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
– ENDS –