Bank Analysis — Privacy Notice

1. Who is responsible for your data

The controller is Insolvency Direct Ltd (Saxon House, Saxon Way, Cheltenham GL52 6QX; ICO registration Z3533328). Following any appointment, the Insolvency Practitioner appointed as Liquidator is also a controller. For any data-protection query, or to exercise your rights, contact us at info@insolvencydirect.co.uk or on 0800 088 6767.

2. What this notice covers

It covers the Bank Analysis — an antecedent-transaction review of a company's bank data carried out before any formal insolvency appointment, usually at the request of the company's accountant, to help assess the company's financial position.

3. What personal data we process, and where it comes from

• • The company's bank-account transaction data (dates, amounts, counterparties, references), which may contain personal data.
• • Identity and contact details of directors, officers, shareholders and connected parties, and Companies House data.
• • Findings we derive about the conduct of the company's directors, which may include information relating to alleged unlawful acts (Article 10 data).

The bank data reaches us either through Armalytix, an FCA-regulated open-banking provider, or from statements provided via your accountant.

4. Why we process it, and our lawful basis

We process this data to assess the company's financial position, identify antecedent transactions (such as overdrawn director loan accounts, unlawful dividends, preferences, transactions at undervalue and misfeasance), and support the advice given to the company.

Our lawful basis is legitimate interests (UK GDPR Article 6(1)(f)) — the interests of Insolvency Direct, the company's creditors, its directors and the referring accountant in a rapid, accurate assessment before any decision. Where the findings involve data about alleged unlawful acts, we rely on the condition in Schedule 1, Part 2, Paragraph 10 of the Data Protection Act 2018 (preventing or detecting unlawful acts), governed by an Appropriate Policy Document.

5. Automated analysis using AI

To review the transaction data accurately and efficiently we use a secure automated analysis system provided by Anthropic. Anthropic acts only as our processor, under written terms that require it to process the data solely on our instructions and not to use it to train any AI models. The analysis is always reviewed by our staff and the Insolvency Practitioner before it is relied upon — no decision producing legal or similarly significant effects is made solely by automated means.

6. Who we share it with

Anthropic and Armalytix (as our processors), the Insolvency Practitioner who reviews the analysis, and the referring accountant (to whom the findings are provided so they can advise you). We do not sell personal data.

7. Transfers outside the UK

Anthropic processes data in the United States. That transfer is protected by the UK International Data Transfer Addendum (IDTA) to the EU Standard Contractual Clauses, together with technical and organisational safeguards, so your data continues to be protected to the UK standard.

8. How long we keep it

• • Raw transaction data is securely purged 30–90 days after the analysis is completed and verified.
• • Derived findings are kept for 1 year after the liquidation is completed, or for 6 years if the company does not enter liquidation, then securely destroyed or anonymised.

9. Your rights

You have the right to access your personal data, and to seek its rectification, erasure or restriction, and to object to our processing (because we rely on legitimate interests). To exercise any right, contact us using the details in section 1. You also have the right to complain to the Information Commissioner's Office (ico.org.uk).