About this notice
This notice explains how personal information is handled when you use focusinsolvency.co.uk, send an online enquiry, or contact the team by telephone or email.
It is a website privacy notice. It does not describe every processing activity that may apply if you become a client, creditor, employee, supplier or professional contact, and it does not apply to external websites or services reached through links or embedded content.
Legal entity and data-protection roles
Debtfocus Business Recovery & Insolvency Ltd, trading as Focus Insolvency Group, is the controller for personal information submitted through this website. It is registered in England and Wales under company number 06831646 and registered with the Information Commissioner’s Office under reference ZA572076.
Anthony Benjamin Fisher, Managing Director, is the formally appointed Data Protection Officer.
DPA Cloud Services Ltd operates and maintains the website, server, security controls and email-delivery configuration as a processor acting on Debtfocus Business Recovery & Insolvency Ltd’s instructions.
Microsoft 365 is the approved email service provider used to transmit and store enquiry emails.
Registered office
Skull House LaneAppley BridgeWigan, LancashireWN6 9DWUnited KingdomFor privacy questions or requests, email [email protected], call 01257 257035, or write to the registered office and mark the correspondence “Privacy”.
Professional indemnity insurance
Debtfocus Business Recovery & Insolvency Ltd maintains professional indemnity insurance with CNA Insurance Company Limited under policy number 10581504. The policy covers England and Wales. This disclosure relates to the information requirements in the Provision of Services Regulations 2009.
Information handled when you use the website
The website provides information and an online enquiry form. It does not provide comments, user accounts, online applications or newsletter signup, and it does not include an analytics package.
Technical request information
When your browser requests a page or asset, the hosting infrastructure processes technical information needed to deliver, protect and diagnose the website. This may include your IP address, browser or user-agent information, the requested URL, the referring page where supplied, the date and time, and response or security information.
Website enquiries
When you submit the contact form, the website processes your name, the email address and/or telephone number you provide, your optional preferred callback time, your enquiry message, confirmation that you have read this notice, and technical request information needed to protect and operate the form. The form does not accept document uploads.
A preferred callback time is optional, is not a guaranteed appointment or response time, and uses the Europe/London timezone.
The form uses a limited on-device heuristic to remind you when message text appears to contain certain passwords, bank or card details, or similar identifiers. It is advisory and cannot identify every type of sensitive information. The result is not sent or stored separately.
If sensitive or unnecessary information is submitted, authorised recipients decide whether it should be deleted, redacted, retained or escalated. Public-record company information may be retained where it provides relevant context.
The website passes these details through the Focus enquiry service and Microsoft 365 to the approved enquiry recipients. The application does not add a contact database or durable queue. Microsoft 365 and recipient mailboxes may retain records as explained below.
To limit automated abuse, the enquiry service uses your network address transiently and keeps only a keyed fingerprint for a 10-minute rate-limit window. The fingerprint is no longer used after that window and is removed by the next scheduled cleanup, no later than one minute afterward while the service is running, or when the service stops. The application does not log or retain the raw address for this purpose.
Theme preference
When the website loads, the application reads the localStorage key “theme” and writes the current display mode as “light” or “dark”. If no saved value exists, the application derives the mode from the page and writes it; the normal website entrypoint begins in light mode. Choosing light or dark mode changes the stored value. If you clear browser storage, the application creates the value again on the next load. The value remains on your device and is not used to identify you or track you across websites.
Cookies and analytics
The current application code does not set cookies and does not include an analytics package. Existing embedded or remotely hosted third-party content may use cookies or similar technologies under the provider’s own terms, as explained below.
Third-party content and external links
Some existing pages load embedded YouTube players, YouTube thumbnails or presentation assets hosted on the legacy focusinsolvencygroup.co.uk domain. Loading those resources can disclose technical request information, such as your IP address, browser or device information, the requested resource and the referring page, to the service that supplies the resource.
The website also links to services including Google Maps, YouTube, Facebook and LinkedIn. If you choose an external link or load embedded content, the external provider may process information and use cookies or similar technologies under its own privacy information. Check the provider’s privacy information before using the service.
Some external providers operate internationally and may process information outside the United Kingdom. Their privacy information explains where they process information and the safeguards they use. You can contact us for more information about a restricted transfer connected with this website.
If you send an online enquiry or contact us by telephone or email
We use enquiry information to respond to enquiries; contact people using their chosen method; arrange requested professional-partner referrals; keep proportionate records of substantive advice; and handle complaints, disputes, incidents or legal claims.
An accepted website response means only that the configured email service accepted the enquiry for delivery. It does not confirm inbox delivery, that the message has been read, a response time, or that we can act.
Why we use personal information
| Purpose | Lawful basis |
|---|---|
| Deliver, protect and diagnose the website. | Our legitimate interests in operating a secure, reliable and usable website. |
| Set and remember the website’s current light or dark display mode on your device. | Our legitimate interests in providing and maintaining the website’s display mode. The value remains in your browser storage and is not used for cross-site tracking. |
| Respond to enquiries and contact people using their chosen method. | Steps requested before entering a contract where applicable, and our legitimate interests in responding and administering the enquiry. |
| Arrange a requested referral to a selected professional partner. | A basis appropriate to the requested referral, including requested pre-contract steps or legitimate interests where applicable. |
| Keep proportionate records of substantive advice and handle complaints, disputes, incidents or legal claims. | Our legitimate interests in proportionate administration and establishing, exercising or defending legal rights, plus applicable legal obligations. |
| Protect the online enquiry service from automated abuse. | Our legitimate interests in protecting the website and enquiry service, using data-minimising rate-limit controls. |
| Meet applicable legal, regulatory and professional obligations. | Compliance with a legal obligation where the obligation applies. |
Confirming that you have read this notice is an acknowledgement, not consent and not the lawful basis for handling the enquiry.
The basis that applies depends on the circumstances and purpose. This website does not treat ordinary browsing as consent to unrelated processing. If consent is required for a separate activity, it must be requested specifically and can be withdrawn.
Who information may be shared with
We may share an enquiry with selected professional partners where necessary to respond to the person’s request or arrange the service requested.
The information shared may include the person’s name, email address, telephone number, enquiry text and preferred callback time.
A selected professional partner acts jointly with Focus for the referred enquiry. Focus does not routinely name the selected partner before making a referral.
Guardian Group businesses
Business Guardian and its associated brands are part of Money Managers (UK) Ltd (company number 08367087).
Selected professional partners within the Guardian Group of businesses may include, but are not limited to:
- Guardian Insolvency Ltd (company number 07906134)
- Financial Guardian (UK) Ltd (company number 07906605)
- Guardian Debt Solutions Ltd (company number 07908483)
Marketing requires separate, optional consent. Focus does not sell personal information collected through this website for third-party advertising.
A selected Guardian business may use the personal information included in the referred enquiry only to handle that referral and meet legal or regulatory obligations directly connected with it. Any new personal information obtained or generated while handling the referral must be passed back to Focus Insolvency Group and must not be used for unrelated onward purposes.
- Microsoft 365, as the approved email service used to transmit and store enquiry emails.
- Anthony Benjamin Fisher at [email protected], as the primary enquiry recipient.
- The Focus management shared inbox at [email protected] and Caroline Gray at [email protected], as copied enquiry recipients. Anthony Benjamin Fisher and Emma Jayne Fisher may access the shared inbox.
- Selected professional partners acting jointly with Focus for a referred enquiry.
- DPA Cloud Services Ltd technical administrators, only where access is technically necessary for support, security or incident investigation.
- Professional advisers, regulators, courts, law-enforcement bodies or public authorities where disclosure is necessary or legally required.
How long information is kept
The theme value remains in your browser until it changes or you clear browser storage. If you clear it, the current application creates a new value on the next website load.
An enquiry that does not lead to substantive advice, a referral or an ongoing matter is retained for two years and then deleted automatically under the approved retention policy.
An enquiry that leads to substantive advice, a referral or an ongoing matter is retained for six years from the last substantive contact. Critical-advice records are reviewed after five years and retained beyond the applicable period only where there is a documented reason.
Approved users periodically move or clear ordinary enquiry emails from the receiving mailbox; they are not kept indefinitely. Shared-mailbox access is reviewed periodically by DPA Cloud Services Ltd and removed following an off-boarding request.
Microsoft 365 sent-mail copies and SMTP retry or spool data are retained for one month under the approved operational schedule.
Application and security logs do not contain enquiry text. They are retained for no more than 60 days in one collective archive capped at 32 MB and are accessible to DPA Cloud Services Ltd technical or support management.
Backups containing enquiry information use six rolling weekly copies. If deleted information reappears after a restore, it remains subject to the deletion process.
A documented legal hold may override ordinary deletion while it remains necessary. Anthony Benjamin Fisher authorises holds and reviews compliance ad hoc, and deletion or review records are retained.
External providers determine retention for information they process under their own privacy information.
Your data-protection rights
Depending on the circumstances and the legal basis, you may have rights to be informed, obtain access, correct inaccurate information, request erasure, restrict processing, object to processing, receive portable information, and withdraw consent where processing relies on consent. Some rights are qualified and may not apply in every case.
To make a request, email [email protected], call 01257 257035, or write to the registered office and mark the correspondence “Privacy”. The Data Protection Officer normally verifies identity and authority; the Operator is the backup.
Anthony Benjamin Fisher is the primary owner for data-subject requests, privacy complaints and suspected personal-data incidents; Emma Jayne Fisher is the deputy. Unresolved privacy complaints may be escalated to the Information Commissioner’s Office.
The Data Protection Officer decides whether a data-subject request can be fulfilled, refused or restricted. The Focus Insolvency Legal Team is the legal and privacy escalation route for that decision.
Anthony Benjamin Fisher is the primary assessor for suspected personal-data breaches and decides whether regulatory or individual notification is required. The DPA Cloud Services Ltd Monitoring Team is the backup breach assessor and may provide consultancy, remediation, disaster-recovery and audit support.
Raise a concern
Please contact us first so we have an opportunity to address your concern.
If you remain unhappy, you can complain to the Information Commissioner’s Office, the United Kingdom regulator for data protection.
Changes to this notice
We may update this notice when the website, processing activities or legal requirements change. The effective date shown at the top identifies the current published version.
