Legal Processing of Data for InfolinkGazette Customers

25/05/2018

Contents
About the Vendor
Introduction
What is Personal Data
Is ILG affected by the GDPR
Does ILG obtain consent from the individuals it processes data on
How does ILG process personal data without consent
What Information does ILG Provide to Data Subjects

About the Vendor

InfolinkGazette (ILG), a trading style of Connell Data Ltd is a commercial data collection bureau, supplying commercial risk and opportunity data to its clients, together with the tools required to maximise the value of the data. Distribution is primarily through information re-sellers, such as Credit Reference Agencies and Data Aggregators, but also to end users of information in the Credit Insurance, Debt Recovery and Insolvency sectors.

ILG started out by collecting and digitising all the information available on UK and Irish Insolvency appointments, and in particular, the UK unsecured creditors listings, which are used for both risk management purposes and identifying opportunity. More recently, ILG diversified data collection strategy to cover a wider range of commercially available information, all sourced from data that isn’t available in a practical digital format, but continued to concentrate on their core customer requirements, providing information suitable for credit risk assessment or prospect targeting.

ILG also provide bespoke product development, software solutions and hosting services, for their data customers, including: Case Management Systems; Credit Scoring & Decisioning Systems; API’s and online portals.

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Introduction

From 25/05/2018, all companies will be subject to the requirements of the General Data Protection Regulation (GDPR) when processing personal data on European (EU) residents. This document sets out some frequently asked questions and sets out InfolinkGazette’s (ILG’s) position on GDPR

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What is Personal Data

Personal data is any information relating to an identified, living individual, in either a private, business, or professional context and includes sole proprietors, insolvency practitioners and directors (data subjects).

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Is ILG affected by the GDPR?

Yes, even though ILG only processes business data, neither the GDPR, or the legislation it is replacing, make a distinction between private and business information. Accordingly, ILG has always processed: directors; partners; owners; insolvency practitioners, as personal data, and will continue to do so.

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Does ILG obtain consent from the individuals it processes data on

Consent is one of six grounds under which companies can process personal data; due to the size of our database and the nature of our work, consent is not always the most appropriate grounds.

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How does ILG process personal data without consent

We process data to enable businesses to manage financial risk, protect against fraud and meet regulatory compliance requirements. We process personal data for these legitimate business purposes, and consent is not required. We meet the GDPR principles as follows: we do not process data in a manner that is incompatible with what it was collected for; we collect the minimum amount of data to ensure our data is accurate and up to date; we only store the data for as long as it is necessary, and for a maximum of 6 years; we have the appropriate measures to keep the information confidential.

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What Information does ILG Provide to Data Subjects

As part of our work to identify corporate insolvencies, we collect the name of the Insolvency Practitioner, firm name and trading address of Insolvency Practitioners, when they are appointed as: Liquidator; Receiver; Administrator; or, Examiner, in a corporate insolvency.

We will obtain this information about you, when you publish notices of an insolvency in official gazettes, national newspapers, or official registries, and we will share this information with Credit Reference Agencies and Data Aggregators that maintain company databases. The information will be used to inform creditors and interested parties that: an insolvency has taken place; the type of insolvency; who has been appointed as insolvency practitioner; and, who are the creditors. The information may also be used for statistical analysis of corporate insolvencies.

There are circumstances where the law allows us to disclose data without the data subject’s consent, on the basis that: the individual has already made the information public, and that it falls within the legitimate interests.

We regard the lawful and correct treatment of personal information to be of vital importance to our business and maintaining the confidence of those with whom we deal. For further information on how your personal data is used, and your rights of access, please email greg@connelldata.co.uk providing your name and contact details, and we will call you back.

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