Introduction
Interpath (“Interpath”, “we”, “us”, “our”) is dedicated to protecting the confidentiality and privacy of information entrusted to us in accordance with applicable data protection legislation, including the EU General Data Protection Regulation (“GDPR”), the GDPR as it applies in the United Kingdom (“UK GDPR”), the UK Data Protection Act 2018, and all other applicable data protection laws in the territories in which we operate.
Insolvency services
When an Interpath staff member is appointed as an office holder in insolvency proceedings under local insolvency and similar laws and regulations (e.g., a liquidator or administrator in corporate proceedings or a trustee in bankruptcy proceedings) ("Office Holder"), the Office Holder holds the appointment in their personal capacity. The Office Holder will act either as a separate controller or as an agent for the insolvent company. In the latter case, the insolvent company not the Office Holder will be the ultimate controller. It is important to note that Interpath does not itself accept appointments as an Office Holder.
What is this notice about?
This Privacy Notice sets out how the Office Holder processes information about you (referred to as “personal data” within this Privacy Notice), including how the Office Holder collects and uses this personal data and your rights in relation to this personal data.
This Privacy Notice applies to the Office Holder's processing of personal data relating to individuals involved in or subject to formal insolvency proceedings including, but not limited to, bankruptcy in respect of individuals; and receivership, administration, creditors’ voluntary liquidation, compulsory winding up, company voluntary arrangement, court appointments, examinerships and members’ voluntary liquidation in respect of corporate entities, noting that this is not an exhaustive list and other additional localised appointments may apply (“Insolvency Services”).
This Privacy Notice does not apply to Interpath's processing of personal data; it only applies to the processing of personal data by or on behalf of the Office Holder as controller. For information about Interpath's processing of personal data in the context of Insolvency Services, please see the Interpath Client Privacy Notice.
This Privacy Notice is supplemented with specific information relating to each country in which Interpath's Office Holders operate. Please see the relevant Country-Specific Information section at Appendix 1 attached.
Who is responsible for your personal data?
Licenced insolvency practitioners are appointed in their personal capacity to act as Office Holders in the insolvency of a company or individual. When appointed in this capacity, it is the relevant Office Holder, not Interpath, who is responsible for the personal data they process in the exercise of their duties.
In the context of an insolvent company
When the Office Holder is acting on behalf of an insolvent company, the Office Holder acts as agent for the insolvent company and it is the insolvent company that is responsible for your personal data. This Privacy Notice does not apply to the Office Holder's handling of your personal data when they are acting as agent for the insolvent company, nor does it apply to the insolvent company's handling of your personal data. Please see the Privacy Notice provided by the insolvent company for this information.
In the context of an insolvent individual
When the Office Holder is acting on behalf of an insolvent individual, the Office Holder steps into the shoes of the insolvent individual and it is the Office Holder that is responsible for your personal data. This Privacy Notice does not apply to the insolvent individual's handling of your personal data. Please see the Privacy Notice provided by the insolvent individual (if applicable) for this information.
Who can you contact with privacy questions or comments?
The Office Holder responsible for the processing of your personal data will be defined within the appointment documents and notification of appointment and can be contacted at the relevant Interpath office specified. Any questions or comments regarding the Office Holder’s handling of personal data in their personal capacity should be addressed to the Office Holder in the first instance.
If you have questions or comments about this Privacy Notice or concerns about how the Office Holder handles personal data in their personal capacity, please contact the Data Privacy team at DataPrivacy@interpath.com.
Personal data the Office Holder collects and why
Applicable data protection laws require Office Holders to inform you about the purposes for which they use your personal data. In some territories, Office Holders are also required to have, and to inform you of, the legal basis they rely upon for such use. 'Legal bases' are the legal reasons for the Office Holders' use of your personal data – these are set out in applicable data protection laws. If your territory requires the Office Holder to have a legal basis, they cannot use your personal data if they do not have a valid legal basis for such use.
The Office Holder only handles your personal data for the purposes of administering the insolvent estate. Their overriding obligations will generally be dictated by insolvency legislation in the first instance and, where this conflicts with any of your specific data rights, the Office Holder will be obliged to fulfil their duties under the insolvency legislation.
The Office Holder processes the following types of personal data, which they collect directly from the insolvent company or individual:
|
Category of personal data |
Purpose of processing |
Legal basis for processing (only applicable in those territories that require the Office Holder to have a legal basis) |
|
Contact details (name, company name, job title, work and personal telephone numbers and work and personal email addresses) |
To assist the Office Holder with a number of |
Legal Obligation The Office Holder requires copies of these records to fulfil their statutory and regulatory duties under local insolvency and similar laws |
|
Record keeping purposes following the cessation of the Office Holder's appointment |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
|
|
Personal ID documents (passport, utility bills, driving license, national ID cards) |
To assist the Office Holder with a number of |
Legal Obligation The Office Holder requires copies of these records to fulfil their statutory and regulatory duties under local insolvency and similar laws |
|
Record keeping purposes following the cessation of the Office Holder's appointment |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
|
|
Family and dependent details (names, date of birth and relationship) |
To assist the Office Holder with a number of |
Legal Obligation The Office Holder requires copies of these records to fulfil their statutory and regulatory duties under local insolvency and similar laws |
|
Record keeping purposes following the cessation of the Office Holder's appointment. |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
|
|
Financial information (taxes, payroll, pensions, assets, bank details and claims details) |
To assist the Office Holder with a number of |
Legal Obligation The Office Holder requires copies of these records to fulfil their statutory and regulatory duties under local insolvency and similar laws |
|
Record keeping purposes following the cessation of the Office Holder's appointment. |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services. |
|
|
Sensitive personal data (details of trade union membership and adverse information about potential or existing clients that reveal criminal convictions or offences) |
To assist the Office Holder with a number of |
Legal Obligation The Office Holder requires copies of these records to fulfil their statutory and regulatory duties under local insolvency and similar laws |
|
Record keeping purposes following the cessation of the Office Holder's appointment. |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
The Office Holder processes the following types of personal data, which they generally collect from you or the company you represent during their appointment:
|
Category of personal data |
Purpose of processing |
Legal basis for processing (applicable in those territories that require the Officer Holder to have a legal basis) |
|
Claims data (information about claimants (which will generally be employees and creditors) and their claim against the insolvent company or individual) |
To assist the Office Holder with resolving claims against the insolvent company or individual |
Legal Obligation The Office Holder requires claims data to fulfil their statutory and regulatory duties under local insolvency and similar laws |
|
Record keeping purposes following the cessation of the Office Holder's appointment |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
|
|
Contact details (name, company name, job title, work and personal telephone numbers and work and personal email addresses) |
To conduct sanctions checks on the claimant before the payment of distributions |
Legal Obligation The Office Holder requires these details to comply with laws relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime |
|
Record keeping purposes following the cessation of the Office Holder's appointment |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
|
|
Financial information (source of funds, bank account information, assets) |
To conduct sanctions checks on the claimant before the payment of distributions |
Legal Obligation The Office Holder requires these details to comply with laws relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime |
|
Record keeping purposes following the cessation of the Office Holder's appointment |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services |
|
|
Personal ID documents (passport, utility bills, driving license, national ID cards) |
To conduct sanctions checks on the claimant before the payment of distributions |
Legal Obligation The Office Holder requires these details to comply with laws relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime |
|
Record keeping purposes following the cessation of the Office Holder's appointment |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to maintain recordings of their decision-making as part of the Insolvency Services. |
|
|
New client information (name, company name, job title, work and personal telephone numbers and work and personal email addresses, passport, utility bills, driving license, national ID cards, taxes, assets and bank details). |
To assist the Office Holder with onboarding new clients, including to conduct ID verification, set up an account, process payments and communicate with the client. |
Legal Obligation To comply with Office Holder's legal and regulatory obligations to manage the insolvent company as part of the Insolvency Services. |
The Office Holder processes the following types of personal data, which they generally collect from public sources, including public registers, news articles, sanctions lists, government intelligence and crime prevention agencies, and internet searches:
|
Category of personal data |
Purpose of processing |
Legal basis for processing (applicable in those territories that require the Office Holder to have a legal basis) |
|
Contact details (name and address) |
To conduct sanctions checks on the claimant before the payment of distributions |
Legal Obligation The Office Holder requires these details to comply with laws relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime |
|
Contact details (name and address and date of birth) |
To conduct investigations in respect of Directors |
Legal Obligation The Office Holder requires these details to comply with laws relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime. |
Automated decision making
Automated decision making is where a decision, based solely on automated processing of your personal data, is taken by or on behalf of a company responsible for the handling and use of your personal data, and that decision produced legal effects or otherwise significantly affects you. For example, for the purpose of evaluating your creditworthiness, reliability, conduct, or other matters relating to you.
Office Holders do not currently engage in automated decision making using your personal data.
Do Office Holders share personal data with third parties?
Office Holders occasionally share personal data with trusted third parties to help them deliver efficient and quality services. These recipients are either contractually bound or bound by law to safeguard the data the Office Holder entrusts to them. Office Holders engage with the following categories of recipients:
Do Office Holders transfer your personal data outside your country of residence?
We have servers in the United Kingdom, Europe, Australia and Canada.
Office Holders may transfer personal data within the Interpath group of companies or to reputable third-party organisations situated outside the country in which your personal data is stored when they have a business reason to engage these organisations. Office Holders only transfer your personal data outside the countries in which Interpath has offices where the Office Holder is satisfied that the transfer complies with local data protection law and, if legally required, appropriate safeguards are in place to ensure that your personal data is subject to safety measures equivalent to those in the country in which it is stored.
What are your data protection rights?
Depending on your location, you may have some or all of the following rights in relation to your personal data, subject to certain limitations and exceptions:
Access – You can ask the Office Holder to verify whether they are processing personal data about you, and if so, to provide more specific information.
Correction – You can ask the Office Holder to correct our records if you believe they contain incorrect or incomplete information about you.
Erasure – You can ask the Office Holder to erase (delete) your personal data after you withdraw your consent to processing or when the Office Holder no longer needs it for the purpose it was originally collected. In most cases, this right will not apply where Office Holders process your personal data pursuant to their legal obligations.
Processing restrictions – You can ask the Office Holder to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having Office Holders erase it, or need the Office Holder to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether the Office Holder has overriding legitimate grounds to process it. You can also ask the Office Holder to inform you before they lift that temporary processing restriction.
Data portability – Where you have provided personal data to the Office Holder, you can ask them to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if it is technically feasible. This right is only available in relation to personal data that the Office Holder processes with your consent or where this is necessary for the performance of a contract with you, and such processing is carried out by automated means.
Right to object – You can object to the Office Holder’s use of your personal data for direct marketing purposes, including profiling, at any time. Office Holders may need to keep some minimal information to comply with your request to cease marketing to you. You can also object to our use of your personal data where our processing is necessary for us to pursue a legitimate interest (in those territories where we need a legal basis for processing).
Right to withdraw consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean Office Holders are not able to provide certain products or services to you and they will advise you if this is the case. This right is only available in relation to personal data that the Office Holder processes with your consent.
Right to lodge a complaint – You can lodge a complaint with the relevant data protection supervisory of your country if you believe your rights have been infringed. Please see the relevant Country-Specific Information section set out at Appendix 2 below for details of the relevant data protection supervisory in your country.
Please note that the availability and scope of these rights may vary depending on the office with which you engage. If you have a question about your data protection rights or would like to exercise your data subject rights, you can email your local Interpath entity using dataprivacy@interpath.com.
How long does the Office Holder retain your personal data?
Office Holders retain personal data to comply with applicable laws, regulations, and professional obligations that they are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where Office Holders retain personal data in accordance with these purposes, they retain such personal data for the duration of the insolvency process and for a time thereafter as set out below:
Do we change this Privacy Notice?
We regularly review this Privacy Notice and will post any updates to it on this webpage. All amendments will automatically take effect immediately on posting. Please check this Privacy Notice periodically to inform yourself of any changes.
This Privacy Notice was last updated in November 2025.
Bermuda – Additional Information
Privacy Officer
Contact details of our Privacy Officer for Bermuda are:
Email: data.privacy@interpath.com
Contact details of our PIPA Privacy Officer for Bermuda are:
Ali Wisbey
Email: dataprivacy@interpath.com
Complaints
The contact details for the appropriate data protection supervisory is as follows:
- Bermuda:
o The Office of the Privacy Commissioner for Bermuda
Email: privcom@privacy.bm
Post: Maxwell Roberts Building, 4th Floor, 1 Church Street, Hamilton, HM11, Bermuda
Website: https://www.privacy.bm/
Telephone: 1-441-543-7748
British Virgin Islands – Additional Information
Legal basis for processing
Under the data protection laws of the British Virgin Islands, we are unable to rely on our legitimate interests as a legal reason for processing your personal data. If "legitimate interest" is referred to in the table under Personal data we collect and why, this shall be replaced with your consent as our legal reason for processing your personal data.
Complaints
The contact details for the appropriate data protection supervisory is as follows:
- British Virgin Islands:
o BVI Information Commissioner:
Email: gis@gov.vg
Post: 33 Admin Drive, Wickhams Cay 1, Road Town, Tortola, British Virgin Islands
Website: https://bvi.gov.vg/departments/office-complaints-commission
Telephone: 1284468701
Cayman Islands – Additional Information
Complaints
The contact details for the appropriate data protection supervisory is as follows:
- Cayman Islands:
o Ombudsman Cayman Islands:
Email: info@ombudsman.ky
Post: PO Box 2252, Grand Cayman KY1-1107, CAYMAN ISLANDS
Website: https://ombudsman.ky/data-protection
Telephone: +13459466283
European Union and United Kingdom – Additional Information
Data Protection Officer
In addition to the contact details set out above, any questions about this Privacy Notice or complaints about how the Office Holder handles your personal data may be directed to the Data Protection Officer using the email address: dataprivacy@interpath.com.
International transfers
To the limited extent that it is necessary to transfer personal data outside of the UK or the EEA, the Office Holder will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data, including standard contractual clauses under Article 46(2) of the GDPR (and the equivalent standard contractual clauses for the UK, where appropriate) or an adequacy decision under Article 45 for the GDPR. Please contact the Office Holder using the contact details set out in the Who can you contact with privacy questions or comments? section above if you wish to obtain further information concerning the safeguards they put in place, including copies of the standard contractual clauses entered into with any third parties based outside of the UK or EEA to whom they transfer personal data to.
Data Protection Rights
In relation to the personal data that the Office Holder collects and processes as detailed in this Privacy Notice and to which the GDPR or UK GDPR applies, you have the right to:
For further information about your data protection rights under EU GDPR and UK GDPR, see here: https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/individual-rights/
Complaints
The contact details for the appropriate data protection supervisory authorities are as follows:
- United Kingdom (including Northern Ireland):
o Information Commissioner’s Office
Email: casework@ico.org.uk
Post: Water Lane, Wycliffe House Wilmslow, Cheshire SK9 5AF, United Kingdom
Website: https://ico.org.uk
Telephone: 03031231113
- Republic of Ireland:
o Data Protection Commission:
Webform: https://forms.dataprotection.ie/contact
Post: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Website: https://www.dataprotection.ie/
Telephone: 017650100
Hong Kong – Additional Information
Complaints
The contact details for the appropriate data protection supervisory is as follows:
- Hong Kong:
o Data Protection Supervisory Authority - PCPD
Email: complaints@pcpd.org.hk
Post: Unit 1303, 13/F, Dah Sing Financial Centre, 248 Queen's Road East, Wanchai, Hong Kong.
Website: https://www.pcpd.org.hk/
Telephone: 2827 2827
