Circo Consulting

Our Firm Information 

By ‘We’ or ‘Us’, we mean Circo Consulting Ltd. Trading Name: Circo Consulting. By “You” we mean the customer or individual (data subject) who has accessed our service. we are Registered in Scotland. Registered Address: 1 Simonsburn Road, Kilmarnock, Ayrshire, United Kingdom, KA1 5LA. Circo Consulting Ltd is a controller of your personal data. 

 

Circo Consulting Limited is Authorised and Regulated by the Financial Conduct Authority (FCA) as a claims management company and is also registered with the Information Commissioner’s Office (ICO), Registration Number: ZA765158

 

Our Contact Information: 

Telephone: 01475 540 296

Email: claims@circoconsulting.com 

Postal Address: 1 Simonsburn Road, Kilmarnock, Ayrshire, United Kingdom, KA1 5LA

 

Personal Data We Collect From You

We collect personal data about you, from you, to provide services and products requested by you. We are not required to provide you with the categories of personal data that we obtain directly from you, however, we have detailed the likely data that is requested from you, for the purposes described within this Privacy Policy.

 

Personal Data That Is Processed

Whether provided by you, or by third parties, we may process the following personal data:

 

Personal Data 

Description 

Identity Data 

Examples may include: first name, surname, title, date of birth, gender, passport/ID information, national insurance number, current employment address (following redundancy), country of residence

Employment Data 

Examples may include: Length of employment, annual holiday and sickness entitlement, nature of employment (director/employee etc), redundancy date, age when made redundant, weekly working hours, overtime, breaks in employment, current employment (following redundancy), date of current employment (following redundancy), letters sent to or received from your employer or an employment tribunal, job title/occupation

Financial Data 

Examples may include: Weekly pay before tax and deductions, wage records, bonus and commission, taxation, bank or building society details, employer liability to you, employee liability to an employer

Contact Data 

Examples may include: Telephone number, email address, billing address, home address

Special Category Data 

Examples may include: Health data



How We Collect Personal Data From You

We have different methods of collecting data from and about you, including via: 

 

Direct Interactions: 

You may provide us with your personal data when completing online forms or by corresponding directly with us via post, phone, email or otherwise. This includes personal data you provide when you:

 

  • Engage our products and services;
  • Provide us with feedback; or

 

Third Parties 

We may receive personal data about you from third parties. Please see the section “Information We Collect From Third-Party Sources”. 

 

Automated Technologies or Interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing patterns and actions. This will be collated after the acceptance of ‘cookie’ and other similar technologies. Please refer to our Cookies Policy for further information.

 

Contractual/Legal Obligation To Provide Personal Data

If you do not provide certain information (as described within the section: “Lawful Basis and Purposes for Processing Your Personal Data” we will be unable to provide regulated employment-related claims management services to you in accordance with a contract or for the performance of a contract entered into by you, the claimant, and us, the claims management company. 

 

Information We Collect From 3rd Party Sources

We collect personal data about you from third party sources. We have detailed the personal data that may be requested from third-party sources and who the third-party sources are. Please see as follows:

 

Personal Data 

Third-Party Source 

Identity Data: First name, surname 

Your Insolvency Practitioner (where applicable)

Contact Data: Telephone number, email address

Identity Data: First name, surname 

Your Accountant (where applicable) 

Contact Data: Telephone number, email address

Identity Data: Date of birth 

Companies House (public register)

 

Lawful Basis And Purposes For Processing Your Data

 

Purpose

Lawful Basis/Bases

To verify your identity ahead of offering any employment-related claims management services 

For the performance of a contract 

To identify, investigate, advise and represent you in relation to employment-related claims management services 

For the performance of a contract 

To tailor our services to any needs that you may have e.g., vulnerabilities. This may include the processing of health data where applicable. 

For the performance of a contract (not health data)

Explicit consent (health data)

To keep you informed regarding the progression of an employment-related claim 

Legal Obligation 

To invoice you for employment-related claims management services, including any payment arrangements, arrears and forbearance 

For the performance of a contract

To best achieve compliance with our regulatory and legal obligations by sharing personal data with a third-party compliance consultant 

Legitimate Interests 

To contact your accountant and insolvency practitioner (where applicable) to retrieve information relevant to your employment-related claim

For the performance of contract

To comply with our legal and regulatory obligations (e.g, monitoring and quality assurance, complaint handling, record keeping etc, prevent financial crime, satisfy regulator (FCA/ICO) requests.  

Legal Obligation 

To process any cancellations/terminations 

Legal Obligation 

 

Recepients For Your Personal Data

In certain circumstances, we are required to or may disclose your personal data to third party recipients. These third parties are listed below:

 

  • The Redundancy Payment Service (RPS) 
  • Your Insolvency Practitioner (where applicable) 
  • Your Accountants (where applicable) 
  • The Financial Conduct Authority (FCA) 
  • The Information Commissioner’s Office (ICO)
  • Professional Compliance Consultant (Scott Robert Compliance Limited) 
  • Call Recording Software Provider (Horizon) 
  • Cloud storage Provider (Microsoft) 

 

Personal Data Retention Periods

We will only retain your personal data for as long as is necessary to fulfil our obligations under the provision of our service as well as any purposes necessary to satisfy 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 of 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, including applicable legal requirements.  

 

Details of retention periods for different aspects of your personal data are available upon request. By law we have to keep certain information about our customers and this data will be held solely and securely for those legal purposes.  

 

Your Data Rights

You have the following ‘Rights’ available to you regarding the processing of your personal data. Not all rights are absolute. 

 

Your Right to Object

Under certain circumstances you have the right to object to the processing of your personal data, however, you do have the absolute right to object to direct marketing.

 

Your Right to Access

The right of access, commonly referred to as subject access, gives individuals the right to obtain a copy of their personal data as well as other supplementary information. it helps you to understand how and why we are using your data, and to check we are using it lawfully.

your right to Rectification   

You have the right to have inaccurate personal data rectified. you may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing. this may involve providing a supplementary statement to the incomplete data.

Your Right to Erasure

Under certain circumstances, you have the right to have personal data erased. also known as ‘the right to be forgotten’. the right is not absolute.

Your Right to Restrict Processing 

Under certain circumstances, you have the right to request the restriction or suppression of your personal data, and as like the right to erasure, it is not absolute. restriction of processing means we are permitted to store your personal data; we are unable to use it. 

Your Right to Data Portability 

You have the right to obtain and reuse your personal data for your own purposes across different services. this eases the copying or transferring of personal data easily from one IT environment to another, safely and securely, without affecting the usability of the data. 

Your Right to Be Informed 

You have the right to be informed about the collection and use of your personal data. your right to be informed forms part of this policy, and provides the purposes for processing your data, our retention periods and who it will be shared with. 

 

If you would like to exercise your rights, please contact us:

 

Our Contact Information: 

 

Telephone: 01475 540 296

Email: claims@circoconsulting.com 

Postal Address: 1 Simonsburn Road, Kilmarnock, Ayrshire, United Kingdom, KA1 5LA

 

Your Right To Lodge A Complaint With The Information Commission

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

 

Our Contact Information: 

 

Telephone: 01475 540 296

Email: claims@circoconsulting.com 

Postal Address: 1 Simonsburn Road, Kilmarnock, Ayrshire, United Kingdom, KA1 5LA

 

ICO Contact Information 

 

Telephone: 0303 123 1113

Postal Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Live Chat: https://ico.org.uk/global/contact-us/live-chat/

 

Data and Information Sharing

11.1 In order to process your claim, Circo Consulting will share your personal information with the Redundancy Payments Service, Insolvency Practitioner associated with your case and where applicable representatives of your previous employer such as Director or the nominated accountancy firm. Your details will not be shared with any other 3rd party without additional consent.

 

11.2 The personal information we hold can include details such as name, address, contact details, date of birth, pay records & employment history. All data is stored securely and used solely for purposes outlined in the service proposal.

 

11.3 For audit purposes your data will be held for a 2-year period.

 

Your Right To Withdraw Consent

If you have given us consent to process your personal data you have a right to withdraw that consent at any time, including but not limited to the removal of consent to be contacted for marketing purposes. You can request this using the following contact details: 

 

Our Contact Information: 

Telephone: 01475 540 296

Email: claims@circoconsulting.com 

Postal Address: 1 Simonsburn Road, Kilmarnock, Ayrshire, United Kingdom, KA1 5LA

 

Where you have received marketing communications, you will be able to ‘unsubscribe’ to receiving further communications as part of that marketing communication. 

 

Changes To This Privacy Policy

This Privacy Policy was last updated on 01/09/2021 and remains under regular review. Should you wish for us to send the Privacy Policy to you, please contact us using the contact information provided within this Privacy Policy.