Purpose of this notice
This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act (1998 or 2018) and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (“Data Protection Legislation”). For the purpose of Data Protection Legislation and this notice, we are the “data controller”. This means that we are responsible for deciding how we hold and use personal data about you. We are required under Data Protection Legislation to notify you of the information contained in this privacy notice.
Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at paragraph 14 (Contact us),
we take the protection of your privacy very seriously. We will only use your personal information to deliver the services you have requested from us, and to meet our legal responsibilities.
How do we collect information from you?
We obtain information about you when you engage our services and/or when you use our website, for example, when you contact us about our services. We collect information when:
you OR your employer OR our clients engages us to provide our services and also during the provision of those services;
required from third parties and/or publicly available resources
you contact us by email, telephone, post or social media (for example when you have a query about our services); or
you apply for employment with us or submit a speculative application and/or CV
What type of information do we collect from you?
The personal information we hold about you will vary depending on the service we provide.
The personal information we collect might include:
your personal details (such as your name, address, telephone number, email address); your passport/ID card number, your Unique Tax Reference (UTR) number, your National Insurance number, bank account details, your IP address
details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
details of any services you have received from us;
our correspondence and communications with you;
salary information, tax code, employment contract details
information about enquiries you make to us;
information from research, surveys, and marketing activities;
information we receive from other sources, such as publicly available information, information provided by your employer OR our clients or information from your accountant or other advisor:
which pages you may have visited on our website and when you accessed them.
How is your information used?
We may process your personal data for purposes necessary for the performance of our contract with you OR your employer OR our clients and to comply with our legal obligations.
We may process your personal data for the purposes necessary for the performance of our contract with our clients. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
We may occasionally contact you by post, email, and/or telephone with details of any changes in legal and regulatory requirements or other developments that may be relevant to your affairs and, where applicable, how we may assist you further. If you do not wish to receive such information from us, please let us know by contacting us as indicated under ‘Contact us’ below.
Situations in which we will use your personal data
We may use your personal data to:
carry out our obligations arising from any agreements entered into between you OR your employer OR our clients and us (which will most usually be for the provision of our services);
carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
verify your identity where this is required
understand your needs and how they may be met
maintain our records in accordance with applicable legal and regulatory obligations
prevent and detect crime, fraud or corruption
provide you with information related to our services and our events and activities that you request from us or which we feel may interest you
seek your thoughts and opinions on the services we provide;
notify you about any changes to our services
contact you by post, email or telephone
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration:
the requirements of our business and the services provided;
any statutory or legal obligations;
the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
the types of personal data we have collected;
the amount and categories of your personal data; and
whether the purpose of the processing could reasonably be fulfilled by other means.
Any staff with access to your information have a duty of confidentiality under the ethical standards that this firm is required to follow.
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: IT, portal and cloud services, professional advisory services (including quality and peer review services), administration services, marketing services and banking services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
We will not sell or rent your information to third parties.
We will not share your information with third parties for marketing purposes.
Transferring personal data outside the European Economic Area (EEA)
We may transfer personal data to reputable third-party organisations situated inside or outside the European Economic Area (EEA) when we have a business reason to engage these organisations. Each organization is required to safeguard personal data in accordance with our contractual obligations and data protection legislation.
If you require further information about these protective measures pleased contact us using the contact details below.
We have commercially, reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Security precautions in place to protect the loss, misuse or alteration of your information
Whilst we strive to protect your personal information, we cannot guarantee the security of any information you or another party (for instance your accountant) transmit to us, and you or they do so at your own risk. We have a secure client portal which can be used to transfer data.
Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given, or where you have chosen, a password which enables you to access information, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Rights of Access, Correction, Erasure and Restriction
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
Request correction of the personal data that we hold about you.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Changes to the notice
We regularly review this Privacy Notice and will post any updates to it on this webpage.
If you have any questions regarding this notice or if you would like to speak to us about the way we process your personal data, please email our Data Protection Point of Contact - firstname.lastname@example.org.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Telephone – 0303 123 1113 (local rate) or 01625 545 745