We are committed to protecting personal information. This statement explains how we collect and use personal information (i.e. information about an identified or identifiable living person).
What personal information we collect
We collect personal data where required by law or regulation, or where required in order to perform services agreed with our clients.
This may include email addresses and other contact information for our client contacts, identification of owners (for example to comply with Anti-Money Laundering regulations), job descriptions of client contacts and financial instruments held by individuals in our clients or other entities.
In general we only ask for and collect personal information from our clients where it is directly relevant for us to provide the services agreed.
Where we collect personal information from
Where we collect personal information, this is primarily sourced from our clients. The data requested and provided is that needed for us to fulfil our engagement.
In limited circumstances we collect personal information from public sources, including company annual reports and Companies House.
How we use your personal information
Personal information held by us may be used by us for any or all of the following (the list is no-exhaustive):
deliver professional services (legal grounds: legitimate interest in using personal information to provide, and our clients to receive, professional services)
verify identity where this is required to comply with other laws and regulations, including the verification of identity where required, and using the internet to determine if a person is Politically Exposed Person or subject to sanctions (legal ground: legal obligation)
communication by post, email or telephone (legal grounds: legitimate interest in using personal information to provide, and our clients to receive, professional services)
maintain records and administer our business. This may involve using third party information technology providers to store information offsite (for example our emails are administered by google and uses Google cloud technology) (legal ground: legitimate interest in using personal to maintain records and administer our business).
Who we share your personal information with
We share personal information in limited circumstances. This includes:
where we need to process personal data to provide professional services to our clients, we may share personal data in our deliverables (such as the reports we create). Such deliverables will be shared by us only with our clients unless our clients request us to share with their legal or other advisors, lenders and/or auditors; and
where required by law or regulations.
If you do not provide your personal information
If you do not provide personal information that is reasonably requested then this may prevent us being able to carry out our agreed scope of work. If personal information is required by law or regulation, not providing such information may prevent us from being able to engage to provide services.
Holding personal information outside the EEA
Although we do not physically store personal information outside of the EEA, we use third party information technology and cloud-based storage (for example provided by Google and Microsoft) which may store information on servers outside of the EEA.
Access to your information – You have the right to request a copy of the personal information about you that we hold.
Correcting your information – We want to make sure that your personal information is accurate, complete and up to date and you may ask us to correct any personal information about you that you believe does not meet these standards.
Deletion of your information – You have the right to ask us to delete personal information about you where:
You consider that we no longer require the information for the purposes for which it was obtained.
We are using that information with your consent and you have withdrawn your consent – see Withdrawing consent to using your information below.
You have validly objected to our use of your personal information – see Objecting to how we may use your information below.
Our use of your personal information is contrary to law or our other legal obligations.
Objecting to how we may use your information – You have the right at any time to require us to stop using your personal information for direct marketing purposes. In addition, where we use your personal information to perform tasks carried out in the public interest then, if you ask us to, we will stop using that personal information unless there are overriding legitimate grounds to continue.
Restricting how we may use your information – In some cases, you may ask us to restrict how we use your personal information. This right might apply, for example, where we are checking the accuracy of personal information about you that we hold or assessing the validity of any objection you have made to our use of your information. The right might also apply where this is no longer a basis for using your personal information but you don't want us to delete the data. Where this right to validly exercised, we may only use the relevant personal information with your consent, for legal claims or where there are other public interest grounds to do so.
Automated processing – If we use your personal information on an automated basis to make decisions which significantly affect you, you have the right to ask that the decision be reviewed by an individual to whom you may make representations and contest the decision. This right only applies where we use your information with your consent or as part of a contractual relationship with you.
Withdrawing consent using your information – Where we use your personal information with your consent you may withdraw that consent at any time and we will stop using your personal information for the purpose(s) for which consent was given.
Please contact us in any of the ways set out in the Contact information and further advice section if you wish to exercise any of these rights.
Changes to our privacy statement
We keep this privacy statement under regular review and will place any updates on this website.
This privacy statement was last updated on 27 February 2019.
Contact information and further advice
Please contact firstname.lastname@example.org for further information.
We seek to resolve directly all complaints about how we handle personal information but you also have the right to lodge a complaint with the Information Commissioner's Office, whose contact details are as follows:
Information Commissioner's Office
Telephone - 0303 123 1113 (local rate) or 01625 545 745
Website - https://ico.org.uk/concerns