Policies

Introduction

This privacy policy explains how personal information is collected, used, shared and retained by Coots & Boots Limited and, where applicable, by insolvency practitioners of Coots & Boots Limited when acting as office-holders.

It applies to personal information processed in connection with formal insolvency appointments, advisory and restructuring work, general enquiries, recruitment, complaints, suppliers, website use and other business administration.

This privacy policy is intended to provide general transparency. In some insolvency matters, additional case-specific information may be provided in appointment notices, reports, correspondence or other documents issued by the relevant office-holder(s).

The data controllers

Coots & Boots Limited is registered in England and Wales under company number 15805906. Its registered office is 29 Farm Street, London, W1J 5RL. Coots & Boots Limited is registered with the Information Commissioner’s Office under data protection registration number ZB714871.

For general firm administration, website use, enquiries, recruitment, marketing, advisory work, non-insolvency services and other firm-level processing, the data controller is Coots & Boots Limited.

Where one or more insolvency practitioners of Coots & Boots Limited are appointed as office-holders, the appointed office-holder(s) will usually be the data controller(s) for personal information processed for the purposes of that insolvency appointment. Where two or more insolvency practitioners are appointed jointly, they may act as joint controllers for appointment-related processing.

Coots & Boots Limited supports the office-holder(s) in administering insolvency appointments, including by providing staff, systems, premises, administrative support and case-management services. The relevant office-holder(s) will usually be identified in case correspondence, appointment notices, statutory reports or other documents issued in the relevant insolvency procedure.

General privacy enquiries may be sent to help@cootsandboots.com or by post to Coots & Boots Limited, 29 Farm Street, London, W1J 5RL. Where your enquiry relates to a specific insolvency appointment, please quote the case name and reference where possible.

How does it work?

We may process personal information in different capacities depending on the nature of the matter:

Insolvency appointments: personal information may be processed by the appointed office-holder(s) to comply with insolvency legislation, statutory duties, court requirements, regulatory obligations and the proper administration of the estate.

Advisory or restructuring work: personal information may be processed by Coots & Boots Limited to provide advice or services to a client, to manage the engagement and to comply with professional and regulatory obligations.

Website and general firm activity: personal information may be processed by Coots & Boots Limited when you use our website, contact us, attend meetings, make an enquiry, apply for a role, supply goods or services, or otherwise interact with the firm.

We do not generally rely on consent for processing personal information in insolvency appointments. Much of the processing is required by law, by statutory duties or for legitimate insolvency and regulatory purposes. Where consent is required, we will ask for it separately.

What personal information do we collect?

The personal information collected will depend on the nature of the matter and your relationship to it. It may include:

names, titles, job titles, dates of birth and contact details, including postal addresses, email addresses and telephone numbers;

identification and verification information, such as copies of passports, driving licences, proof of address and electronic verification results;

information about directors, shareholders, members, partners, creditors, employees, debtors, guarantors, customers, suppliers, purchasers, advisers and other parties connected with an appointment or engagement;

financial information, including bank details, account information, claims, proofs of debt, dividends, payments, tax information, payroll information, pensions, benefits and employment-related claims;

company, trading and transactional records, books and records, correspondence, contracts, invoices, statements, minutes, reports, electronic data and information obtained from company systems or third parties;

information relevant to insolvency investigations, asset realisations, litigation, claims, complaints, regulatory reporting, director conduct matters and potential recoveries;

anti-money laundering, sanctions, politically exposed person, adverse media, fraud prevention and risk-screening information;

website and technical information, such as IP address, browser type, device information, pages visited and cookie preferences;

recruitment and employment application information, where you apply for a role with us;

special category personal data, such as health, trade union membership or other sensitive information, where it is necessary for the administration of an insolvency appointment, an employment claim, legal claim, statutory obligation or regulatory requirement; and

criminal offence data or information relating to alleged wrongdoing, where necessary for insolvency investigations, legal claims, regulatory reporting, anti-money laundering obligations or other lawful purposes.

How do we collect your personal information?

We may receive personal information from you directly or from other sources, including:

the company, individual, partnership or entity to which the matter relates;

directors, shareholders, members, partners, employees, creditors, debtors, customers, suppliers, guarantors, agents and professional advisers;

office-holders, the Official Receiver, the Insolvency Service, Companies House, HMRC, the Redundancy Payments Service, courts, tribunals, law enforcement agencies and regulators;

banks, payment providers, insurers, pension providers, landlords, asset agents, valuers, auctioneers, solicitors, accountants, IT providers and other third parties involved in an appointment or engagement;

public registers, court records, Companies House, credit reference agencies, fraud prevention agencies, sanctions lists, adverse media searches and electronic verification providers;

company books and records, electronic data, email accounts, cloud systems, servers, devices, files, correspondence and backup data; and

our website, cookies, analytics tools, email systems, telephone calls, meetings and other communications.

How do we use your personal information?

We may use personal information for the following purposes:

to accept, manage and administer insolvency appointments and advisory engagements;

to comply with insolvency legislation, company law, tax law, employment law, court rules, professional standards and regulatory obligations;

to communicate with creditors, directors, shareholders, members, employees, debtors, customers, suppliers, purchasers, agents, advisers, regulators and other stakeholders;

to identify assets, realise assets, adjudicate claims, make distributions, operate bank accounts, maintain accounting records and complete statutory reporting;

to investigate the affairs of a company or individual, directors’ conduct, transactions, assets, liabilities, claims, recoveries, complaints and potential legal proceedings;

to verify identity, carry out customer due diligence, complete sanctions, PEP and adverse media checks, prevent fraud, prevent money laundering and terrorist financing, and comply with anti-bribery and sanctions obligations;

to obtain professional advice, instruct agents, instruct solicitors, liaise with insurers, assign claims, pursue or defend legal claims, and protect the interests of an insolvent estate or stakeholders;

to maintain case files, audit trails, quality control, compliance records, training records, risk assessments and internal records;

to respond to enquiries, complaints, subject access requests and other data protection requests;

to manage our website, IT systems, premises, security, business continuity, insurance and administration;

to manage recruitment, suppliers, professional relationships and general business contacts; and

to send marketing or event information about our services where permitted by law and where you have not opted out.

Lawful basis for processing

The lawful basis for processing will depend on the purpose for which the personal information is used. The main lawful bases we rely on are:

Legal obligation: where processing is necessary to comply with insolvency legislation, statutory duties, tax obligations, regulatory obligations, anti-money laundering obligations or other legal requirements.

Legitimate interests: where processing is necessary for the proper administration of insolvency appointments, the protection of creditors and stakeholders, asset realisation, investigations, claims, business administration, security, complaints handling and the provision of professional services.

Contract: where processing is necessary to enter into or perform a contract with you, a client, supplier, employee, consultant or other business contact.

Consent: where we ask for consent for a specific purpose, such as certain optional cookies or marketing communications. Consent may be withdrawn at any time where it is the lawful basis for processing.

Vital interests: in rare cases, where processing is necessary to protect someone’s life.

Where we process special category personal information or criminal offence data, we will only do so where a further condition under data protection legislation applies. This may include legal claims, substantial public interest, employment and social security obligations, preventing or detecting unlawful acts, regulatory requirements, insolvency administration, or explicit consent where appropriate.

How we may contact you about the work we undertake

We may contact you by post, email, telephone, secure portal or other appropriate means in connection with an insolvency appointment, advisory engagement, enquiry, complaint, regulatory obligation or other legitimate business purpose.

In insolvency appointments, some communications are required by law, court order, regulatory requirements or the office-holder’s statutory duties. You may not be able to opt out of receiving communications that we are required or entitled to send as part of an insolvency procedure.

Where we send marketing communications about our services, events or updates, we will do so only where permitted by law. You can ask us to stop sending marketing communications at any time. We will not use insolvency case data for unrelated direct marketing.

How long do we keep your data?

We retain personal information for as long as necessary for the purpose for which it was collected and for any related lawful purpose. This may include retaining information to comply with statutory, regulatory, tax, accounting, professional, insurance, audit, anti-money laundering, limitation period and legal claim requirements.

In insolvency appointments, records are generally retained for at least the period required by insolvency law, professional standards and regulatory requirements, and may be retained for longer where necessary for investigations, claims, complaints, litigation, insurance, audit, regulatory review or other legitimate purposes.

AML and customer due diligence records may be retained for the period required by the Money Laundering Regulations and related guidance. Website cookie retention periods are dealt with in the Cookies section below and in any cookie banner or cookie preference tool used on our website.

Who do we share your information with?

We may share personal information where necessary and lawful, including with:

the appointed office-holder(s), their staff, consultants and advisers;

creditors, directors, shareholders, members, employees, debtors, customers, suppliers, purchasers, agents and other stakeholders where required or appropriate for the appointment or engagement;

Companies House, the Insolvency Service, the Official Receiver, HMRC, the Redundancy Payments Service, courts, tribunals, law enforcement agencies and government bodies;

recognised professional bodies, regulators, monitoring bodies, auditors, compliance reviewers, insurers and professional indemnity advisers;

banks, payment providers, pension providers, payroll providers, landlords, landlords’ agents, utility providers and other parties relevant to the affairs of the company or individual;

solicitors, counsel, accountants, tax advisers, valuers, auctioneers, agents, surveyors, debt collection agents, tracing agents, IT specialists, forensic accountants, litigation funders and other professional advisers;

electronic verification providers, sanctions screening providers, credit reference agencies, fraud prevention agencies and risk-screening providers;

IT, cloud hosting, document management, storage, archiving, printing, mailing, email, website, security and other service providers;

potential purchasers, bidders, assignees, funders or parties interested in assets, claims, books and records, or other matters arising in an insolvency appointment;

other office-holders or insolvency practitioners involved in connected appointments; and

any other person or organisation where disclosure is required by law, court order, professional obligation, regulatory requirement, legal claim, asset realisation, investigation or the proper administration of an appointment.

Some personal information may be included in statutory reports or filings and may become available on public registers, including Companies House or the Insolvency Service, where required by law.

Where we use third party service providers, we take steps designed to ensure that personal information is protected and processed in accordance with applicable data protection requirements.

Anti-money laundering, sanctions, fraud prevention and regulatory checks

We may use personal information to verify identity, carry out customer due diligence, complete sanctions, politically exposed person and adverse media screening, prevent fraud, prevent money laundering and terrorist financing, comply with anti-bribery and sanctions obligations, and meet professional and regulatory requirements.

This may involve using electronic verification providers, credit reference information, public registers, sanctions lists, fraud prevention databases, adverse media sources and information from regulators, law enforcement agencies, office-holders, directors, creditors or other third parties.

Where required by law or professional obligations, we may make reports to regulators, law enforcement agencies or other authorities. We may not always be permitted to tell you that such a report has been made.

International transfers

Some insolvency appointments, assets, creditors, directors, shareholders, records, advisers, service providers or IT systems may be located outside the United Kingdom. Where personal information is transferred outside the UK, we will take steps to ensure that the transfer is lawful and that appropriate safeguards are in place where required.

Social media

If you contact us through social media or interact with our social media pages, we may receive personal information contained in your profile, message, comment or interaction. Social media platforms may also process your personal information for their own purposes under their own privacy policies.

The social media section of this policy applies mainly to website visitors and users of our social media pages. It does not override or limit the statutory duties of an insolvency office-holder.

Security

We use technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. These measures may include access controls, secure systems, staff training, confidentiality obligations, data back-up, document management controls and physical security measures.

No method of transmission or storage is completely secure. If you send us confidential or sensitive information, please use secure methods where possible and contact us if you require guidance on how to send information securely.

Other types of advertising and marketing

We do not sell personal information. We do not use personal information obtained in an insolvency appointment for unrelated direct marketing.

We may use limited personal information for general firm marketing, professional updates, events or similar communications where permitted by law. We may also use website analytics or advertising tools where these are enabled and lawful. If optional cookies or similar technologies are used, they will be managed through our cookie arrangements or cookie preference tools.

Your rights

Data protection law gives individuals rights in relation to their personal information. Depending on the circumstances and the lawful basis for processing, these may include the right to:

be informed about how personal information is used;

request access to personal information;

request correction of inaccurate or incomplete personal information;

request erasure of personal information in certain circumstances;

request restriction of processing in certain circumstances;

object to processing in certain circumstances;

request data portability in certain circumstances;

withdraw consent where processing is based on consent; and

complain to the Information Commissioner’s Office.

These rights are subject to legal limitations. In insolvency appointments, we may need to retain or process personal information to comply with statutory duties, regulatory obligations, court requirements, investigation duties, reporting obligations, claims handling, asset realisation, distributions or legal proceedings. This may mean that some rights, such as erasure, objection or restriction, cannot be exercised in the usual way.

We may need to verify your identity before responding to a request. We will aim to respond to valid requests within the period required by law. If a request relates to a specific insolvency appointment, the relevant office-holder(s) may be responsible for responding.

Complaints

If you have concerns about how your personal information is being used, please contact us first so that we can consider and respond to your concerns.

You can contact us by email at help@cootsandboots.com or by post at Coots & Boots Limited, 29 Farm Street, London, W1J 5RL. If your complaint relates to a specific insolvency appointment, please include the case name and reference where possible.

You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator. Information about how to contact the ICO is available on the ICO website.

Cookies

Our website may use cookies and similar technologies to operate the website, improve functionality, understand website use and, where applicable, support analytics or marketing preferences.

Some cookies are necessary for the website to function. Optional cookies, such as analytics or marketing cookies, will be used only where permitted by law and, where required, with your consent. You can usually manage cookies through your browser settings and any cookie banner or preference tool available on our website.

Disabling some cookies may affect how the website works.

Updates

We may update this privacy policy from time to time. The latest version will be published on our website and will show the date it was last updated.

Where an update materially affects how personal information is processed in a specific appointment or engagement, additional information may be provided where appropriate.

Updated: July 2026