1. THE PURPOSE OF THIS NOTICE
This notice describes how we, as a firm, collect and use personal data about individuals, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act [1998 OR 2018] and any other statute laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
You should read the following carefully in order to understand our procedures regarding your personal data and how we will treat it.
2. ABOUT US
Walker Thompson Ltd is registered in England and Wales under number 06574838 and our registered office is at Empress House, 43a Binley Road, Coventry
Walker Thompson Ltd trades as Walker Thompson Accountants and Registered Auditors.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’, which means that we are responsible for deciding how we hold and use any personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this Privacy Notice.
In accordance with the legislation we have appointed a Data Protection Officer. That Data Protection Officer is the principal point of contact for any matters relating to Data Protection within the company and is responsible for assisting with enquiries in relation to this Privacy Notice or our treatment of your personal data. Should you wish to contact our Data Protection Officer you can do so using the contact details noted below.(para 12)
3. HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you at various points in time , eg, when:
- you request a fee quotation from us in respect of any future work to be undertaken, perhaps during an initial meeting
- you as a prospective client or your employer or as one of our existing clients instruct us to provide our services and also during the provision of those services being carried out,
- you contact us by email, telephone, post, social media or video conference facilities eg; Skype, or
- from third parties or publicly available records (eg; Companies House) or from your employer.
4. THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you might typically include some or all of the following:
your personal details; ( Please note that GDPR does not include data held in respect of Companies, Charities, Not for Profit Organisations)
- name & address including e mail address, telephone number & any other contact details
- details of contact we have had with you in relation to the provision, or the proposed provision, of a service to be provided by us;
- details of any services you have received from us;
- our correspondence and communications with you;
- information about any complaints and enquiries you may have made to us;
- information from research, surveys, and marketing activities eg. Newsletters;
- Information we receive from other sources, such as publicly available information, information provided by your employer or our clients.
5. HOW WE MAY USE PERSONAL DATA WE HOLD ABOUT YOU
In accordance with the legislation we may process your personal data for purposes necessary for the performance of our contract with you or with your employer or with our clients and to comply with any legal obligations placed upon us.
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 the benefit of our own marketing, business development and management purposes.
We may process your personal data for certain additional purposes with your express consent, and in these very 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 that data.
Situations in which we will use your personal data
We may use your personal data in order to:
Undertake our obligations arising out of any agreements entered into between you or your employer or our clients and us (which will generally 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;
- 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, provided you have expressly consented in writing to be contacted for such purposes;
- seek your thoughts and opinions on the services we provide; and
- notify you about any changes to our fees & services.
In some circumstances we may fully anonymise the personal data so that it cannot any longer be attributed to 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 work which we have agreed to complete for you. Alternatively it is possible that we may be unable to comply with our legal or regulatory obligations.
In certain circumstances where we are required to do so we may also process your personal data without your knowledge or consent, in accordance with this notice.
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected from time to time.
When assessing what retention period is appropriate for your personal data, we will take into consideration:
- the requirements of our business and the services which we provide or have provided;
- any statutory or legal obligations placed upon us;
- any obligations placed upon us by our Regulatory body (ACCA)
- the original reason(s) for which we collected the personal data;
- the lawful basis upon which we based our processing;
- the nature of personal data we have collected;
- the amount and categories of your personal data; and
- whether the purpose behind the processing could be fulfilled by other means in a cost effective manner.
Change of purpose
Where we need to use personal data for any reason, other than for the purpose for it was first collected, we will only use such data where that reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
6. DATA SHARING
Can you share my personal data with third parties?
We will share your personal data with third parties only where we are required to do so by law, where it is necessary to update any administration between us or where we have any other legitimate reason to do 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 Services, IRIS Openspace and cloud services, professional advisory services, administration services, marketing services and banking services. In addition Third Parties will include Government Organisations & Departments such as HM Revenue & Customs and Companies House.
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 which will be clearly set out separately in our Terms & Conditions and in our Engagement Letters.
What about other third parties?
We may be required to share personal data with other third parties from time to time. Except for disclosure legally required, data will only be released to other third parties upon your express consent given in writing.
7. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We may transfer the personal data we collect about you to countries outside of the EEA.
Either, where there is an adequacy decision by the European Commission in relation to these countries therefore they are deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation or, where there is not an adequacy decision by the European Commission in relation to certain countries and they will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation, we have put in place measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation, such as binding corporate rules or model contract clauses.
8. DATA SECURITY
We have in place 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 order to achieve this we limit access to your personal data to those employees, agents, and other third parties who have a commercially based need to know. They will only process your personal data on our instructions and they are themselves bound by the GDPR and are subject to a duty of confidentiality.
We have in place 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.
9. RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that any & all personal data we hold about you is accurate and current. Should any of your personal information change, please notify us of such changes immediately by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have a 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 as may be relevant of any personal data that we hold about you.
- Request erasure of your personal data. ( sometimes referred to as the Right to be Forgotten )This exists to enable you to request that we delete or remove personal data where there is no justifiable reason for us continuing to hold or process it. You also have the right to ask us to remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data where there is something about your particular circumstances which makes you want to object to processing even when we are relying on a legitimate interest for that processing. You also have the absolute right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of any part of your personal data. This means that you may ask us to suspend the processing of personal data about you, should 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 written consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we reserve the right to charge a reasonable fee if your request for access is clearly without cause or excessive. In this regard where we ourselves incur fees for retrieval of data at short notice these fees will be re-charged to you and payment will be required in full before data information is released. Alternatively, we may refuse to comply with the request in such circumstances.
We will in most cases need to request specific information from you to help us confirm your identity and ensure that you are entitled to your right to access the information or in the exercise of any other rights This is an appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
10. 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 our monthly Newsletter 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 email@example.com
Once we have received notification that you have withdrawn your consent, we will no longer process your personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so.
11. CHANGES TO THIS NOTICE
Any changes we may make to this Privacy Notice in the future will be updated on our website.
This Privacy Notice was last updated on 21 May 2018.
12. CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Officer: firstname.lastname@example.org
You also have the right to make a complaint to the Information Commissioner’s Office (ICO) which is the UK supervisory authority for data protection issues.
The ICO’s 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
POLICY STATEMENT AGREED BY
Senior Management Team at Walker Thompson
And signed off on its behalf by
…………………………………. C Irvine. Director
21 May 2018