Privacy Notice – Our Clients
1. We use the information you provide to us (including, without limitation, any personal data such as your internal account manager names, addresses and other contact information, and other information that such people share with us whilst we are providing, or preparing to provide, our services) primarily for the provision of services to you and for related purposes including, but not limited to:
a) updating and enhancing client records;
b) analysis to help us manage our business;
c) ensuring our invoices are paid;
d) statutory returns; and
e) legal and regulatory compliance including, fraud, financial crime and money laundering prevention.
We process that information as a data controller. Our use of that information is subject to your instructions, relevant data protection laws (including, without limitation, the General Data Protection Regulation (EU) 2016/679 and implementing legislation in the United Kingdom) (“Data Protection Laws”) and our duty of confidentiality. We may also need to transfer personal data outside of the European Economic Area to provide services to you, and, if we do, we will comply with Data Protection Laws in doing so; for those purposes, you hereby grant us your consent for us to process your data in that way. Further, and notwithstanding that we have a legitimate interest in processing the same, where we have received personal data of your employees, contractors or other representative, you confirm that their consent has been provided for the purposes of our processing that personal data in accordance with this Agreement, or another legal basis exists under Data Protection Laws to allow us to process that personal data in accordance with this Agreement.
2. Where we need to collect personal data by law, or under the terms of a contract we have with you under this Agreement, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you to provide services. In this case, we may have to cancel that contract, and we will notify you if this is the case at the time.
3. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying 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 from 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, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
4. By law we have to keep basic information about our customers (including contact information, and information about services provided and fees paid) for six years after they cease being customers.
5. We may use your personal data to make suggestions and recommendations to you about services or information that may be of interest, or benefit, to you. That is in our legitimate interest, to develop our services and grow our business. You can always opt-out of receiving these communications.
6. We may have to share your personal data with:
a) third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Agreement;
b) credit agencies to verify your identity, comply with money laundering prevent requirements and to ensure we are permitted to provide services to you; and
c) third parties such as service providers to the extent required to provide you with services.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. We have put in place 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.
8. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Under certain circumstances, you have rights under Data Protection Laws in relation to your personal data, being the right to:
a) request access to your personal data;
b) request correction of your personal data;
c) request erasure of your personal data;
d) object to processing of your personal data;
e) request restriction of processing your personal data;
f) request transfer of your personal data; and
g) withdraw consent to our processing of your personal data.
10. If you wish to exercise any of these rights, please contact our data protection manager, James Bowler. 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
11. We try to respond to all legitimate requests to exercise rights in respect of personal data within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
12. 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.