Privacy Notice

The Association of Business Recovery Professionals (“R3”) Privacy Notice

Who we are:
R3 is the trade association for the UK’s insolvency, restructuring, advisory, and turnaround professionals. We represent licensed insolvency practitioners, lawyers, turnaround and restructuring experts, students, and others in the profession.

Our members work across the spectrum of the profession, from the global legal and accountancy firms through to smaller, local practices. Our members have direct experience of insolvencies and their impact on the UK economy and insolvent companies’ stakeholders.

The insolvency, restructuring and turnaround profession is a vital part of the UK economy. The profession rescues businesses and jobs, creates the confidence to trade and lend by returning money fairly to creditors after insolvencies, investigates and disrupts fraud, and helps indebted individuals get back on their feet.

The UK is an international centre for insolvency and restructuring work and our insolvency and restructuring framework is rated as one of the best in the world by the World Bank. R3 supports the profession in making sure that this remains the case.

R3’s work includes:

• Technical support for members
• Education, training and networking opportunities
• Public affairs, press and policy work
• Support for all practice sizes, including dedicated smaller
  practice support
• Marketing and advertising opportunities
• Guidance for businesses and individuals

Protecting your personal data
R3 is committed to protecting the privacy and security of your personal information. This privacy notice explains how we use, hold and retain any personal information we collect about you in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) in our capacity as a “data controller”. “Personal information” is information that identifies you as an individual or relates to an identifiable individual. R3 is a “data controller” in respect of the information we collect, use, hold and retain about you as set out in this privacy notice. In this privacy notice we refer to our collection, use, storage and retention of your personal information as “processing”.

Updates to this privacy notice
This privacy notice may be updated from time to time. The “Last Updated” section at the end of the privacy notice indicates when it was last revised. Any changes that we make to this privacy notice will be effective from the date specified at the end of the revised privacy notice. Your continued membership of R3, or use of our services, following any such changes indicates that you have accepted them.

Duty to inform us of changes
It is important that the personal information we process about you is accurate and current. Please keep us informed if your information changes during your relationship with us.

Third-party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy or notice of every website you visit

What information do we collect?
When you join R3 as a member or when, as a non-member, you register with us to attend one of our regional or national events, courses or conferences, we collect information about you such as name, date of birth, postal address, e-mail address, company name, company address, job title, telephone number, bank account details, IP addresses and insolvency practitioner or other professional licence holder details.

Why do we process information about you?
We process information about you to enable us to carry out our functions as a trade association. We only process your personal information to the extent that we consider it is in our legitimate interests to do so, where it is necessary to perform services to our members and non-members or where we have a legal obligation to process your personal information.

For example, the personal information we collect about you will allow us to ensure we are able to communicate with you as and when needed and to bring matters to your attention. This will include (but not be limited to):
- Details of membership renewals
- Technical and best practice guidance
- Details of lobbying carried out on behalf of the profession
- Member surveys
- Consultation processes
- Details of training courses, seminars, conferences, events and networking opportunities organised or arranged by R3

What do we do with the information which we collect about you?
1. Membership Administration: We may process personal information for the purposes of administering your R3 membership; the communication of information and the organisation of events.

2. Marketing: We may use personal information provided at the time of booking an R3 course, conference or other R3 sponsored event, to provide you with further details of R3 courses, conferences and other R3 sponsored events and information about the benefits of R3 membership.

3. Course, conference and event materials: Members and non-members booking onto a course, conference or regional event who have opted to do so may have their details (name and firm) included on a delegate list which will be published in the course materials and provided to all other delegates and speakers.

4. Third parties: We will not share your personal information with any third parties EXCEPT that (i) we may share your personal information to INSOL International in order that they may effectively administer your automatic membership of that body; and (ii) your personal information may be provided to R3 Regional chairs for the purpose of organising regional events.

5. R3 Directory: Personal information of R3 members who have opted to do so will be included in the R3 Directory which is freely available both to members and other interested parties.

Automated technologies and Cookies:
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. This information does not reveal your specific identity. We collect this personal data by using server logs and other similar technologies such as IP address identification and logging.

R3 may also use cookies to collect information on you such as your browser type, time spent on the website services, pages visited, language preferences, and other traffic data. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the website services.

R3 may use Google Analytics, which uses cookies and similar technologies to collect and analyse information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.


Data security:
We have put in place appropriate security measures to prevent your personal data 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 also put in place procedures to deal with any suspected personal data breach and will notify you and the regulator of a breach where we are legally required to do so. We cannot guarantee the security of any personal data that you disclose online, for example when it is sent by email. You accept the inherent security risks of providing information online over the internet and will not hold R3 responsible for any breach of security unless this is due to R3's negligence or wilful default.

Data transfers:
R3 is based in the European Economic Area (“EEA”). We do not envisage that we will transfer your personal information outside the EEA. If we were to transfer personal data to any affiliate entities or to third parties outside of the EEA, we would ensure your personal data is properly transferred by ensuring one or more of the safeguards permitted by the GDPR.

How you can check what data we hold about you?
If you wish to see the personal information which we hold about you, you should contact us by emailing the Membership Officer Shemin.varma@r3.org.uk or in writing to; Membership Officer, R3, 8th Floor, 120 Aldersgate Street, London, EC1A 4JQ.

We want to make sure that your personal information is accurate and up to date. Please contact us to correct or remove information you think is inaccurate.

How long do we keep your data for and why?
R3 will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In particular:
1. Members: Our current policy is to retain membership data during membership and for a period of 10 years following cessation of membership. This is so that we have a record of your membership should you wish to renew your membership. Our experience has shown that members may suspend membership for significant periods of time (e.g. if they are working abroad or on periods of career or parental leave).
2. Non-members: Non-member details will be kept for a period of two years from the date of the last R3 sponsored course, conference or event attended. You may opt out of receiving information from R3 at any time by contacting the Courses Administrator by emailing Maggie.dean@r3.org.uk, by clicking the “Unsubscribe” button at the bottom of emails from us or in writing to; Courses Administrator, R3, 8th Floor, 120 Aldersgate Street, London, EC1A 4JQ.

Your rights:
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights include your right to:

- request access to your personal data;
- request correction of your personal data;
- request erasure of your personal data;
- object to processing of your personal data;
- request restriction of processing your personal data;
- request transfer of your personal data; and
- right to withdraw consent

If you wish to exercise any of the rights set out above you can email the Membership Officer Shemin.varma@r3.org.uk or write to; Membership Officer, R3, 8th Floor, 120 Aldersgate Street, London, EC1A 4JQ.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints:
If you have a concern about the way we are collecting or using the information that we collect about you, we would encourage you to please raise your concern with us in the first instance. Alternatively you can contact the Information Commissioner’s Office at https://ico.org.uk/concerns/

Changes to our privacy notice:
We keep our privacy notice under regular review and we will place any updates on our website www.r3.org.uk. This privacy notice was last updated on 18 July 2018.

The identity and contact details of the R3 employee responsible for data protection is:
Emma Lovell, Chief Executive Officer
E: emma.lovell@r3.org.uk
R3, 8th Floor, 120 Aldersgate Street, London, EC1A 4JQ